Mexico

Mariano Escobedo 573

Col Rincón del Bosque

11570 México, DF

Mexico

Tel: + 52 55 52638571

Email: adolfo.calatayud@mx.pwc.com

Website: www.pwc.com.mx

Adolfo Calatayud is the leading partner of the tax controversy practice in Mexico. He has more than 16 years of professional experience in transfer pricing and international tax services for private and public companies.

He is the president of the Transfer Pricing Commission of the Mexican Institute of Public Accountants, and an active member of the International Tax Commission of the Mexican Board of Public Accountants.

In his role as TCDR lead partner, Adolfo has participated in several tax audits, bilateral and unilateral advance pricing agreements (APAs) and mutual agreement procedures (MAPs).

Before becoming a partner at PwC, Adolfo was part of the Mexican Tax Administration Service, acting as director of audits to foreign residents, within the International Tax Division.

Adolfo has two postgraduate degrees in international taxes (ITAM and Duke University), as well as an academic major in international taxes (Tax Studies Institute and the Ministry of Public Finance in Spain).

PT de La República 3304, Piso 1

Ciudad Juárez, Chihuahua

México, 32330

Mexico

Tel: +52 656 629 1346

Email: luis.carbajo-martinez@bakermckenzie.com

Website: www.bakermckenzie.com

Luis Carbajo has extensive experience in the areas of international tax planning, mergers and acquisitions, permanent establishment, cross-border transactions, inter-company pricing, taxation of non-resident entities and individuals, corporate taxes and other taxes such as the value added tax, flat tax, and in planning and litigation on social security contributions and other local and municipal taxes.

Luis has been the lead counsel on tax audits and tax litigation on complex subjects, including the following:

• Tax litigation related to the tax treatment for multi-million incentives received by companies for research and development centres located in northern and central Mexico, securing favourable court rulings;

• Challenges of multi-million tax assessments issued against pharmaceutical companies for disallowed deductions, securing favourable resolutions;

• Handling of complex tax litigation related to the tax treatment of charter payments to non-residents without a permanent establishment in Mexico, securing favourable court rulings;

• Handling of tax litigation of royalty payments to software developers;

• Tax litigation related to transfer reports challenged by the tax authority, securing favourable verdicts acknowledging the present reports as well as rulings ordering the adjustment of the transfer pricing reports;

• Handling of complex tax audits with observations concerning royalty payments, exchange losses and gains, technical assistance services;

• Successful handling of tax audits related to the application of maquiladora tax incentives;

• Assisted international companies on the tax treatment for charter hire payments to non-resident companies, securing favourable resolutions.

Luis received a law degree from the Universidad de Guanajuato in Mexico, a certificate on special studies of administration and management of the Harvard University in 1994 and a joint degree international tax programme/LLM of Harvard Law School in 1995, and finished a transfer pricing specialisation jointly offered by the Universidad Anahuac and the Spanish Universidad de Cantabria.

Hera 76, Col Crédito Constructor

México, DF CP 03940

Mexico

Tel: +52- (55)56632190

Mob: +52- 1 (55) 15107536

Email: ccastaneda@kroy.com.mx

Website: www.kroy.com.mx

Cesar Castañeda is the partner in charge of the international and domestic tax practice of Mexico's highly-specialised firm Kroy Abogados.

His constant ability to provide useful insight and tailored advice has allowed him to create room for himself among the most renowned tax practitioners in Mexico for the pharmaceutical, energy, oil and gas, food, IT, insurance, transportation, and many other industries.

For more than a decade, Cesar has successfully provided tax advice and handled tax-related litigation, including:

• International tax planning;

• Business structure for Mexican projects;

• Interpretation of double taxation treaties;

• Transfer pricing;

• Payment, withholding and refund of taxes;

• Tax audits; and

• Real estate.

Cesar is member of the International Fiscal Association and is a former member of the YIN committee (Young IFA Network). He has attended seminars and conferences organised by the College of Public Accountants of Mexico, the Mexican Institute of Finance Executives, Mexican Bar Association and other tax and accounting organisations.

Before becoming a partner at KROY Abogados, he worked for more than 10 years in one of the most respected law firms in Mexico where he was the head of the litigation and tax audit areas.

Cesar obtained his law degree at the Escuela Libre de Derecho, where he was awarded for his professional thesis and subsequently completed the master's programme in tax law at the Universidad Panamericana. He has also acted as tax law professor in the Escuela Libre de Derecho and the Escuela Bancaria y Comercial, and as speaker in front of the Mexican Chamber of Representatives within the context of the latest tax reforms.

