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Mario Barrera focuses his practice on domestic and cross-border tax advisory, planning, and strategy. He represents clients before tax authorities in procedures such as tax examinations, administrative appeals, settlements, and mutual agreement procedures.

Mario also has broad experience handling tax treaties, transfer pricing matters, and corporate reorganizations. He has advised leading companies in the automotive sector, particularly in connection with supply chain structuring, transfer pricing policies, VAT certification regimes, permanent establishment risk assessments, and the implementation of efficient tax and customs strategies tailored to the sector’s operational model.

He has also developed significant experience advising clients in the manufacturing industry, especially those operating under IMMEX programs. His work in this area includes compliance with tax and customs regulations and defending tax positions in audits and disputes involving structures and export incentive regimes.

In addition, Mario has authored numerous papers for specialized journals, including Tax Notes International, Puntos Finos, IDC, and Practical Mexican Tax Strategies, and is a frequent speaker and lecturer on tax law.

Education

L.L.M., summa cum laude, Universidad Panamericana
Certificate, Harvard Law School, Cambridge, Massachusetts, International Tax Program
J.D., summa cum laude, Universidad de las Américas

Recognitions

  • ITR World Tax, Tax Controversy, 2020-2026
  • Chambers Global – The World’s Leading Lawyers for Business guide, Mexico: Tax: Non-Contentious, Band 4 (2022-2026)
  • Chambers Latin America – Latin America’s Leading Lawyers for Business guide, Tax: Non Contentious, 2022-2024
  • The Best Lawyers in Mexico, Tax Law, 2020-2026
  • Who’s Who Legal: Mexico, Corporate Tax, 2015, 2017-2024; Corporate Tax – Controversy, Mexico, 2022
  • Leaders League, Mexico: Tax Law – Corporate Tax, 2021-2024; Tax Law – Major Tax Litigation, 2023, 2024
  • Certified “Transfer Pricing Expert,” Federación de Colegios de Economistas de la República Mexicana A.C.
  • The Legal 500 Latin America, Tax, 2019
  • International Who’s Who of Corporate Tax Lawyers, 2012

Memberships

  • Advisory Board, Thomson Reuters, 2023
  • Asociación Nacional de Abogados de Empresa A.C.
  • Barra Mexicana, Colegio de Abogados A.C., Tax Subcommittee of the Fiscal Commission, Coordinator
  • Club Harvard de México A.C.
  • Colegio Nacional de Economistas A.C., Transfer Pricing Committee
  • International Fiscal Association
  • Harvard Law School Student Association A.C.
  • Cámara Franco Mexicana de Comercio e Industria A.C.; Board of Directors, 2021-2023; Legal and Tax Committee, Co-Chair, 2015-2017
  • Colegio de Contadores Públicos de México A.C., Transfer Pricing Committee

Languages

English, Spanish

State Bar Licenses

Mexico

Representative Experience

  • Advised a major U.S. insurance company in a transfer pricing examination with a potential exposure of more than US$100 million.
  • Advised a major U.S. real estate investment manager in recovering value-added tax (VAT) favorable balances worth more than US$50 million.
  • Advised a U.S. worldwide consumer products company on Mexican tax issues associated with a global corporate reorganization.
  • Advised a Spanish group engaged in providing renewable energy in order to recover VAT in excess of US$200 million.
  • Advised a Canadian mining group on Mexican tax issues associated with the sale of its Mexican assets.
  • Advised several non-Mexican pension plans on the structure of their investments into Mexico in order to claim the relevant tax benefits afforded by the law.
  • Represented a global steel manufacturer in a transfer pricing audit which could result in a contingency of several million dollars.
  • Advised a Spanish group engaged in e-commerce on the structure of their operations in Mexico from a tax perspective.
  • Advised a U.S. real estate developer on the structure of their operations in Mexico, taking into consideration the tax situation of its institutional investors.
  • Advised a U.K. financial group with regard to its operations in Mexico from a tax perspective.
  • Advised a U.K. architectural firm with regard to the tax structure of their operations in Mexican real estate projects.
  • Advised a U.S. bottling group in structuring the sale of certain fixed assets in Mexico worth more than US$600 million.
  • Advised on the supply chain among a US warehouse, producers and retailers regarding the structure of its business in Mexico. This while focusing on cost-related matters such as taxes, profits, international commerce labor, and other relevant aspects.
  • Advised a U.S. hospitality group on the sale of its operation represented by timeshares on assets located in Mexico, including issues such as international taxation, analysis on value added tax, legal structure of the transaction, and negotiation between the parties involved.
  • Advised a multi-level multi-national group dedicated to the distribution of food supplements on all aspects regarding the entry to the Mexican market. This, facing issues such as, the nature of its business according to Mexican legislation that could trigger challenges on tax and international commerce matters.