Partner - Tax Litigation Practice

Mexico City


+52 55 55409200




Highly Regarded

Spanish
English


Jurisdictions:

Mexico

Practice areas:

Tax controversy


Denise is highly committed to jurisdictional processes as well as to her professional development and that of her team. She has over 20 years of experience specializing in strategic tax litigation, becoming an expert in complex proceedings before tax authorities and Procuraduría de la Defensa del Contribuyente (Prodecon).

As leader of this practice, Denise has been able to reverse criteria that previously shaped jurisprudence. She has analyzed issues ranging from procedures carried out by tax authorities, such as the temporary restriction of digital seals, to the filing of means of defense, which established precedents that have served as guidelines for the resolution of new cases, as well as for the interpretation and application of tax provisions and international treaties.

She has developed excellent relationships with tax authorities. This allows her to expedite administrative and litigious processes, creating legal benefits and added value for the Firm’s clients. Denise has advised high profile clients including, Tata Consultancy, Grupo Femsa (Coca-Cola), Blue Marine, and others. She always seeks the best solutions to meet client needs and accompanies them in each stage of any process, including those client´s whose cases ascend to the Supreme Court of Justice.

Denise’s partner appointment (2020) honors her extensive experience in tax litigation and marks another milestone in Galicia’s efforts to promote gender diversity, a topic that is very dear to her as well. Denise has been deeply involved in Pro Bono work and has overseen several major litigations that challenge reforms detrimental to women lawyers.

In addition, she has written several articles on tax litigation, addressing the analysis of jurisprudential criteria and unconstitutionality. She has also participated in seminars such as International Fiscal Association’s (IFA) International Treaties.

Denise graduated from her professional studies with honors and continues to demonstrate the same discipline and passion in her daily work.

She is recognized as an expert lawyer by renowned international publications, such as Chambers and Partners, Women in Business and The Legal 500. She is also identified as a leader in her practice by specialized publication International Tax Review (ITR) World Tax.

Denise's trajectory has earned her the 2023 ITR | World Tax Latin America Litigation & Disputes Leader of the Year award, placing her as a tax litigation leader in the Mexican and Latin American legal market and reflecting her deep comprehension of an ever-evolving tax landscape.

Denise is a member of Galicia’s Diversity, Equity and Inclusion Committee.

Dispute resolution:

  • Audit defence
  • Dispute resolution
  • Pre-litigation
  • Litigation
  • Controversy management

  • Accounting
  • Banking
  • Construction and materials
  • Consumer goods and services 
  • Energy
  • Financial services
  • Food and beverage
  • Gaming
  • Government and public policy
  • Healthcare
  • Industrials
  • Insurance
  • Investment management
  • Media
  • Mining
  • Natural resources
  • Oil and gas
  • Pharma and life sciences
  • Real estate
  • Social infrastructure
  • Tech and telecoms 
  • Tourism
  • Transport 
  • Utilities

  • Participated as co-leader for issuing a legal opinion (second reviewers) regarding the defense strategy in an important tax audit. Moreover, assisted in the request of the conclusive agreement submitted before the Mexican Taxpayer Ombudsman (Procuraduría de la Defensa del Contribuyente); regarding the observations determined by the tax authority within the tax audit regarding the fiscal year 2014, amounting to approximately MXN $1,754,600,989.
  • Lead counsel to assist a multinational conglomerate (based on India) on several tax audits, whose tax contingency amounts up to approximately more than USD 100 Million. In such audits, Denise and her team provided solid arguments to sustain the deductibility of IT payments, as well as to ensure a 0% VAT rate, among other issues.
  • Participated as co-leader of an audit and the conclusive agreement for 2018, in connection with VAT issues related to a renowned brokerage house. The involvement of Galicia’s tax team, whose contingency amounts to approximately USD $1,000,000, was significantly valuable in distinguishing between the tax treatment applicable for a bank and a brokerage house before the tax authorities.
  • Lead counsel for an important maritime carrier, in several refund requests of VAT balances amounting approximately to MXN $ 72 Million, corresponding to several months from 2011 – 2013. The tax team thereby argued the applicability of a 0% VAT rate. However, the tax authority rejected that balance requested, arguing such rate was not applicable since the taxpayer had a PE.
  • Participated, jointly with other Law Firms, to co-assist a Foundation in challenging several tax provisions originated from an important recent tax reform.

Denise is highly committed to the jurisdictional processes she is responsible for, as well as to her professional development and that of the people on her team. She has over 20 years of experience specializing in tax litigation, honing her skills as an expert in complex proceedings before the tax authorities and the Mexican Taxpayer Ombudsman (Procuraduría de la Defensa del Contribuyente).

In her practice, Denise has been able to reverse criteria that had already shaped jurisprudence. She has analyzed issues ranging from procedures carried out by the tax authorities, such as the temporary restriction of digital seals, to the filing of means of defense through which precedents have been established that have served as guidelines for the resolution of new cases, as well as for the interpretation and application of tax provisions and international treaties.

She has developed excellent relationships with the tax authorities. This allows her to expedite administrative and litigious processes, creating legal benefits and added value for the Firm’s clients. Denise always seeks the best solutions to meet the needs of its clients, as well as accompanying them in each of the stages of any process.

The appointment of Denise as partner of Galicia in 2020 is the result of the recognition of her extensive experience in tax litigation but also marks another milestone in Galicia’s efforts to promote gender diversity, a topic that is very important to her as well. Denise has been deeply involved in pro bono work and has overseen several major litigations to challenge some reforms that are detrimental to women lawyers.

In addition, she has written several articles on tax litigation, addressing the analysis of jurisprudential criteria as aspects of unconstitutionality. She also participated in seminars such as “International Treaties” given by the International Fiscal Association (IFA).

Denise graduated from her professional studies with honors and continues to demonstrate that discipline and passion are key in her day-to-day work.