Ramiro Aguirre Pérez is counsel at Arias & Charua Abogados, S.C., specializing in Counseling and Litigation in administrative, Tax, Fiscal and Social Security matters. Mr. Aguirre has actively represented companies in Mexico, the United States, Canada, Latin America and Europe.
Due to his professional experience, Mr. Aguirre is an expert in tax matters, since he has worked in this particular section of law for 10 years, in private and public sectors; He worked at Federal Court of Administrative Justice (“TFJA”), Tax Administration Service (“SAT”) and at various prestigious international firms, including Hogan Lovells, Tiburcio Abogados and Grupo 100.
During his career, Mr. Aguirre has focused mainly on consulting and tax litigation, participating in numerous audits and inspections carried out by various administrative authorities, achieving the release of tax assessments or a significant reduction of his clients' contingencies and, in some cases, the early conclusion of procedures without go to litigation, thanks to mediation and dialogue with authorities.
Mr. Aguirre received his law degree in 2012 from University of Guadalajara; in 2014 he completed a specialization in Tax Law at Escuela Libre de Derecho. In 2020 he completed a certificate (diploma) in international tax law in University of Leiden, Holland.
He has taken various courses, diplomas and seminars, among which are the following:
2013 - National Congress: “ANTI LAUNDERING LAW: REGULATION AND GENERAL RULES. TAX DISCREPANCY AND THE NEW AUDIT ACTS. ANALYSIS AND PROPOSAL FOR A SOLUTION AND COMPLIANCE.", given by Defensa Fiscal Magazine on September 12 and 13, 2013.
(Curricular value records: AMCP/CE/030 – FNAMCP FN0008144 – IMEFI 002/2005)
2013 - "CONFERENCE TO UNDERSTAND THE TAX REFORM 2014", given by the INSTITUTE OF LEGAL RESEARCH OF THE NATIONAL AUTONOMOUS UNIVERSITY OF MEXICO on November 5, 6 and 7, 2013.
2014 - Course: "TAX FORUM 2014", taught by the BUSINESS AND TAX TRAINING INSTITUTE, S.C. on May 20, 2014.
2014 - Seminar: "TAX CONSTITUTIONAL LAW IN IBERO-AMERICA", given by MEXICAN SUPREME COURT OF JUSTICE [SCJN] on June 25, 26 and 27, 2014.
2019 - Seminar: "HOW TO LEGALLY PROVE THE MATERIALITY OF NON-EXISTENT OPERATIONS FOR SAT", given by CAPACITADORA FISCAL AZUA, S.C. on July 23, 2019.
((Curricular value records: EPC: ICCPCH-DC-042-0618 CC Fiscal SC of the Standard for Continuous Update. National Commission for the Standard for Academic Update of the National Federation of the Mexican Association of Public Accountants A.C. with registration FN0003113. Registration as Training Institution before the STPS: CMR03210722-0013.).)
2020 – “RETHINKING INTERNATIONAL TAX LAW” Diploma, taught by the University of Leiden, Netherlands.
2021 – “FISCAL STRATEGIES AND PRODUCTIVITY 2021” Diploma, taught by CAPFISCAL with a duration of 50 hours, taught in the months of October to December 2021.
2021 – Course "THE SAS AND THEIR BENEFITS", taught by LC Professional Training on December 8, 2021.
(Registration of curricular value STPS Registry: LOOV-850924-330-005)
2021 – Table of Analysis "CORPORATE GOVERNANCE AND BUSINESS LAW" given by the General Directorate of Houses of Legal Culture of the SCJN, on September 14, 2021.
2021 - Diploma "JUICIO DE AMPARO" given by the General Directorate of Houses of Legal Culture of the SCJN, from February to July 2021.
2022 - Course "REGULATION OF CRYPTO ASSETS" taught by Lawgic for the month of the month from March to May 2022.
2022 – Course "REGULATION AND INDUSTRY OF TEQUILA AND MEZCAL" taught by Lawgic from August to November 2022.
Throughout his career, he has been involved in important tax disputes involving shipping companies, airlines and international mining companies, as well as leading companies in our country, even actively participating in the defense of former leader of National Union of Education Workers (SNTE), just to name a few things.
