Next Generation Partners

Tax in Bolivia

PPO Abogados

Administrative proceedings and litigation are core focus areas for PPO Abogados‘ tax team, which remains a go-to choice for clients seeking representation in disputes with the tax regulator and the Bolivian State. It also excels in representing clients in government tax audits and investigations. The group continues to expand the services it provides; it offers tax accounting, outsourcing and audit services and has increased its focus on digital economy taxation, wealth management and constitutional analysis of tax rules. The team demonstrates prowess in the design of tax structures and advice on the tax aspects of corporate and financial transactions, as well as international trade and customs matters. With a growing roster of national and international clients that spans various sectors, the team specialises in tax advice within the energy and natural resources, aeronautics and international transport industries. Tax specialist Pablo Ordóñez leads the team and has particular experience in the international commodities and oil and gas industries. Since July 2024, clients have additionally been able to draw on the expertise of José Luis Tufiño, who focuses on international and domestic taxation, tax planning and tax litigation (including tax litigation on appeal), and was hired from his own firm. This followed earlier consolidation of the department in September 2023 when Alexandra Ortíz was promoted to associate practice director; thanks to her expertise in international tax planning, she is a go-to advisor for foreign investors. At the senior associate level, Miguel Ángel Gumucio centres his practice on tax administration matters, including tax audits and enforcement, while Adrian Bellot represents clients in administrative and judicial proceedings before various governmental authorities and courts.

Responsables de la pratique:

Pablo Ordoñez


Les références

‘I recommend them for their expertise, follow-up, speed in responding and providing the best solutions in the process: before, during and after.’

‘High levels of knowledge in the area of ​​business promotions, constant updating and monitoring of each item.’

Principaux clients

Abbott


AkzoNobel


Avon


Ericsson


Latam Airlines


Makiber


WCS


Nestlé


DXN


Dufry


Principaux dossiers


  • Advising Abbott on tax and customs processes in administrative and judicial instances.
  • Advising AkzoNobel on tax matters and gambling regulations.
  • Advising Avon on all processes involved in the closing of its operations in Bolivia, including tax litigation aiming to mitigate the impact of debt collection, mitigating tax risks and providing tax compliance support.

Villegas Aldazosa & Asociados Soc. Civ.

Villegas Aldazosa & Asociados Soc. Civ.’s tax team remains a market leader in local and international taxation, transfer pricing and tax matters arising from M&A. The group works in tandem with the firm’s corporate and commercial and labour practices, providing a full-service offering to its expanding clientele. Family groups make up another key part of the team’s client base, and it has a strong background in wealth management and inheritance tax planning. Practice head Álvaro Villegas is a prominent figure in the tax field, providing expert advice on the tax aspects of corporate transactions and representing clients in tax litigation. Also at the senior associate level, Milenka Salvatierra represents both national and international companies in litigation, administrative and constitutional processes and is active in due diligence processes. Gabriel Villegas Aldazosa is another key contact in the team. Christian Olea left the firm in October 2024.

Responsables de la pratique:

Alvaro Villegas


Les références

‘Specialised attention from the main partner, who knows the tax issues and foreign structures for persons residing in Bolivia very well.’

‘It is a very cordial, friendly team, it responds in the priority requested, they are always willing to collaborate, they put themselves in the client’s shoes.’

‘Kindness, responsibility, transparency, precision, knowledge. I’d highlight Alvaro Villegas and Gabriel Villegas.’

Principaux clients

Industrias de Aceite


Alicorp


Milicom International Cellular (Telefónica Celular de Bolivia)


Granja Avícola Integral Sofía


Belia (Perú)


Drogueria Inti


Gedesa


Nibol (Nissan)


Shell


Agropartners


Ghenova


Ingeser


Elementia


Accor Hotels


Thermomix


Tropical Tours Travel Agency


Archer


Indatta


Principaux dossiers


  • Advised Alicorp (Perú) on the design and implementation of tax initiatives in its subsidiary Industrias de Aceite.
  • Provided guidance on the tax consequences and performed an in-depth risk evaluation for Millicom International’s M&A process of its communications towers in Bolivia.
  • Advising a client on a challenge of the Bolivian Tax Administration’s decision to disapply the Double Tax Treaty between Bolivia and Sweden, alleging treaty abuse to claim unpaid Withholding Tax on dividends.

