Moses Curiel Garcia

Moisés Curiel García

Baker & McKenzie Abogados, S.C.


Moisés Curiel heads Baker McKenzie’s Transfer Pricing and Valuation practice in Mexico. He has more than 27 years of experience in transfer pricing and international taxes. Moisés served as the transfer pricing audits and resolutions administrator of Mexico’s Ministry of Finance and Public Credit for almost eight years. He helped to prepare and implement various transfer pricing rules in Mexico, including the Income Tax Law, the Temporary Tax Ruling and the Federal Tax Code. He also led the country’s Advance Pricing Agreements Program and conducted the first transfer pricing audits in Mexico and in Latin America. He has also proposed amendments to legislation on various matters for Latin American countries, and represented Mexico before the OECD.

Since 2003, he has been recognized for his practice by International Tax Review. He is tax counsel for the maquiladora industry and the Employers’ Confederation of the Mexican Republic. Moisés is also a professor and coordinator in the Transfer Pricing specialization in conjunction with the Universidad Anáhuac and European School of Business for five generations.

Practice Focus

Moisés has gained extensive experience in transfer pricing and valuation matters from his years in governmental and private practice. Since joining Baker McKenzie in 2004, he has contributed to the development of the Firm’s transfer pricing practice in Latin America, helping clients to accurately interpret and determine their tax obligations and their effects in other jurisdictions. He currently assists different clients in Mexico and throughout the Latin American region to keep them abreast of changes to the Base Erosion and Profit Shifting action plan (BEPS/OCDE/G20).

Representative Legal Matters

  • Successfully represented different types of clients in negotiations with authorities in Mexico, Chile, Venezuela, Ecuador, and, among others, in landmark transfer pricing litigation proceedings, where authorities acknowledged that the value of the products had been determined through the customs value of similar imported products without taking into consideration the different nature of the companies.
  • Provided different companies with technical analyses to defend transfer pricing valuations.
  • Assisted multinational groups in the analysis of global value chain.
  • Negotiating different advance pricing agreements in Latin American countries, including Mexico, Ecuador, Chile, Colombia and Uruguay, among others.
  • Participated in the preparation and implementation of various transfer pricing rules in the Income Tax Law and Omnibus Tax Ruling.
  • Participated in the preparation and implementation of various transfer pricing rules of the Federal Tax Code.
  • Negotiated unilateral agreements with Mexican taxpayers and bilateral agreements with authorities from other countries.
  • Participated in the negotiation of the mutual agreement procedures with the governments of the United States, Canada and Japan.
  • Conducted transfer pricing audits.
  • Participated in different transfer pricing cases in Colombia, Ecuador, Argentina, Venezuela, Greece, Peru, Turkey and Uruguay, among others. 

Professional Associations and Memberships

  • Colegio de Contadores Publicos de Mexico – Member
  • CNIME – Member
  • COPARMEX (Employer's Confederation of the Mexican Republic) – Member
  • Instituto Mexicano de Contadores Públicos de México – Member
  • Zonas Económicas Especiales (ZEE) at the Colegio de Contadores Públicos de México – President 


  • Mexico (2004)


  • Instituto Mexicano de Contadores Públicos de México, A.C. (Tax Specialization Certificate) (2015)
  • Anahuac University (International Expert Transfer Pricing) (2010)
  • Instituto Tecnológico Autónomo de México (Diploma Intellectual Property) (2003)
  • Universidad Panamericana (Tax) (1998)
  • Universidad ISEC (Public Accountant) (1991)
  • (Certificate Course Transfer Pricing Third Party Expert approved by the Mexican Federal Court for Administrative Justice)


  • English
  • Spanish