Rodrigo Ogea

Rodrigo advises large companies, family offices and private equity funds on the tax structuring of investments, reorganizations and high value transactions. His experience spans fund structuring — including private equity, real estate, infrastructure and renewable energy vehicles — and complex structured finance transactions such as project finance, asset finance and securitization.

He regularly leads the tax design of major cross border restructurings and capital markets operations, including multibillion dollar takeover bids, pan European acquisition programs, securitization platforms and cross border financing structures. Rodrigo’s practice is characterized by his ability to integrate technical tax analysis with commercial strategy, regulatory insight and an in depth understanding of global investment flows.

• Advised a leading Spanish energy utility on the tax structuring of the sale of its Mexican USD 4 billion asset portfolio in a landmark transaction. The transaction represented one of the most significant disposals by a Spanish corporate in Mexico and was critical to the client’s wider strategic repositioning in the region.
• Advised a Spanish gas utility on the tax aspects of a USD 1 billion LNG importation project involving the regasification and injection of gas into Argentina’s national system. The advice was provided in the context of President Milei’s privatization plan, against a backdrop of significant regulatory and fiscal reform.
• Advised a leading Spanish private bank on the tax structuring of the acquisition, on behalf of private investors, of a hospital under construction to be leased to a healthcare group.
• Advised one of the largest Spanish private equity funds on the tax structuring of its investment in a CDMO multinational operating in more than 100 countries.
• Advised a global luxury group on the carve out of its cosmetics and make up business, a highly relevant project involving multiple practice areas.
• Advised an international logistics group on the tax and legal restructuring of a multijurisdictional corporate structure comprising more than ten entities.
• Advised various private equity firms on structuring carried interest incentives for Spanish resident managers.
• Advised a multinational engineering and consulting group on the tax implications of its international expansion, including a review of its transfer pricing policy and expense allocation criteria between the Spanish headquarters and its global taxable presences.
• Assisted a Portuguese group in establishing a new operational structure for the EMEA and North America markets, including the creation of a main service providing entity in the Canary Islands under the ZEC regime and application of the IGIC rules for travel agencies.
• Advised a closed end fund manager on the formation and regulatory transformation of a new investment fund structure in Spain, including conversion into a regulated AIF and the drafting of management agreements and fund documentation from regulatory, corporate and tax perspectives.
• Advised a high net worth individual on the negotiation and tax structuring of a complex corporate reorganization and separation of multiple family owned businesses across different sectors.

• Leading Partner, Tax, Legal 500, 2026
• Eminent Practitioner, Tax, Chambers and Partners Europe, 2026

• Madrid Bar Association