Carmen Sanabria

Practice Areas

Tax; Family Office and High Net Worth; Corporate;

Career

Carmen is a partner in the Tax and Corporate Law practice areas at Dentons Cárdenas & Cárdenas in Bogotá, Colombia. She holds a law degree from Universidad del Rosario, a specialization in Tax Law from the same university, and a Master’s degree in International Business Law from the London School of Economics, where she was a British Government scholar through the Chevening (Simón Bolívar) Scholarship.

With over 30 years of experience, she provides expert counsel on a wide range of tax and corporate matters. She has advised national and multinational companies from various economic sectors on corporate and tax-related issues, and has represented clients before both administrative and judicial authorities in tax and parafiscal contribution disputes, including proceedings against the Colombian Tax Authority (DIAN), the Superintendency of Companies, and other governmental bodies.

She has advised companies on international investments, foreign exchange regulations, corporate law, implementation of tax planning schemes, project financing, and employee stock option plans, among other matters. Carmen has led major local and international mergers, spin-offs, and acquisitions.

More recently, she has led various transactions aimed at simplifying corporate structures using tax-efficient strategies, acquiring companies in Colombia, and reorganizing corporate or family structures to identify the most favorable tax alternatives.

Her practice is enriched by her previous experience at Arthur Andersen and the law office of Dr. Mauricio Plazas Vega. She has published articles in both national and international journals in the field of tax law and has spoken at conferences organized by the International Fiscal Association (IFA), the American Bar Association (ABA), and has served as a panelist for the Colombian Institute of Tax Law (Instituto Colombiano de Derecho Tributario). There, she has also acted as a peer reviewer and speaker on expert opinions in constitutional challenges before the Constitutional Court and nullity actions before the Council of State, at the request of the Institute’s Board of Directors, challenging tax regulations.

Professional Memberships

Member of the Editorial Board of the Journal of the Faculty of Jurisprudence at Universidad Colegio Mayor de Nuestra Señora del Rosario, Temas Jurídicos, from 1991 to 1993, selected through a competitive process.

Teaching Assistant, selected through a competitive process, for the course History of Political Ideas in 1991 at the Faculty of Jurisprudence, Universidad Colegio Mayor de Nuestra Señora del Rosario.

Publications

Co-author of the article “VAT-Exempt Services: Human Health” in the book Value Added Tax, Volumes I and II, published by the Colombian Institute of Tax Law, 2024

Critical studies of Tax and Customs Case Law, “Case law analysis of VAT on export of services. VAT on construction services. Opportunity to take deductible VAT,” Colombian Institute of Tax Law (Instituto Colombiano de Derecho Tributario - ICDT), Book VIII, Pages 75 to 89, 2019

"Value-Added Tax on Online Content," Global E-Business Law & Taxation, Oxford University Press, 2009

"Analysis of deductions on income tax," Reports of the XXX Tax Conference, Volume I, Colombian Institute of Tax Law, 2006

"The fight against tax havens," Tax Review, Editorial Legis, Number 107, September-October 2001

"The sources of international law," Journal of the Faculty of Law of the Universidad Colegio Mayor de Nuestra Señora del Rosario, No. 7, 1995

"The general principle of unjust enrichment," Journal of the Faculty of Law of the Universidad Colegio Mayor de Nuestra Señora del Rosario, No. 6, 1994

"Liability," Journal of the Faculty of Law of the Universidad Colegio Mayor de Nuestra Señora del Rosario, August 5, 1994

"White Paper of Guardianship," Journal of the Faculty of Law of the Universidad Colegio Mayor de Nuestra Señora del Rosario, No. 4, August 4, 1992

Experience

Inversiones Actual Colombia S.A.S.: Advised an international client in the construction sector on restructuring its corporate group to enhance tax efficiency and streamline its organizational structure. This involved assessing tax losses across three entities to optimize their utilization through several mergers.

WPP Media Management Colombia S.A.S.: Advised on a corporate reorganization process that involved a multiple spin-off and two mergers within GroupM Totvs Colombia S.A.S.: Analyzed the most tax-efficient approach for contributing Totvs México’s Colombian branch to an existing simplified joint-stock company (S.A.S.).

McGraw Hill: Advised the company on an international merger with Panama, followed by the integration of the branch of the absorbing company with the absorbed one.

Clorox de Colombia S.A.: Advised on tax matters in dealings with tax authorities regarding corporate income tax issues.

VML Group Colombia S.A.S.: Advised the company in several mergers with other group entities, including VMLY&R, C&C Action Marketing, and most recently The Cocktail America S.A.S.

Geometry Global Colombia S.A.S.: We advised the company on its merger with Grey Colombia S.A.S.

Levelma: We advised the company on a spin-off in favor of a partially related entity to achieve tax efficiencies.

Grupo Diana: We have advised the group on various corporate structures, capital reductions, and mergers aimed at a corporate reorganization with tax efficiencies.

Ártica Colombia S.A.S.: We advised the company on a corporate reorganization that included contributions in kind, mergers, and donations, in order to build a better structure for the generational transition and to achieve maximum tax efficiency.

Triada S.A.S.: We advised the company on both local and international mergers to achieve a corporate restructuring with optimal tax efficiencies.

Education

Languages Spoken

English

Italian

Spanish

Awards