Chile

Albagli Zaliasnik is a full-service law firm offering full integrated tax services, including strategic tax planning, investment tax modelling, advice on financing, structuring for the acquisition, divestment and sale of companies, and intra-group and family offices restructuring. It advises some of the world’s largest companies across all sectors, such as Airbus, Accenture, Farmacias Ahumada, Walmart, Empresas La Polar, Bodegas San Francisco, Mitsubishi, Thompson Reuters and Louis Vuitton.

During the research period, the firm advised XIAOMI on tax issues for the framework of the incorporation of the firm in Chile, as well as its initial activities (set-up structure, investments, amongst others).

The firm welcomed senior associate Pablo Trucco and junior associate Guillermo Ulloa during the research period.

Client feedback

“Ability to listen, assertiveness, creativity, perseverance.”

“Precise, commercial focus, accurate, understanding of our company's needs.”

The team at Allende Bascuñán & Cía is led by Francisco Javier Allende, a renowned expert in both domestic and international taxation matters. It is a leader in high-net-worth individuals’ tax and legal assistance, providing professional advice to more than 30 family offices (Chile’s wealthiest families), in asset protection and allocation, tax and corporate structuring, project finance, wills and estate law, long-term wealth management planning, and both domestic and offshore investment schemes.

The firm continues to assist Talbot Hotels in international tax matters and corporate restructuring, and in developing its investments in the USA.

Client feedback

“Throughout his extensive career, Francisco Javier Allende has shown a unique leadership and capacity to build up highly qualified teams. A clear example of that has been the incorporation of Mauricio Carloza as a partner of the international tax practice, then improving the quality of their services by improving the substance of their international structures and widening the alternatives to go through when setting up a business.”

“Transparency, mastery of the subject, seriousness and agility in decision making.”

The tax department at Aninat Abogados provides a wide range of services including identifying and restructuring the tax effects of operations, assisting clients in aspects related to income taxation, VAT, stamp tax, heritance tax, payments of debts, and day-to-day counselling. The team consists of five professionals from the tax field.

Details of the firm’s work and clients remains confidential.

The tax team at Arteaga Gorziglia has in-depth of experience in tax advice, tax planning, auditing and litigation. The group works with a variety of sectors including finance, retail, real estate, energy and chemical. Andrés Ossandón leads the tax team.

During the research period, the firm advised AME – HIF with tax analysis and the execution of a cross-border reorganisation that was aimed to consolidate HIF’s projects in Chile, the United States and Australia, under a new parent company formed in the USA (HIF Global). Its legal counsel was focused on the identification in the drafting of documents and identification of the tax implications.

The firm welcomed senior associate Gonzalo Guerra during the research period.

Client feedback

“Excellent knowledge of the local legislation. Always focused on customer satisfaction. Absolute fulfilments of due dates.”

“Arteaga Gorziglia & Cía's tax practice has a great capacity to pay strong attention to details and has the ability to think on its feet.”

Baker McKenzie in Chile is experienced in the fields of technology, finance, pharmaceutical and mining. The team is supported by a regional and global network with dedicated industry group specialists. It advises on tax planning, tax controversy, international tax and industry-specific tax issues. The team is led by the partner Alberto Maturana who has more than 30 years of experience in corporate M&A and foreign investment matters.

Details of the firm’s work and clients remains confidential.

Baraona Marshall’s tax department is led by Alejandro Abuyeres. It provides active advisory services to local and international clients within an ample scope of tax advisory areas, including general corporate matters, M&A, financing, implementations, transfer pricing, tax compliance, tax planning and the structuring of property of companies and individuals. The tax litigation team has extensive experience in representing national and international clients.

Details of the firm’s work and clients remains confidential.

Partner Francisca Villamán left the firm to pursue tax court during the research period.

Client feedback

“Excellence, seriousness and great experience.”

“The team is really close to the business and have really good expertise in the industry.”

Barros & Errazuriz Abogados is well known for its extensive experience and broad scope of services as advisors for corporate clients as well as private clients. The firm has a strong practice in tax structuring and implementation both on a national and international level.

On an ongoing basis, the team provides advisory services to the Compass Group regarding general tax matters and, more specifically, on the taxation of investment vehicles and instruments in the capital market.