Dentons Guevara & Gutierrez

Active in the filing of administrative, judicial and constitutional claims, Dentons Guevara & Gutierrez‘s tax team has a wealth of experience before the tax administration, particularly in matters related to the oil and gas industry. Working closely with the firm’s corporate, energy and administrative law departments, it participates in M&A and joint ventures, as well as the project financing of hydrocarbon and mining operations. The drafting of tax efficient structures and advice on tax contingencies also make up a core part of the team’s practice. Both local and foreign individuals in Bolivia turn to the team, which has an active wealth management practice. Mauricio Dalman leads the team, with a strong practice in national and international tax planning. He also plays a key role in multi-jurisdictional projects, advising on the tax aspects of transactions, reorganisations and restructurings. Rodrigo Rivera represents clients in tax and administrative litigation. Senior associate Belén Montes is another active member of the tax team, with experience in tax and customs consultations.

Responsables de la pratique:

Mauricio Dalman


Les références

‘Dentons focuses on knowing its clients and their needs.’

‘Without a doubt, the speed in serving clients is its greatest strength. Mauricio Dalman is always willing to support and resolve client concerns.’

‘Detailed knowledge of the topics, in addition to collaboration with the client.’

Principaux clients

SantaCruz Silver Mining


The Church of Jesus Christ of Latter-Day Saints


PepsiCo


Ferroviaria Oriental


Universidad Privada Franz Tamayo


Trafigura


Cervecería Boliviana Nacional


Construtora Queiroz Galvao


Repsol E&P Bolivia


Petrobras Bolivia


Explora


Total Energies E&P


SK Rental


Thales Group


VINTAGE PETROLEUM BOLIVIANA


TECPETROL DE BOLIVIA


Principaux dossiers


  • Represented Repsol E&P Bolivia in tax assessments, providing advice, analysis and solutions from a tax, constitutional and administrative perspective.
  • Assisting Santacruz Silver Mining in a review of local tax matters concerning five target mining companies and proposing solutions to identified matters.
  • Acted for TotalEnergies E&P Bolivia before administrative and judicial courts, challenging administrative resolutions requesting payment of $14m and $27m,.

Indacochea & Asociados

Working in tandem with the firm’s corporate, real estate, and banking and finance departments, Indacochea & Asociados‘ tax practice stands out for its advice on tax planning linked to corporate formations and reorganisations and the execution of related due diligence. It has extensive experience before the tax authority, handling claims concerning the rejection of tax credits and designing appeal strategies. The group has a successful track record representing clients in administrative and judicial proceedings. Practice head Candys Dorado has expert knowledge of tax regulations, based on extensive public sector experience, and also advises clients on customs law. Mariana Pereira plays a lead role in the reorganisation of companies and family estates, alongside Alonso Indacochea, who also collaborates with the tax team to advise clients on optimisation structures. Also bringing public sector experience, senior associate Dolly Salazar plays a lead role in the firm’s tax litigation work, representing clients before the tax administration and advising on the resolution of appeals.

Responsables de la pratique:

Candys Dorado


Les références

The lawyers have wide and recognised experience in the tax area: Candys Dorado and Dolly Salazar. Anwar Farah has extensive experience in legal commercial management. I’d highlight the firm’s ability to generate alternative strategies for the defence of tax processes.’

‘Experience of working in public government institutions, they know how to analyse and make observations.’

‘The team is constantly updated on tax regulations and economic changes in the environment.’

Principaux clients

Interconexión Eléctrica ISA Bolivia


ARG


Industria De Grasas y Aceites Industriales


Bayer Boliviana


Empresa De Embutidos Monserrat


Alta Estetica


Baker & Hughes


Inversiones Vaka


Compañia Industrial De Tabacos


Grupo Empresarial Del Oriente (Grupo Geo/Batebol)


Laboratorios IFA


Partners Group


Productos Alimenticios Sofía


Indatta


Empresa Agrícola Monica


Remaster Holdings


Imcruz/Inchcape


Principaux dossiers


  • Advising Bayer Boliviana on an administrative proceeding before the tax authority to disprove alleged local tax and transfer pricing debts.
  • Advising Grupo Geo on an administrative process before the tax authority to disprove alleged local tax debts.
  • Advising Interconexión Eléctrica ISA to obtain the tax refund of tax credits that belong to the client.

