Julio Pino Caballero
Our team has gained relevant experience and know-how on comprehensive tax advisory for infrastructure projects, which allow us to take charge of the design and implementation of tax structures for such type of projects, the preparation of the record of tax assumptions, the identification of controversial aspects and the management strategy, the assessment of tax implications of the many alternatives for financing the project, and the hiring of Derivative Financial Instruments, the advisory to evaluate the tax aspects of the financial model, the review or due diligence of tax assumptions of the financial model, etc.
Topics such as those relating to the EPC Contract, supplies from abroad, early VAT recovery, customs taxes, infrastructure’s accounting cost and depreciation, financing costs, pre-operating expenses, IFRS effects, transfer pricing, among others, are deeply analyzed by our team to reassure the various participants of the project and, in particular, to make the project’s bankability viable.
In addition, we support our clients in the formalities required for executing Legal or Tax Stability Agreements and Guarantee Agreements with the Peruvian Government, to register foreign investments with PROINVERSION, to keep company accounts in foreign currency, to execute Investment Agreements, and to apply the VAT Refund or Early VAT Recovery Regimes. Moreover, we provide assistance in preparing, filing and following up on the requests for VAT refund, in order to implement such regimes as established for this kind of projects.