Rafael de la Mora Gorriz

Rafael De La Mora Górriz

Baker & McKenzie Abogados, S.C.


Rafael is a junior associate in the Tax Practice Group of Baker McKenzie's office in Mexico City, specializing in transfer pricing. He joined the Firm in 2015, and has been involved in different transfer pricing matters across different industries. Rafael has been involved in consulting, compliance and dispute resolution projects, advising some of the world's biggest multinational companies.

Practice Focus

He focuses his practice on transfer pricing, including compliance, benchmarking analysis, transfer pricing audits, APA procedures and financial valuations in Mexico, across Latin America and Luxembourg. He has participated in transactions in the consumer goods, financial, hospitality, pharmaceutical, entertainment, insurance, mining, retail, and services industries.

Representative Legal Matters

  • Advised multinational companies on compliance with tax obligations in transfer pricing matters.
  • Assisted on the tax dispute of marketing intangibles payments for the world's biggest food and beverage group, which represented their largest tax contingency in the world, where it was achieved to reduce the tax credit by almost 99%.
  • Advised the biggest Spanish-speaking entertainment group in the world on the proper treatment for royalty payments, according to the DEMPE functions guidelines stated by the OECD. 


  • Mexico~Mexico (2015)


  • Universidad Anáhuac (Diploma Transfer Pricing) (2017)
  • Universidad Panamericana (Accounting) (2015)


  • English
  • Spanish
Co-author, "Transfer Pricing Forum, Transfer Pricing for the International Practitioner – Mexico Chapter,” Bloomberg Tax, 2018