Moreno Baldivieso Estudio De Abogados

Moreno Baldivieso Estudio De Abogados‘ tax team is comprised of experts with extensive experience in the public sector and strong backgrounds in auditing and consulting. The team is well equipped to advise on tax regulations and guides firms throughout policy implementation. It is also regularly called upon to draft enforcement strategies and represents clients in tax audits. With expertise in international tax practices, the team has recently added companies to its roster of domestic and foreign clients. Practice head and senior counsel Rodrigo Burgos brings both in-house and public sector experience to the team, in addition to expertise as a qualified public accountant. He leads the team alongside senior associate Moises Blanco, who also draws on previous experience at the tax authority, and is an expert in tax regulation and consultancy. Senior associate Christhian Delgado joined the group in 2023, alongside his role as accounting outsourcing manager at the firm; he has experience advising multinational corporations across the mining, industrial, commercial and services sectors. The team was further strengthened in May 2024 with the hire of Luis Andrés Valda (formerly at Criales & Urcullo) as associate practice director.

Responsables de la pratique:

Rodrigo Burgos; Moises Blanco


Principaux clients

Archer Daniel Midland (ADM)


Claure Group


Super Abasto


Administración & Estructuras Phoenixtorres II


Empacar


El Deber


Premonor


Industrias Venado


Samsung Engineering Bolivia


Principaux dossiers


  • Advising Claure Group on the construction of a new stadium and training facilities, including navigating international transactions and devising a tax strategy to optimise advantages while ensuring legal compliance.
  • Representing Industrias Venado in two cases before the tax authority involving disputes over VAT fiscal credit miscalculations and their impact on company expenses.

Bufete Aguirre, Quintanilla, Soria & Nishizawa Sociedad Civil – (BAQSN)

Tax planning forms the core of Bufete Aguirre, Quintanilla, Soria & Nishizawa Sociedad Civil – (BAQSN)’s tax practice. The team has carved out a niche advising clients on the interpretation of treaties in order to avoid double taxation, and it is also active in both administrative and judicial litigation. Mauricio Torrico heads the tax team from La Paz, focusing his practice on tax and human resources planning. He also demonstrates expertise in administrative proceedings before the tax authority. Practice co-head Gonzalo Prudencio, based in Santa Cruz and with experience at the Bolivian IRS, litigates against resolutions issued by the tax administration.

Responsables de la pratique:

Mauricio Torrico Galindo; Gonzalo Prudencio


Principaux clients

Aldeas Infantiles SOS


Principaux dossiers


  • Advised Aldeas Infantiles SOS on structuring a foreign donation scheme.

Ferrere

Administrative and judicial litigation are core strengths of Ferrere‘s tax team, which represents clients in disputes with the tax regulator and the Bolivian state. With its roster of international clients, foreign trade and customs matters are also focal points for the group. Collaborating with the firm’s consulting services branch, the team covers general tax consulting, tax structures and the tax aspects of corporate and financial transactions. Senior associate Mauricio Viscarra leads the team and his practice spans advice on tax planning, contingencies and litigation, particularly in relation to international commodities and oil and gas. Viscarra also represents both local and international clients in tax litigation before administrative and judicial bodies. Senior associate Christian Olea joined from VILLEGAS ALDAZOSA & ASOCIADOS Soc. Civ. in October 2024.

Responsables de la pratique:

Mauricio Viscarra


Principaux clients

Cargill


Amazon


Ingener Sucursal Bolivia


Remote


EOCORP


HBO


Marriott International


Dufry


HIG Capital


Glencore


Tigre


Logicalis


Schlumberger


Jindal Steel


Brightstar


Moove


3M


MOBILEMEDIA


PRO ANI


Principaux dossiers


  • Representing a Schlumberger subsidiary in a tax proceeding for payment of municipal patents for $242,590.
  • Representing Cargill Bolivia in several tax proceedings related to tax credit for $4.7m.
  • Representing 3M in an audit proceeding initiated by the Tax Administration.

Criales & Urcullo

The tax department at Criales & Urcullo has a reputation for assisting clients with tax planning, audits and inspections, as well as for its estate planning capabilities, and is currently in a process of reorganisation following the May 2024 departure of former practice head Luis Valda. His departure leaves the practice best positioned to handle auditing matters, where both Rubén Acuña Zalles (who has over 20 years at the firm) and Diego Mojica have considerable experience.

Responsables de la pratique:

Rubén Acuña Zalles


Les références

‘High level of knowledge of the Bolivian legislation and regulations.’

