LATAM Regional Profile (Tax Controversy)

Firm name: Deloitte

Region: Latin America

Address: Paseo de la Reforma 505, p.28, Colonia Cuauhtémoc, 06500, Mexico City, Mexico

Phone: +52 (55) 50807040

Website: https://www2.deloitte.com/mx/es/services/impuestos.html?icid=top_tax

Offices: México, Guatemala, Costa Rica, El Salvador, Honduras, Nicaragua, República Dominicana, Panamá, Colombia, Perú, Ecuador, Venezuela, Bolivia, Argentina, Uruguay, Paraguay, Chile, and Brazil

The Deloitte tax controversy practice in Latin America includes one of the largest teams of professionals and partners of any Big Four in the region, covering 18 countries. From Mexico to Argentina, Deloitte tax controversy professionals are engaged in services, including supporting clients with their interactions with tax authorities, i.e., audits, refunds, domestic and international negotiations, and litigation at all levels. Negotiations include formal processes, where applicable, and discussions with tax authorities during audits.

DTTL’s tax controversy practices include a strong international conflict resolution specialization, i.e., mutual agreement procedures (MAP) and arbitration, as per the double taxation treaties signed throughout the region.

Our tax controversy practice handles high-profile cases for clients with a very high-resolution rate. The biggest practices are in Brazil and Mexico, with over 100 professionals and 15 partners alone in Mexico City. Our areas of specialization include constitutional challenges, domestic and international tax controversies, foreign trade and transfer pricing, and local taxation.

Deloitte tax controversy practices in the region include seasoned litigators and tax lawyers with many years of handling controversy. We are also constantly developing digital tools to further streamline our services and interaction with our clients, the judicial branch, and the tax authorities.

Our professionals also teach at prestigious educational institutions in the region and are leading members and participants in technical, industrial, and commercial forums.

Deloitte’s tax controversy practice includes tax lawyers with many years in private practice who have either grown within the Deloitte ranks or joined Deloitte from other successful firms.

We also have a strong practice in terms of negotiations with tax authorities, both formal and informal. Finally, our success rate in terms of litigation resolved in the taxpayer’s favor is well above 90%.

Deloitte is now one of the largest tax practices in the region. This means that much of the tax advice throughout Latin America is provided by Deloitte. As a multidisciplinary organization, it also means that our tax controversy practitioners have in-depth knowledge of our clients’ tax positions and their interactions with the tax authorities of their respective countries.

Deloitte has implemented digital control of litigation and controversy processes that, where available, is directly connected to the local court’s database, getting live notices of the steps in a particular process.

Deloitte tax controversy professionals in the Spanish Latin America region mostly excel at litigation, with their success rate supporting the taxpayer’s position above 90%. In addition, our tax controversy practice has a very high success rate in negotiating favorable settlements for our clients, thus avoiding litigation whenever possible.

Our key service offerings

Legal and constitutional litigation related to federal and local taxes.
Formal and informal negotiation processes.
International controversy solution processes, i.e., mutual agreement procedures and arbitration.
Legal analysis of complex tax advice.

Awards

In 2022:

Deloitte in the Americas region won the ITR Indirect Tax Firm of the Year, Tax Compliance and Reporting Firm of the Year, Tax Innovator of the Year, Tax Technology Firm of the Year, Transfer Pricing Firm of the Year, and North America Transfer Pricing Firm of the Year awards.
Deloitte LATAM won ITR’s Transfer Pricing Firm of the Year award.
Deloitte S-LATAM won ITR’s Transfer Pricing Firm of the Year awards for Argentina, Central America, Uruguay, and Venezuela.
15 Transfer Pricing leaders were recognized in ITR’s 2023 World Tax guide from a total of 34 for all Americas, including the Big Four leaders.
4 Indirect Tax leaders were recognized in ITR’s 2023 World Tax guide from Colombia and Mexico.
11 Tax Controversy leaders were recognized in ITR’s 2023 World Tax guide from Argentina, Mexico, and Peru.
14 leaders were recognized in ITR’s 2023 World Tax guide for Women in Tax from Argentina, Colombia, Costa Rica, Guatemala, Mexico, and Peru.
Legal 500 recognized 12 tier rankings and 35 lawyers in Argentina, Chile, Colombia, Guatemala, Mexico, and Uruguay.
Chambers & Partners ranked Deloitte Legal Mexico and recognized eight lawyers in Mexico, Costa Rica, Guatemala, Peru, and Uruguay. Ten professionals were acknowledged as notable practitioners across five jurisdictions in Mexico, Costa Rica, Guatemala, Peru, and Uruguay.