Languages: English and Spanish.

Paseo de la Reforma 505

Col Cuauhtémoc

06500 México, DF

Mexico

Tel: +52 55 50 80 70 23

Fax: +52 55 50 80 60 01

Email: rgonzalezorta@deloittemx.com

Website: www.deloitte.com/mx

Ricardo González Orta is a Deloitte Mexico partner, leader of Deloitte Mexico's tax and legal practice and the business tax leader for Deloitte member firms in Latin America. Ricardo is based in the Mexico City office where he advises multinational companies on tax-related matters, including controversy issues with tax authorities on domestic and international matters, structuring new businesses, acquisitions, reorganisations, joint ventures, double taxation issues and transfer pricing. Ricardo is the former leader of the Deloitte Mexico business tax practice and, from 2001 to 2010, served as the Latin American transfer pricing leader for Deloitte member firms in the region, as well as the Deloitte Mexico transfer pricing leader.

Before joining Deloitte, Ricardo spent eight years in a number of top executive posts with the Ministry of Finance and the Mexican Tax Administration Service.

From July 1999 to November 2000, Ricardo was general director of tax and customs policy at the Under Ministry of Income, where his duties included designing tax and customs policy. In this position, he negotiated the Mexico-US intergovernmental transfer pricing agreement in the maquiladora industry. Before this, he acted as general director of legislation and international negotiations (1998 to 1999), where his main functions included drafting tax and customs legislation, negotiating double-taxation treaties, and representing the Mexican government in international forums (especially at the OECD).

From March to June 1998, he was general director of international tax affairs at the Tax Administration Service (formerly Under Ministry of Income of the Ministry of Finance and Public Credit). Primary responsibilities included transfer pricing audits, the negotiations of advance pricing agreements, the issuance of private letter rulings regarding foreign residents with Mexican source income, the exchange of tax and customs information with other countries and the performance of audits and issuance of rulings in line with Mexico's free trade agreements. Before this, he was assistant general director for international audits (1993 to 1998). In this position, Ricardo created the international audit programme, which included transfer pricing inspections, negotiating advance pricing agreements, drafting the 1997 tax reform on transfer pricing, the inspection of international transactions, audits of origin pursuant to Mexico's commercial agreements, acting as competent authority for the exchange of tax and customs information, and inspection of Mexican residents with investments in low-tax jurisdictions.

Ricardo is a frequent speaker in different national and international forums. He writes periodically for the International Management Tax Journal on domestic and international topics. For almost a decade he has been named by Euromoney as a leading transfer pricing and tax adviser.

Ricardo graduated from the Universidad Iberoamericana.

Paseo de la Reforma 505, Piso 23

Colonia Cuauhtémoc

06500 México, DF

Mexico

Tel: +52 55 5080 6600

Email: jorjimenez@deloittemx.com

Website: www.deloitte.com/mx

Jorge Jiménez Cañizares obtained his law degree from the Escuela Libre de Derecho, in Mexico City in 1986; a certificate in tax law from the Universidad Panamericana, in Mexico City in 1987; and a certificate in corporate law from Escuela Libre de Derecho in 1995. He has been a Deloitte Mexico partner in the firm's tax and legal practice since February 2014. He joined Parás Asesores Fiscales, S.C. from 1989 and became a partner in 1991.

His practice covers consulting in general corporate taxation, VAT (national and international operations), international taxation, double taxation treaty application, and customs law, and he leads the firm's practice dedicated to the tax consulting and defence services for financial and insurance institutions, as well as regulatory aspects of the same. Additional practice includes assistance regarding audits by tax authorities, general tax litigation and amparo litigation.

He is an active member of the Mexican Bar Association and the Academy of Tax Studies of the Public Accounting Profession. Jorge is included in the Chambers & Partners Legal Publishers list of leading business lawyers in Latin America, as a lawyer with a superb reputation for tax work with insurance companies and financial institutions.

Mariano Escobedo 573

Col. Rincón del Bosque

11570 Mexico, DF

Mexico

Tel: +52 55 52638684

Email: fernando.lorenzo@mx.pwc.com

Website: www.pwc.com.mx

Fernando is a legal partner of the tax controversy practice. He has more than 18 years of experience in national and international taxes for private and public companies.

Under his responsibilities, he negotiated several mutual agreement procedures under tax treaties (including the MAP that led to the inclusion of LLC's as beneficiaries under the US-Mexico tax treaty) and has served as a delegate for Mexico in the OECD's Tax Treaties and Related Matters working group where he drafted paragraphs that were included in the OECD Model Tax Convention commentaries.

