Edson Uribe

Edson is passionate about tax controversy. His creativity, technical expertise and drive have allowed him to become a key player in the design and implementation of innovative dispute resolution mechanisms in Mexico. His unique profile and record of accomplishments are of great value to the Firm’s client base.

Before joining the Firm as a partner in 2019, Edson served as Deputy Chair of the Mexican Tax Ombudsman Agency (Prodecon). Earlier in his career, he acted as a litigant attorney for the Mexican Tax Administration and as senior law clerk in the Federal Tax Court.

Edson has outstanding abilities to identify tax risks in complex transactions. His experience in handling alternative dispute resolution procedures allows him to implement long-term, preventative actions on potential disputes before the tax authorities.

The professional sensitivity acquired throughout his career allows Edson to act as trusted advisor both for corporate clients facing complex business problems and for individual taxpayers he defends in pro bono matters.

His relationship-building skills and extensive international network helped him participate in academic tax research projects in countries, such as the United States, Austria, Switzerland, Netherlands, England, Poland, India and China.

Edson is an active member of the recognized Foundation for International Tax Dispute Resolution, based in The Hague, Netherlands. From 2017 to 2021, he was the only Mexican to be part of the Subcommittee on Dispute Avoidance and Resolution under the United Nations Tax Committee.

He is recognized as an expert by renowned international publications, such as The Legal 500 and ITR World Tax, in the Tax Controversy practice.

He holds a master’s degree in Taxation from Universidad de Guadalajara, where he lectures as a visiting professor.

Corporate tax matters:

• APAs

Dispute resolution:

• Audit defence
• Audit support
• Dispute resolution
• Pre-litigation
• MAPs/ADRs
• Controversy management

• Banking
• Consumer goods and services
• Financial services
• Government and public policy
• Mining
• Tech and telecoms

• Advice and legal support to one of the largest automotive companies in the world in the negotiation and implementation of a successful Bilateral Advance Pricing Agreement (BAPA) between the Mexican and US tax administrations.
• Successful tax advice to one of the largest telecommunications companies in the world in the handling of tax disputes that arose before its operation in the Mexican market. These controversies include audits, tax mediation procedures and technical opinions as an expert in Mexican tax law for the preparation of litigation in foreign courts.
• Design and implementation of risk prevention actions in tax matters, for the benefit of one of the largest Spanish banks in the world, in the refinancing of an electric power project in Mexico, through a special purpose vehicle.

Edson is Member of the United Nations Subcommittee on Dispute Avoidance and Resolution of the Committee of Experts on International Cooperation in Tax Matters.

Edson is passionate about the Academy. For many years he has been a professor of tax subjects in both undergraduate and postgraduate degrees and master's degrees at prestigious Mexican universities.

He is a member of the National Executive Committee of the International Fiscal Association (IFA) in Mexico. He is also a member of various relevant associations in tax matters such as the Mexican Institute of Public Accountants and the Academy of Fiscal Studies.

Edson wrote in 2015 a book on tax mediation in Mexico that was published by Thomson Reuters and which to date is the mandatory reference in Mexican tax literature on alternative dispute resolution.

He has also written for international platforms. Particularly noteworthy is his participation as the sole Mexican co-author in the work "Felixible Multi-Tier Dispute Resolution in International Tax Disputes" published by the International Bureau of Fiscal Documentation (IBFD) in 2020.

Edson also participated as co-author of the work "Cocktail of measures to control the harmful manipulation of transfer prices, focused on the context of low-income and developing countries" published in 2019 by the Inter-American Center for Tax Administrations (CIAT) and the German Agency for International Cooperation (GI).