Firm / Organisation

Chevez, Ruiz, Zamarripa y Cia., S.C.

This content is provided by Chevez, Ruiz, Zamarripa y Cia., S.C..

Managing Partners: José Luis Fernández, Manuel Sainz, Iván Moguel
Number of partners: 52
Number of lawyers: 111
Languages: English, Spanish, German

Firm Profile:
Chevez Ruiz Zamarripa is a leading tax firm in Mexico, known worldwide for its expertise in high-level tax advisory and consulting, transfer pricing, social security and administrative litigation services.

The firm is proud of being one of the first to offer high-quality tax and administrative services in the Mexican market, providing the innovation, honesty and professionalism needed in today’s world for solving highly complex matters.

Chevez Ruiz Zamarripa has developed a code of conduct that guides its work performance based on the laws and regulations, as well the ethical and social principles that apply to this profession. The firm has an in-depth understanding of the importance of social responsibility, concentrating its efforts onto pro bono activities, working with institutions centering on education, health and children’s well-being, as well as environmental protection.

Chevez Ruiz Zamarripa has several offices within Mexico (Mexico City, Monterrey and Querétaro) and two additional offices located in New York and Madrid.

Main Areas of Practice:
The range of professional practices include an expanded tax advisory and consulting area, tax and administrative litigation services and a specialised international trade and customs division with an area solely dedicated to transfer pricing.

Tax Consulting:
In-depth research at CRZ supports the development of tax strategies that maximise ROI, generate additional working capital for company operations and increase per-share profits. A change in corporate structure gives rise to a variety of tax implications. At CRZ, the accountants and lawyers analyse each client’s situation on a case-by-case basis, assessing the impact on its organisation; from there, they identify tax scenarios and develop recommendations designed to create the optimal restructuring model for each unique situation. The firm aims to assist its clients regarding complex audits practiced by the tax authorities and resolving them, among other means, by alternative dispute resolution mechanisms such as mutual agreement procedures, advanced pricing agreements, as well as representation before the Mexican Tax Ombudsman.

Key considerations include:
■ Engineering complex operations, such as corporate restructuring, mergers and acquisitions, all of which CRZ professionals are experts at
■ A tax-related cost/benefit analysis of each proposed strategy
■ An in-depth analysis of regulations governing both federal and local taxes
■ Evaluation and proposal of applications for special authorisations as required by revenue agencies or other government entities
■ Specialised collaborations with Mexican market securities law experts for solutions involving share and investment instrument placements on stock exchanges in Mexico and around the world
■ Support in determining the corporate structure that will enable clients to optimise their participation in various infrastructure contracts as with the analysis of possible tax implications that may result from these participations

Tax Litigation:
The tax litigation area specifically offers advice and defends against the actions of the tax authorities when they are in violation of taxpayer rights or the tax law, or when the authorities fail to respect taxation guarantees, considering each client’s particular matters.

With regards to tax audit procedures, the firm drafts the documents that must be submitted to the tax authorities, from the beginning to the conclusion of the procedure, and meet with the tax authorities to present the arguments. When the firm’s clients decide to draft these documents themselves, lawyers take care to provide all the pertinent advice so that their case will have a positive outcome, including the latest precedents issued by the judicial authorities on the topic.

The firm also supports clients concerning appeals for reconsideration against the rulings issued by the tax authorities, as well as in proceedings for annulment before the Federal Court of Tax and Administrative Justice or in amparo proceedings before the Federal Judicial Branch, drafting and submitting them to the respective authorities. The firm ensures that these are followed up on a timely basis, meeting with the judicial authorities to present arguments, addressing the particular questions of each matter and attending the proceedings until the corresponding rulings are issued or a definitive conclusion is reached.

Administrative Litigation:
The administrative litigation team focusses on formulating knowledgeable responses to the challenges generated by the enforcement of the constantly changing laws and regulations. It also focusses on the defence of clients from any legal actions carried out by the federal or local authorities and relevant consequences related to the concession of public services and activities, certification, registry, authorisation, permit, license as well as closing down, suspension, recall, fines and other penalties.

International Trade:
This area includes a specialised international trade and customs division and an area solely dedicated to transfer pricing. CRZ experts leverage opportunities and utilise the best possible tools to focus on three critical issues: minimising risk, reducing production/operational costs and boosting ROI via high-profit transactions. They also offer guidance with regard to operations governed by free trade agreements, optimal import/export mechanisms, international traffic cost reduction, and tax/customs risk management. CRZ international trade experts also specialise in analysing global market productivity and profitability requirements to design one-of-a-kind, forward-thinking strategies that optimise the financial benefits of clients’ import/export mechanisms.

Transfer Pricing:
Transaction analysis is a CRZ specialty in Mexico and abroad that forms the basis for strategies that minimise the tax burden for every type of entity. Solutions include transfer-price analysis for regulatory compliance, Advance Pricing Agreements (APA), negotiation and alternative dispute resolutions, value-assessment of companies, shares, transactions and intangibles, and audit support. Additionally, CRZ provides solution-oriented economic and trade analyses on matters arising from dumping and other unfair international business practices. CRZ’s transfer-pricing team of economists, legal, and tax specialists leverages state-of-the-art financial, economic, and accounting analyses to add value to every possible area of client operations.

Additional Areas of Practice:
The firm also has experience in anti-money laundering, energy, corporate risk prevention and anticorruption. Its service is grounded on keeping up to date and is focused on ensuring its clients’ satisfaction by being fully committed to dealing with their needs.

Clients:
CRZ provides services to major industrial, commercial and financial groups. The firm has a prominent presence with Fortune 500 companies operating in Mexico. Further information is available upon request.