BaseFirma in Chile was founded in 2013. The team has experience in different sectors including engineering and construction, mining, retail and finance. Bruzzone & González is a leading independent law and tax advisory firm with a significant presence in Chile. In 2019 BaseFirma Chile and Bruzzone & González Abogados reached an agreement for the latter firm to join BaseFirma’s Transfer Pricing Alliance. This alliance consolidated a premium services portfolio for Chilean clients, allowing both firms to deliver a broad spectrum of services in the fields of TP, customs and international tax planning. The firm assists its clients in a variety of practice areas including corporate and finance, antitrust, dispute resolution, corporate tax, intellectual property and overseas investments.

During the research cycle, the team performed various transfer pricing audits for clients that remain confidential.

The firm recently welcomed Eduardo Vera as a manager, previously from KPMG.

Bofill Mir Abogados is a full-service firm with experience in a variety of businesses matters from a tax perspective, such as international taxation including international clients who operate or have investments in Chile and for local clients operating or looking to expand abroad. The team is regularly involved in M&A processes regarding the structuring of the business. Core industries include mining, real-estate and project developers, airline-related matters and investors.

One example of the firm’s work saw it providing legal advice to Mitsui Mineral Resources Development Latin America regarding the utilisation of PPUA credit. In addition, it assisted the client in the modification of certain loan contracts which could affect the application of thin capitalisation grandfathering rules.

During the research period, senior associate Paris Norambuena departed to Lembeye. However, the firm welcomed two new senior associates as well: Josefina Da-Bove and Claudio Palavecinos.

A leading firm in Chile, Carey is among the top players in the tax area. The group includes lawyers, accountants and one economist, and it excels in tax planning, consulting, and litigation. It is regularly involved in the structuring of the most complex, national, and international transactions. The group works in different sectors, including energy, infrastructure, technology and financing. It is led by partners Jaime Carey, Jessica Power, Manuel José Garcés and Manuel Alcalde

Details of the firm’s work and clients remains confidential.

Client feedback

“Assertive, knowledgeable and practical.”

The tax department at Chirgwin advises clients on various matters related to tax consultancy in Chile. While it has an extensive range of clients, the industries in which it is most active are consumer products, energy, media and entertainment, professional services, transportation, international trade and pro bono work. Chirgwin is the Andersen Global collaborating firm in Chile.

Details of the firm’s work and clients remains confidential.

The tax team at Claro & Cia advises on corporate law, litigation, M&A, capital markets, banking and project finance. It assists national and multinational companies covering both domestic and cross-border transactions.

One recent example of its work saw the team advise Hortifrut in leading its international restructuring process. The work done involved the transfer of the foreign subsidiaries of the group to a newly created holding company in Ireland. The structuring process involved more than 15 jurisdictions and the team oversaw coordinating the various law firms involved.

Client feedback

“They are very assertive, proactive, knowledgeable and reliable. They are used to international transactions. They follow up closely on the cases and besides they have both the legal and accounting vision which gives an upgrade.”

“They are very detailed in their analysis and all details requested by the client are considered in their tax advice.”

“Very clear at explain pros and cons of each decision.”

“Serious work, professionals with extensive legal and tax knowledge, and extensive experience and reputation.”

“Responsiveness, client empathy, understanding of client's needs and business.”

“Clear, practical, timely and relevant tax advice.”

“Clear instructions, willingness to discuss findings, and comprehension of comparative legislation.”

“The team are excellent on all areas of international tax planning. They have real depth and breadth of knowledge. They are extremely responsive and commercial and deliver advice on time. They are highly trusted advisors and the best we have used in the Chilean market. They showed far superior tax technical knowledge than the Big 4 accounting firm that was involved. Claro are clearly a Tier 1 firm.”

“Involvement of senior partners in the process; agility the provision of the services; proactive approach; innovative solutions to the problems raised.”

“Claro & Cía is one of the top legal offices in Chile. The taxes team led by Nicolás Maturana works with ethics, transparency and efficiency. They are truly trustworthy in their advice, always certain and close to their clients.”

“Huge experience in tax matters.”