Fernando has vast experience in both consultancy services and tax litigation on international tax and transfer pricing matters. Moreover, he has been engaged in important projects that have successfully resolved international disputes in different industries through mutual agreement procedures (MAPs) and BAPAs between the Mexican Competent Authority and the competent authorities of different jurisdictions.

He has also published different articles including those published by International Tax Review and International Tax Journal.

He is member of the Barra Mexicana Colegio de Abogados, the American Chamber of Commerce and the International Fiscal Association (IFA).

Fernando was graduated as a lawyer from the Escuela Libre de Derecho and has a master's degree in taxes and international commerce from the University of Warwick in the UK.

Av Lazaro Cardenas 2321 Pte PB

Col Residencial San Agustín

Monterrey 66260

Mexico

Tel: +52 81 81337360 x7360

Email: gmanideita@deloittemx.com

Website: www.deloitte.com

Gonzalo Mani is a Deloitte Mexico partner and national leader for tax litigation. He has been with Deloitte for 15 years. His principal area of expertise is tax litigation. He has 20 years of experience in trial law related to complex tax matters and has helped clients challenge tax laws which have set national judicial precedents.

Gonzalo has been a professor at Iberoamericana University, La Salle, and Anahuac del Sur. He has also taught degree programmes at the Bank and Commercial School in Mexico City and in the Public Accountants School of the Public Accountants Institute in Nuevo León, Mexico.

Gonzalo has written several essays on tax topics, the vast majority of which have been published in leading Mexican tax publications. He has advised writers of the business section of the newspaper El Norte, one of the most prestigious newspapers in Mexico. He is a regular speaker in the most important tax lectures organised by universities and professional organisations.

Gonzalo studied law at the Anahuac University in Mexico City. He later graduated with a master's degree in tax law from Panamericana University. He later completed another qualification in tax law at the Anahuac University and in civil law at the Escuela Libre de Derecho. Gonzalo also earned a degree in common law from the Universidad Autonoma de Mexico in Mexico City. Gonzalo is now pursuing a master's degree in business and corporate law at the University of Monterrey (UDEM).

Gonzalo is a member of the Mexican Lawyers Bar Association and the National Tax Specialists Association (ANEFAC) Chapter Monterrey.

Paseo de la Reforma 489, P 6

Col Cuauhtémoc

México, Distrito Federal 06500

Mexico

Tel: +52 55 50807040

maumartinez@deloittemx.com

Website: www.deloitte.com

Mauricio Martinez-D'Meza has been a business tax partner at Deloitte Mexico since October 2002. His areas of expertise include domestic and international tax planning, tax controversy and tax litigation.

He served for nine years in the Ministry of Finance before joining Deloitte as assistant chief counsel for large taxpayers, assistant general director for international tax policy and treaty negotiations and assistant chief counsel for domestic taxes.

From 1999–2001 he was a partner at Baker & McKenzie in Monterrey. From 1995-1997 he served as representative for the Ministry of Finance before the US and Canadian government for tax and customs affairs in Washington, DC.

He got his bachelor's law degree in 1993 from the Instituto Tecnológico Autónomo de México (ITAM). He holds a postgraduate degree from Harvard-ITAM (international taxation programme).

Mauricio has taught in several universities including the Instituto Tecnológico de Estudios Superiores de Monterrey (2010-present) postgraduate degree in taxes. Litigation and defence processes; Universidad Anáhuac del Norte: tax law II (January – June 1999) & political history (1998); Universidad Iberoamericana: tax law I (1998); Instituto Tecnológico Autónomo de México: Mexican taxation (1995).

Edificio Scotiabank Inverlat, Piso 12

Blvd M Avila Camacho 1

México DF 11009

Mexico

Tel: +52 (55) 5279 2924

Email: jorge.narvaez-hasfura@bakermckenzie.com

Website: www.bakermckenzie.com

Jorge Narváez has more than 28 years of professional experience to back him up as an international corporate tax, transfer pricing and tax and administrative litigation specialist.

On July 1 2005 he was appointed chairman of the Latin American tax practice group and became a member of the Global Tax Steering Committee of Baker & McKenzie. His term ended on June 30 2009. During all this time he also acted as member of the global transfer pricing sub-group of Baker & McKenzie. As of July 1 2009, he was appointed chairman of the Latin American VAT practice group and member of the Global VAT Steering Committee of Baker & McKenzie.

