Alejandro Messineo

Practice Areas

Alejandro Messineo has been the partner in charge of the firm’s Tax department since 1997.

Career

He has worked in all areas of national and international tax law, providing general advice and tax planning. He has a wide experience on the problems of international taxation as well as safeguarding taxpayers in tax disputes with the tax authorities at different levels of government.

He has handled the tax planning of different businesses and transactions, such as international financing operations and corporate acquisition and reorganization schemes. He has also represented clients in tax assessment claims by the national, provincial and municipal tax authorities, including the National Tax Court, Appeals Chambers and the Argentine Supreme Court.

As a specialist in national and international taxation law, he has been recognized on numerous occasions by publications such as Chambers Latin America, Best Lawyers and Who’s Who Legal.

He is a professor of the Master in Tax Law of the Faculty of Law of the Austral University and Director of the Intensive Course in International Tax Law of the Austral University. He is a member of the Argentine Association of Fiscal Studies (former member of its board of directors) and of the International Fiscal Association (IFA). He is a member of the Board of the Bar Association of the City of Buenos Aires. He has also been National Rapporteur for Argentina before the IFA (EILAT 1999), where he was also a panelist (Boston 2012). He regularly lectures on different topics of tax law and is the author of several publications.

Professional Memberships

He is a member of the Argentine Association of Fiscal Studies (former member of its board of directors), of the International Fiscal Association (IFA) and of the Bar Association of the City of Buenos Aires (former member of its Board of Directors). He has also been National Rapporteur for Argentina before the IFA (EILAT 1999), where he was also a panelist (Boston 2012). He regularly lectures on different topics of tax law and is the author of several publications.

Publications

He is the author of several articles on international tax law published in journals such as International Tax Review special report on “Taxation of Directors and Employee Benefits (1994), the “International Transfer Pricing Journal” (IBFD), “Bulletin for International Fiscal Documentation” (IBFD),” “Tax Management International Forum” of which he was its member for several years (2008 through 2015) on these topics:

-Imputation to a Foreign Corporation of the Activities of Its Employee, Agent or Independent Contractor in Host Country, 2008.

- Outbound Redomestications and Reverse Acquisitions, June 1, 2008.

- The Viability of Treaty Shopping with Respect to Host Country, September 18, 2008.

- Tax Consequences of Cross Border Asset Reorganizations, 2008.

- Choosing an Optimal R&D Location: Consideration of Host Country's Income Tax Treatment, September 10, 2009.

- Transfer Pricing Audits, December 7, 2009.

- Determining the Interest Deduction of a Branch, PE, or Subsidiary, March 2010.

- Tax-Motivated Transactions — The Economic Substance Doctrine, June 4, 2010.

- Loan Guarantees — Does Deductibility Entail Taxability? September 06, 2010.

- The Audit Process, December 02, 2011.

- Tax implications of contingency convertible securities, June 15, 2012.

- Beneficial Ownership, December 30, 2012.

- Capital Gains Realized by Nonresidents June 30, 2013

- Income tax withholding and reporting obligations on cross border payments, December 30, 2013.

- Inbound Investment in Real Estate, June 30, 2014.

- Income and indirect tax consequences of inbound cloud computing transactions, December 1, 2014.

- Income and Estate, Gift and wealth tax consequence to inbound employee, June 7, 2015.

- Consistency requirements on inbound taxpayers in applying host country treaty provisions. December 7, 2015.

He has also been coauthor of several books writing on international tax such as:

- “The Tax Proceedings”, Editorial Depalma,2003.

- “Taxes on International Commerce”, Víctor Uckmar, Alejandro Altamirano and Heleno Taveira Torres, coordinators. Editorial Depalma, 2003.

- “Treaties for the avoidance of double taxation, controversial aspects” - Fernando García, Director, La Ley 2010, Buenos Aires.

Personal

Alejandro Messineo is the partner in charge of the firm’s Tax department.