“The partner and his team are very well prepared in terms of legal and practical knowledge. The professionals are very approachable and willing to assist quickly. They review the issues in a global and integral way, giving added value to the consultations made.”

“Great experience, updated knowledge, involvement with in-house team.”

“Excellent team combination on contract management and tax planning.”

CMS Carey & Allende handles a wide range of tax matters, such as national and international tax planning, indirect taxes, M&As and double taxation. The firm assists local and multinational corporations, as well as high-income individuals and families.

Details of the firm’s work and clients remains confidential.

Associate Patricia Campos left the firm during the research period. The team also welcomed three new associates: Matías Ramírez, Josefina Vera and Juan Francisco Gutiérrez.

Cuatrecasas is an international law firm with more than 1,700 professionals across 27 offices located in 13 countries. It is a full-service law firm with specialisation in 28 areas of practice. The tax department has 470 professionals that cover several areas in tax law, such as financial and corporate, indirect tax, international tax, M&A, litigation, private client and wealth management, as well as transfer pricing and tax governance.

The firm recently acted as counsel to Brookfield in the structuring and acquisition process of a majority stake in Solarity. This deal marked the entrance of the client into the renewable energy sector in Chile, a currently expanding market.

During the research period the firm welcomed partner Rodrigo Stein and senior associate José Miguel Gazitúa from KPMG Chile.

Since its opening in 1923 the global accounting firm has been tied to the Chilean market, developing a strong tax planning, consulting and advisory practice. Moreover, since 2015 Deloitte Chile and Deloitte Canada have combined their operations to provide more services in North and South America. Deloitte is one of the largest tax and legal services providers in Chile and it focuses on M&A transactions, family offices, litigation and transfer pricing. In addition, the team advises clients on the impact of the BEPS on their operations.

One example of the firm’s recent work saw it advise a Chilean multinational retail group. The scope of the services included the diagnosis, design and implementation of a new company engaged in high-value activities. The analysis included a new transfer pricing model that enables the group to comply with the tax and transfer pricing regulations in force in all the jurisdictions involved in the new TP model.

During the research period the firm welcomed two senior managers, Javiera Ruidiaz and Maria Fernanda Becker, in addition to new partner Susana Zamora and director Jorge Martinez.

Client feedback

“World-based and can use different sources around the globe easily.”

“Deep knowledge of our sector, the jurisdictions where we operate, and our internal strategy.”

Eluchans Abogados has a historic practice dating back to 1914. The firm is focused on corporate law and M&A matters. The team’s tax practice has extensive experience advising foreign and domestic companies on tax planning and investment projects. There are seven partners leading the tax legal practice.

Details of the firm’s work and clients remains confidential.

Client feedback

“They carry out serious and professional work in the entrusted subjects.”

The tax practice at EY offers services across all tax disciplines, including corporate tax, international tax, transactional, compliance and reporting. The international tax practice focuses on non-deal related cross-border issues like holding company structuring, cross-border finance, and treasury and income treaty interpretation. The tax practice consisting of more than seven partners is led by Javiera Contreras. It has four offices across the country.

Details of the firm’s work and clients remains confidential.

Client feedback

“Diligent, fast and good resolutions, well stated resolutions, forward looking, support the whole process also giving good people to apply the plan.”

“A professional service; people aware of our needs and great analytical capacity.”

Fischer y Cía has a wealth of experience assisting clients on corporate tax and private wealth. The team is comprised of both lawyers and auditors who can represent clients before the Chilian IRS in disputes matters and tax litigation, and offer comprehensive compliance service. Name partner Alex Fischer leads the team.

Details of the firm’s work and clients remains confidential.

The tax team at Garrigues Chile consists of six associates and is led by Oscar Ferrari. The team are experts on tax planning for complex transactions, working both autonomously and alongside the labour, corporate, banking, finance and projects teams of the firm’s international network to create effective tax structures for complex deals.

During the research the tax team provided tax advice to DERCORP on its domestic and cross-border restructuring to implement a combination of its business with Inchcape. The legal and tax advice included items regarding tax provisions for acquisition agreements and documentation, tax aspects of local and foreign financing, as well as tax advice on the shareholders’ disposition of shares.