On May 2012 he was appointed by the Mexican President as an independent counselor of the Office of the Taxpayer Advocate's Governing Board (Prodecon) recently created in Mexico. Graduated from the Escuela Libre de Derecho, with a master's of law from the University of Notre Dame and other postgraduate studies at Harvard University, ITAM and the International Bureau of Fiscal Documentation.

As of 2013, Jorge has been appointed as member of the Global Financial Committee of Baker & McKenzie representing Latin America.

He is a member of the Tax Law Commission of the Mexican Bar Association, the International Bar Association and the International Fiscal Association as well as a founding member of Legislative Tax Analysis (ATRIL).

Jorge has sucessfully represented over the years a relevant number of 500 Fortune companies on tax consultancy and tax litigation matters.

Mariano Escobedo 573

Col Rincón del Bosque

11570 México, DF

Mexico

Tel: + 52 55 52636124

Email: sergio.perez.cruz@mx.pwc.com

Website: www.pwc.com.mx

Sergio Pérez is a partner in PwC's tax controversy and dispute resolution practice in Mexico. Before joining the firm, Sergio held a high level position at the Mexican SAT's Large Taxpayers Administration. Over his more than eight year career at SAT, besides leading a large transfer pricing audit team, he also was in charge of the APA programme and conducted Competent Authority negotiations for bilateral APA's and mutual agreement procedures with other tax administrations. His areas of expertise include tax policy, cross-border transactions, operational restructurings, transfer pricing, PE issues as well as settlement negotiations, audit management and tax conventions.

As a delegate of the OECD's Working Party 6, Sergio was involved in the Business Restructuring Project and also in the Comparability and Profit Methods Project which resulted in guidance that was included in the latest version of the OECD's Transfer Pricing Guidelines. He also collaborated in the Intangibles Project and was part of focus groups on specific subjects for the BEPS initiative. Within the framework of the OECD Global Forum on Transparency and Exchange of Information, Sergio was appointed by Mexico as an evaluator and reviewed OECD and non-OECD tax jurisdictions for the project.

Sergio is an economist from the Instituto Tecnológico Autónomo de México (ITAM) one of the world's leading economics schools, where he was recognised with an Academic Excellence Award, but he also attended México's National University (UNAM) where he studied physics with an emphasis in nuclear sciences. His strong mathematical and analytical skills and his international experience contribute to his ability to develop innovative solutions in transfer pricing, international taxation and competent authority negotiations.

Mariano Escobedo No. 573

Col. Rincón del Bosque

CP 11680 México, DF

Mexico

Tel: +52 (55) 52-63-57-34

Email: karina.perez.delgadillo@mx.pwc.com

Website: pwc.com/taxcontroversy

Karina Pérez is the lead tax partner for the financial sector in Mexico and also provides support to Adolfo Calatayud's tax controversy and dispute resolution team in Mexico. Karina has experience in successfully solving complex international tax controversies in different industries such as the financial sector, consumer products, pharmaceutical, automotive, telecommunications, oil and gas. She is a partner that has practised in the area of international taxation for more than 25 years and has recognised experience in competent authority processes, managing audits and settling disputes; she maintains close contact with competent authorities around the world.

Before working at the firm she worked at the Central Bank and occupied for 17 years different relevant positions at the Ministry of Finance and the Tax Administration Service (TAS). Under these responsibilities she negotiated 44 of the Mexican tax treaties, including the treaties and protocols with the US, Germany, UK, Germany, Netherlands, Switzerland, Spain, Canada, Ireland, Singapore, Brazil, India, Chile; she also negotiated exchange of information agreements with the US and Canada. Karina worked on proposed tax legislation and regulations regarding international transactions, issued international private rulings and was the competent authority in several mutual agreement procedures for treaty application with different jurisdictions. She was responsible for the registry for foreign financial institutions and pension and investment funds and was in charge of administrating reporting obligations regarding the placement of securities abroad.

As part of her functions as the legal counsel of the Large Taxpayers Unit she issued technical and operational guidelines applicable to central and field officers for the legal, audit and collection offices. Being a tax official she was the delegate for Mexico at the OECD in different working groups (including, for example, the Committee of Fiscal Affairs, Working Group 1, Treaties and Related Issues). Karina has been for several years a member of the IFA Mexican branch and participates actively at the case law committee of this association where advisers, tax officials and tax judges discuss international controversies on a regular basis. She has participated in different publications where she provides her expertise based on her recognised knowledge of Mexico's treaty practice and policy, including those published by International Tax Review. She graduated as a lawyer from the Escuela Libre de Derecho.