Carlos A. Linares-García
Biography
Carlos Alberto Linares García is a principal partner and leader of the Tax Practice in Mexico and the Transfer Pricing Practice in the Americas. He is also the managing partner of the Monterrey office. His areas of practice are transfer pricing, financial valuation and international taxation. His professional experience includes more than twenty-five years in consulting and three years in the public sector. From 1993 to 1995, Mr. Linares served as deputy director in the General Directorate of Revenue Policy and International Tax Affairs of the Ministry of Finance and Public Credit in Mexico. From 1996 to 1999, Dr. Linares served as an associate economist at Baker & Associates Energy Consultants, based in Houston, and from 2000 to 2004, he was a senior manager and partner in the Tax and Transfer Pricing group at a Big Four firm in Houston and Monterrey. For his research in economics and public finance, Dr. Linares was recognized with the Banamex Economics Award in 2000, as well as the Inter-American Award for Research in Social Security in 2002. He has been a professor at various institutions such as the International Bureau of Fiscal Documentation, Rice University, Instituto Colombiano de Derecho Tributario, Universidad Autónoma de Nuevo León, Instituto Brasileiro de Direito Tributário, and Tecnológico de Monterrey.
Dr. Linares obtained his degree in economics, summa cum laude, from the Universidad Autónoma de Nuevo León in 1993, and completed his M.A. and Ph.D. in Economics at Rice University in 2000, specializing in public finance and tax policy. In 2021, he completed his law degree at Universidad Tecmilenio. He also obtained a Diploma in International Taxation from Harvard University and a Diploma in Energy Law from the University of Monterrey. He is an active member of the International Fiscal Association (Transfer Pricing Committee), the Mexican Institute of Finance Executives, the National Association of Tax Specialists, and is vice president of the Nuevo Leon College of Economists.
Practice Focus
Representative Legal Matters
- Led numerous transfer pricing compliance, planning and dispute resolution projects for multinational companies with operations in North America and Latin America including Argentina, Brazil, Canada, Colombia, Ecuador, United States, Mexico, Peru, Uruguay and Venezuela.
- Supported multinational companies in complex dispute resolution and double taxation cases involving alternative mechanisms and Advance Pricing Agreements ("APAs"), including the first APA authorized by the Colombian government and numerous APAs for manufacturing companies in Mexico; as well as mutual agreement procedures ("MAPs") between Mexico and countries such as Switzerland, Luxembourg, the United Kingdom, the Netherlands, Canada and the United States.
- Led the successful negotiation of out-of-court settlements with the Mexican tax authority, through PRODECON, in several tax audit cases involving advertising and promotional expenses, licensing of intangibles, financial valuation, transfer pricing and attribution of income to permanent establishments.
- Coordinated valuation projects of shares and intangible assets (trademarks, patents, know-how and intellectual property portfolios) for compliance and tax controversy purposes, as well as in corporate reorganizations, mergers and acquisitions.
Professional Associations and Memberships
- International Fiscal Association - member of the Transfer Pricing Committee
- Colegio de Economistas de Nuevo Leon (Vice President)
- National Association of Tax Specialists
- Mexican Institute of Finance Executives
Education
- TecMilenio University (Law Degree) (2021)
- Universidad de Monterrey (Diploma Energy Law) (2005)
- Rice University (Ph.D. Economics) (2000)
- Rice University (Master of Arts Economics) (2000)
- Harvard University (Diploma International Taxation) (1994)
- Universidad Autónoma de Nuevo León (B.A. Economics) (1993)
- Arizona State University (Latin American Business Exchange Program) (1992)
Languages
- English
- Spanish