HD Legal provides services such as tax process, corporate, capital market taxation and family business matters, providing legal advice in such areas including national, international, general, and hereditary tax planning. The firm has provided tax advice in the process of the designing and structuring of relevant investment projects (inbound and outbound), as well as providing advice to international business groups when acquiring relevant local assets. HD specializes strongly in serving clients in the securities and financial markets and fintech, including tax advice on these matters.

During the research period the firm advised Fynsa Administradora General de Fondos in structuring an investment fund with Rockville for investing in the development of solar energy projects. This client is currently being advised in the process of selling developed projects by the fund.

Client feedback

“They have been very proactive.”

“They know very well our industry and how we could have a better approach regarding tax issues.”

Since its foundation in 1994, Larrain & Asociadios Abogados has developed a tax practice focused on tax consultancy and litigation. Víctor Manuel Avilés is the head of the tax department. The firm has an emphasis on tax planning and on administrative and judicial cases at different level. It represents corporation and family offices on tax reorganisation and planning.

Details of the firm’s work and clients remains confidential.

The tax team at MBC Abogados is fully equipped to advise companies on all types of tax matters, covering local and international business restructuring as well as investment structuring, family wealth and business advisory, general tax consultancy, taxpayer defence before tax and administrative authorities.

During the research period, the firm advised Grupo Patio with the tax planning to structure the association with AFP Habitat to develop industrial rental projects in Chile. The advisory included discussions regarding the reorganisation required to contribute the assets previously owned by Grupo Patio in the industrial rental area. The work also included the support and assistance with the preparation of the closing documents.

Client feedback

“Attitude; commitment and lawyers’ expertise.”

“Provide good ideas on how to structure.”

“Not too conservative but not aggressive. Innovative solutions.”

Mena Alessandri & Abogados is best known for its private client practice. It provides advice to high-net-worth clients on structuring investment vehicles, locally and internationally with an emphasis on tax compliance in both jurisdictions. The team also advises local companies on tax compliance issues and transactional tax.

During the research the team provided advice to Nexus (owners of Nueva Más Vida) in acquiring Colmena Salud.

The firm recently welcomed two new lawyers, Ignacio Calderón and Pedro Sánchez.

Founded in 2020, Misraji & Béjar specialises in business law and corporate tax, real estate, and transactional matters. The team has more than 10 years’ experience with assisting various clients across industries such as telecommunications, investments, real estate projects, financial services, retail, technology and more. Founding partner Camilo Bejar is the key figure leading the practice.

During the research period, the firm provided tax advice on a new project/product for Aki KB. The tax team is advising the tax structuring of this new business. In addition, the firm provided general corporate advice for Novo Nordisk regarding their entire Chilean corporate tax portfolio, regularly giving them general corporate tax advice.

Client feedback

“Fast, clever solutions, technological.”

“They excel in providing legal advice and representation to individuals, businesses, and organisations on tax-related issues.”

“The office delivers personalised and accurate services with updated information and advice. As a client I have had a permanent perception that all staff members are genuinely interested in finding the best integral solutions that apply to my tax profile.”

“Very proactive, accessible, knowledge.”

“MBA employs highly skilled and experienced lawyers who possess in-depth knowledge of the law and can provide expert legal advice and representation to their clients. It is well-established, with a proven track record of successfully handling complex legal cases and delivering favorable outcomes for clients.”

“Fast response, very good knowledge of different tax matters affordable fees.”

“Precise and assertive advice.”

The tax team at Morales & Besa is best known for its knowledge and experience in complex cross-border tax matters. The practice includes highly specialised lawyers with experience in tax analysis and planning, tax compliance issues, administrative processes with the local internal revenue service and tax litigation.

During the research period, the firm advised Cencosud in the purchase of 67% of The Fresh Market Holdings and the financing granted by Bank of America and HSBC. The firm is equipped to advise on transactions of this nature.

Corporate tax and private wealth are the primary focuses of the tax team at Philippi Pietrocarrizosa Ferrero Du & Uría. The firm also advises on tax planning and structuring and M&A transactions. It represents national and international clients and is active in an array of sectors including banking, natural resources, agriculture and telecommunications.