‘They gave us very good tax advice, trying to minimise any contingencies that we could have with national taxes. Their team is made up of specialists who are lawyers and accountants, which makes the advice more precise.’

‘The lawyers are quite detailed in their advice, and they are also very efficient in their response times.’

Principaux clients

Telefónica Celular de Bolivia


HOMEPAC


Carl Dean/Servisur Agrícola


UNIFRANZ


Banco FIE/ONG FIE


Panamerican SAFI/Panamerican Securities


Importadora de Ideas


IKM Holding (Adler Family)


Grupo Empresarial Lafuente


Inmobiliaria Upgrade/Smartbuildings


Principaux dossiers


  • Assisted Homepac’s shareholders with the tax-related aspects of the company’s acquisition by Multicent.
  • Assisted Panamerican SAFI in a tax inspection concerning the services rendered by Fundación IES to one of the funds managed by the client.
  • Assisted Agrosur with tax due diligences for the acquisition of a local industrial company from a multinational company.

EY Bolivia

Benefiting from the firm’s international reach, EY Bolivia advises local and multinational clients on investments and incorporations into Bolivia. The firm has also noted an increase in tax litigation, and tax audits have been another recent focal point. Juan Pablo Vargas leads the team, alongside Sandra Vásquez as senior manager, who specialises in tax consultancy and due diligence and advises on the tax aspects of both national and international transactions. Following a promotion in 2023, Nicolas Soria Galvarro continues to support on tax audits and due diligence, as well as assisting with customs matters.

Responsables de la pratique:

Juan Pablo Vargas Ramos; Sandra Vásquez


Les références

‘EY is a practice with extensive experience in complex issues.’

‘Juan Pablo Vargas has extensive experience in various practice situations in Bolivia. Senior Manager Sandra Vasquez is a person with extensive expertise in relations with tax administration and audits.’

Principaux clients

Cervecería Boliviana Nacional


ZTE Bolivia


Saexploration


Nuevatel PCS de Bolivia


Halliburton Latin America


Compañía Americana de Inversiones – CAISA Agencia de Bolsa


Qhawaq Mining Andina


Gasoducto Virtual Sener Indox Bolivia


EY Chile


BIG Bolivia Investment Group


Principaux dossiers


  • Advised Cervecería Boliviana Nacional on different projects of the company and provided support in tax audits.
  • Provided Nuevatel PCS de Bolivia with tax advice on different projects.
  • Advised Qhawaq Mining Andina on different tax audits related to mining tax credit recovery for different periods before the Bolivian Tax Administration and on an appeal before Autoridad de Impugnación Tributaria, obtaining first instance rulings in favour of the company.

Würth Bedoya Costa Du Rels Abogados

Würth Bedoya Costa Du Rels Abogados specialises in succession planning for family assets. The team provides its clients with comprehensive tax planning services, covering tax matters in the corporate and business sectors, drafting tax strategies and tax-efficient structures. It also represents clients in proceedings before the tax authorities and in tax disputes. Practice co-head Fernando Bedoya is an expert in Bolivian tax regulations and is regularly sought out for advice on fiscal and estate structuring. He leads the team alongside Daniela Ayoroa Taborga, who has a wealth of experience in tax matters and brings public sector experience at the tax administration to the group.

Responsables de la pratique:

Fernando Bedoya Alipaz; Daniela Ayoroa Taborga


Les références

‘The WBC tax team has very good people skills and is very collaborative.’

‘Fernando Bedoya is very supportive to the tax team. Daniel Ayoroa has a lot of knowledge in his area of ​​​​specialty and has good relationships.’

Principaux clients

Torre Balesia


Nuevatel PCS de Bolivia


Bussarf


Laboratorios Crespal


Charles Petts


Bizarro Bolivia


Alex Steward


Leo Briner


Juan Carlos Cochamanidis


Laboratorios Maver


Fundación para la Producción – Fundapró


Principaux dossiers


  • Provided comprehensive tax planning and assistance to Torres Balesia, focusing on compliance and tax efficiency optimisation.
  • Represented Nuevatel PDC de Bolivia in a complex tax dispute against a Notice of Assessment by the Servicio de Impuestos Nacionales, with a deal value of $8,189,655.
  • Developed a strategic tax framework for Laboratorios Crespal in the pharmaceuticals and healthcare sector to ensure tax efficiency and compliance.