Energy Taxation

Our recent experience related to taxation includes:

• EDF: Advice on transfer pricing matters regarding price and profitability planning in intragroup transactions and on the analysis of intercompany contracts from France to Peru (general tax consultancy).
• Coelvisac (Consorcio Eléctrico de Villacuri): Advice on the filing of an action against the Supervisory Body for Investment in Energy and Mining (OSINERGMIN) for the collection of the regulatory tax contribution.
• Tullow Oil PLC: Our team provided tax advice to Tullow, a London-based oil and gas company, in acquiring a stake in two offshore oil blocks. The transaction included the acquisition of a 35% stake in block Z-38 located in the Tumbes Basin, Peru’s first deep-water hydrocarbon prospect. Our team provided tax advice to Tullow in acquiring a stake in four offshore license contracts executed with Perupetro S.A., the Peruvian government hydrocarbon agency, which is responsible for promoting, negotiating, executing and supervising hydrocarbon exploration and exploitation contracts on behalf of the Peruvian State.
• Fenix Power Perú S.A.: We advised Fenix Perú on the tax consequences arising from financing through bond issuing in the international market by means of a facility administered by The Depositary Trust Company (DTC).
• Zeta Gas Andino S.A.: CMS Grau is representing Zeta Gas Andino S.A. in several tax procedures regarding excessive municipal taxes charged by the Constitutional Province of Callao.
• Enagás Internacional S.L.U.: CMS Grau advised the Spanish company Enagás International on the acquisition of a 4.34% interest in Transportadora de Gas del Perú (TGP) from SK Innovation Co., LTD (3.94%) and Financial Investment Corporation (0.40%).
• Enel Green Power: CMS Grau provided tax advice relating to the Marcona Project on a social initiative to provide renewable energy to areas of extreme poverty.