Questions & Answers
Ángel specialises in taxation matters, international trade and anti-money laundering (AML). He is recognised as one of Mexico’s key experts in complicated tax matters that involve both litigation and tax planning. He advises multinational enterprise groups and Mexican companies in expanding and strengthening their business. Ángel has a solid and thorough background in federal income tax and international tax, international trade, and AML; and he has more than 17 years of expertise counselling clients from diverse sectors including finance, real estate, pharmaceuticals, consumer goods and retail.
What inspired you to pursue a legal career?
I have always been curious about legal matters, and consider justice to be one of the cornerstones of civilisation. I am also part of a family with a strong legal tradition. Thus, a legal career seemed to me a natural fit, and I am continuously studying related matters, such as accounting, in order to strengthen my legal and tax practice.
What do you enjoy most about working in corporate tax?
In my opinion corporate tax, in both domestic and international contexts, is one the most complex legal practices, where the regulations are most continuously modified and expanded.
The criteria of tax authorities and courts are always being modified and advanced, which compels us to constantly adjust our practice and knowledge.
I really enjoy the fact that corporate taxation requires an advance knowledge of accounting and legal matters, as well as domestic and international law. Thus, I consider corporate tax a highly regulated matter in constant flux, which I find really challenging and exciting.
How have fiscal and customs authorities changed their approach to corporate tax matters since you began your career?
Corporate tax matters have greatly evolved since I started my career; in addition, international taxation has become more and more complex each and every year. The fiscal and customs authorities have significantly changed their approach to corporate tax matters in the past few years, from a narrow domestic standpoint to a broader and more international approach to corporate tax. The substance-over-form principle will be a trend for the Mexican fiscal authorities’ approach to tax matters.
You are a member of the ICC and have been appointed to its taxation commission and its customs and trade facilitations commission. What does this mean to you and to your outlook on your work?
Being a member of the ICC is an important part of my professional activity. All the members of its taxation commission, and its customs and trade facilitations commission, are renowned professionals who always bring interesting topics to the table, and it is always exciting to participate in the discussions. In Mexico, where the rule of law is being threatened, the importance of associations and chambers of commerce is becoming huge.
What trends have you noticed in the corporate tax sector over the past year or so?
A new General Anti-Abuse Rule (GAAR) entered into force in Mexico in 2020, which applies to federal tax matters. Also, the mandatory disclosure of tax schemes has recently entered into force, and is legally binding for tax advisers and taxpayers. Thus, as stated, the substance-over-form principle will be a trend for the Mexican fiscal authorities approach to tax matters, and will become key to the government’s increasing efforts of collection. In addition, the Mexican Tax on Digital Economy entered into force on 1 June 2020. It will be interesting to see how the authorities seek to enforce this new tax.
Has covid-19 affected your practice, and if so, what steps have you put in place for yourself and your clients?
Covid-19 has affected each and every aspect of our lives and professions. Whereas many countries are looking to secure businesses, and stabilise financial markets and economies by granting tax relief and incentives, in Mexico the government decided not only to grant minimum tax benefits, but also to increase tax enforcement to maximise the collection of federal taxes, considering it an essential activity of the government.
Therefore, my professional activity is more important than ever, especially since many of our clients’ businesses are being threatened in the current economic environment.
What has been your greatest achievement to date?
Fortunately, I have had many achievements in my career I feel proud of. Becoming a partner of Nader, Hayaux & Goebel is clearly one of them.
What is the best piece of advice you’ve ever received?
To never stop seeking new and diverse knowledge – since we are students for life – and to always envision the possible consequences of each and every piece of advice given to my clients (where my litigation experience is key).