Regarding constitutional matters, he participated in the challenge of tax reform implemented in 2014 (fighting various regulatory portions, among others, in terms of transportation of goods, limiting tax deductions, cost of sales, mining rights and special tax on production and services on food and beverages with high caloric content), also participated in the constitutional challenge of various general rules contained in Mexican Miscellaneous Tax Resolutions of different years and carried out multiple lobbying efforts, study and legislative monitoring at the federal and statewide level, obtaining declarations of unconstitutionality in benefit of its clients.
For this reason, revocation of tax resolutions at administrative headquarters, annulment of tax assessments and tax resolutions before the TFJA and Statewide Courts, confirmation of a certain tax regime, obtaining of tax refunds and declaration of unconstitutionality of acts and general regulations, are clear examples of his successful performance.
In addition, Mr. Aguirre has extensive experience in detrimental trials (“Lesividad” trial), international taxation and materiality, non-existence and simulation of operations.
2019 – Course "JUICIO DE LESIVIDAD" given at Escuela Libre de Derecho on October 29, 2019, where Magistrate Juan Manuel Jimenez Illescas and Magistrate Maria Zaragoza Sigler participated.
2021 - Class "GENERAL ANTI-ABUSE RULE, BUSINESS REASON AND EFFECTS OF RECHARACTERIZATION (ART. 5-A CFF)" [visible at: https://www.youtube.com/watch?v=38-yRD-NKSg&list=LL&index =2&t=827s] given on March 3, 2021 for Consejero Empresarial Magazine.
2021 - Class "MATERIALITY, NON-EXISTENCE AND SIMULATION FOR TAX PURPOSES" [visible at: https://www.youtube.com/watch?v=pt4HfuEexGU&t=684s], given on June 3, 2021 for Consejero Empresarial Magazine.
2022 – Class "INTRAPROCEDURAL REMEDIES IN FEDERAL NULLITY TRIAL", given on May 5, 2022 for Consejero Empresarial Magazine.
"SOME ASPECTS OF TAX REFORM 2014", PANDECTA Magazine of the Escuela Libre de Derecho, No. 25, spring summer 2014, pages 34 to 38.
Mr. Aguirre is a columnist in the Consejero Empresarial Magazine. These are some of his articles published:
“INTERNATIONAL PERSPECTIVE OF OPACITY IN FINANCIAL AND LEGAL SYSTEM OF JURISDICTIONS THAT ALLOW OFFSHORE HIDING AND MONEY LAUNDERING”
“ANALYSIS OF NEW TAX CRITERIA REGARDING TRANSFERS BETWEEN BANK ACCOUNTS. HOW TO AVOID CUMULATIVE INCOME FROM BEING CONSIDERED FOR INCOME TAX PURPOSES.”
"BRIEF ANALYSIS AND OPINIONS REGARDING BEPS RULES"
"CONTROLLER BENEFICIARY; INTERNATIONAL BACKGROUND AND REGULATION IN OUR COUNTRY. CRITERIA FOR ITS IMPLEMENTATION AND REQUIREMENTS FOR RESPECTIVE INFORMATION"
"PRODECON HINDERS FEDERAL GOVERNMENT?"
"OBLIGATION TO ASSESS IN EXAMINATION STAGE THE EVIDENCE PROVIDED WITHIN THE CONCLUSIVE AGREEMENT"
"THE SCJN AND OFFICIAL PREVENTIVE PRISON"
"COMMENTS ON JURISPRUDENCE PC.XVI.A.J/4A(11ª) RELATED TO THE ACCREDITATION OF VAT GENERATED BY COMPENSATION BETWEEN INDIVIDUALS"
“PRACTICAL TREATMENT OF “CERTAIN DATE” FOR TAX PURPOSES; CAN SUCH FORMALITY BE REQUIRED RETROACTIVELY?”
“THEORETICAL FUNDAMENTALS AND MEXICAN REGULATORY FRAMEWORK OF RELATED PARTIES”
“COMMENTS ABOUT “MORENIST” INITIATIVE WHICH INTENDS TO LIMIT SUSPENSION IN CONSTITUTIONAL APPEALS AND CONTROVERSIES.”
“LEGAL GROUNDS AND EFFECTS OF BARE OWNERSHIP AND ITS TAX TREATMENT FROM THE 2022 REFORM”
Mr. Aguirre’s native language is Spanish, and he is fluent in spoken and written English and French.
Mr. Aguirre is a member of the Illustrious and National Bar Association of Mexico, Western Chapter and belongs to the Tax Law Commission of said Association.