During the research period the team advised multinational firm America Móvil on the structuration of a 50/50 joint venture with Liberty Latin America which will concentrate approximately 45% of the Chilean Telecommunications market. The work done included tax aspects including cross-border mergers, analysis on tax attributes, and the separation and liquidation of entities outside of the JV’s framework.

The firm welcomed associate Carlos Tadres from the Ministry of National Assets during the research period.

The full-service tax and accounting firm at Puente Sur is comprised of more than 110 professionals, including lawyers, economists, and CPAs. The firm advises its client on tax controversies, as well as producing the relevant documentations and reports for tax compliance, and in support during disputes. Partner Ignacio Gepp is the head of the firm’s tax team.

During the research cycle the team represented Edge Connex before the Chilean IRS with voluntary audit processes that lead to a VAT refund associated with its CAPEX investments, which resulted in several million dollars of successful VAT claims. The team worked on preparing all the necessary documentation to be presented to the audit and drafted the argument.

Client feedback

“They provide a very good service at a lower price than other firms with similar technical skills. This is much appreciated by our clients.”

“Puente Sur is a great advisor, responsive and presents knowledge of the matters put in front of them.”

“Immediate responses, concise and to the point advice, excellent knowledge of the indirect tax landscape of the country, pro-active, excellent contacts.”

With offices in 152 countries and almost 328,000 people, PwC is among the leading professional services networks in the world. The team helps organisations and individuals create the value they are looking for by delivering quality in assurance, tax and advisory services.

Details of the firm’s work and clients remains confidential.

Client feedback

“The Chilean team are knowledgeable and timely in their advice. The team has strong communication skills.”

“PwC Chile have a complete knowledge of Chilean tax as well as international tax. Based on this experience, they provide complete answers, considering all angles that may affect the transaction, not only tax but legal, accounting, admin and other consequences.”

Recabarren & Asociados has been in the market for five years and has a broad client base ranging from publicly traded companies to family offices and high-net-worth individuals. The team specialises in local and international tax consulting, transactional tax, tax controversy and indirect tax. The team is led by Soledad Recabarren.

During the research cycle, the team represented its client in dispute resolution before the Chilean tax administration and legal representation in tax matters before Tax and Customs Courts, and Superior Courts of Justice in Chile. The resolution of this case may set precedents for jurisprudence in Chile.

Partner Gloria Flores departed the firm during the research period.

The law firm at Russi & Eguiguren | Quadrant has focused its tax legal practice on corporate and transactional tax, wealth management advice, tax compliance and tax controversy. The team has experience representing various clients before the Chilian IRS. The boutique firm comprises lawyers and accountants to offer a customised service for all clients. Tax partners Gonzalo Rivera and Jaime Rosso are the key point of contact.

The team has been dedicated to navigating tax efficient ways to invest funds in Chile and abroad while taking into consideration the possible outcomes of the new tax reform, as well as the increase of consultations related to tax re-domiciliation due to the tax reform that is intended to be applied in Chile, which contains a new wealth tax. An example of this is with its work advising BTG Pactual Chile, Brazil and Miami.

Partner Jaime Rosso left the firm during the research period.

Torretti & Cia includes 20-tax specialised attorneys, plus eight accountants and a team of paralegals and other team members. The team is tax-specialised with a strong practice in international taxation, foreign investment, corporate taxation, tax litigation, and private clients.

The team was recently hired by Territoria for structuring a tax-efficient alternative to sell a real estate development project to Santander Bank, aimed to be the banks new headquarters in Chile. The structure proposed was successfully approved.

David Fischer departed the firm during the research period to pursue a solo practice. The firm welcomed three new seniors: Paula Espinosa, Francisco Larios and Marco Apablaza.

Client feedback

“The team is exceptional and professional. They have a lot of knowledge; they are updated with legislation and always answer the most complex of questions. They also have soft skills and solid technical knowledge. Javiera and Eduardo are proactive advisors.”

“They are the best tax practitioners I've worked with. They are fast, creative and business oriented. They come with concrete solutions and always having our interest in mind. They are experts in international taxation and are able to coordinate experts in other jurisdictions, so they act as our permanent advisors even for foreign matters.”

TPC group is a firm specialised in transfer pricing consulting. It advises multinational companies, providing tax planning service and reviewing transfer pricing reports.

Details of the firm’s work and clients remains confidential.