Photo, Carlos A. Linares-García

Carlos A. Linares-García

Principal Economist
Baker & McKenzie Abogados, S.C.
Not admitted to practice law in this jurisdiction


Dr. Carlos Linares Garcia is a tax partner based in Mexico, the managing partner of the firm's Monterrey office, and the head of Baker McKenzie’s North America and Latin America Transfer Pricing & Economics practices. He is knowledgeable in the fields of transfer pricing, financial valuation and international taxation. His professional experience includes over 25 years in consulting and three years in the public sector. From 1993 to 1995, Dr. Linares was a deputy director with the International Tax Department of the Mexican Ministry of Finance in Mexico City. From 1996 to 1999, he was an associate economist at Houston-based Baker & Associates Energy Consultants and from 2000 and 2004, he was a senior manager and a partner in the transfer pricing practice at a big-four firm in Houston and Monterrey. For his research in economics and public finance, Dr. Linares received the Banamex Economics Award in 2000, as well as the Inter-American Social Security Award in 2002. He has lectured at various institutions such as the International Bureau of Fiscal Documentation, Rice University, Instituto Colombiano de Derecho Tributario, Universidad Autónoma de Nuevo León and the Tecnológico de Monterrey.

Dr. Linares received his degree in economics summa cum laude from Universidad Autonoma de Nuevo Leon in 1993 and his master’s and Ph.D. degrees in economics from Rice University in 2000, specializing in public finance and tax policy. In 2021, he became a certified Mexican lawyer with a law degree from Universidad Tecmilenio. Also, he obtained a Diploma in International Taxation from Harvard University and a Diploma in Energy Law from Universidad de Monterrey. He is an active member the International Fiscal Association (Transfer Pricing Committee), the Instituto Mexicano de Ejecutivos de Finanzas, the Asociación Nacional de Especialistas Fiscales, and Vice-President of the Colegio de Economistas de Nuevo Leon.

Practice Focus

Dr. Linares specializes in transfer pricing design and implementation with a focus on the manufacturing, oil & gas, and high tech industries. He has over 20 years of experience in coordinating tax and transfer pricing compliance, planning, and dispute resolution projects for multinational companies doing business across Latin America. He also coordinate projects in areas such as financial valuation, energy economics, antitrust and unfair foreign trade practices. He has assisted multinational companies in complex dispute resolution cases involving alternative mechanisms and Advance Pricing Agreements ("APA"), including the first APA ever signed by the Colombian government and numerous APAs for inbound manufacturing companies in Mexico, in addition to bilateral APAs and Mutual Agreement Procedures with Switzerland, Sweden, Luxembourg, Canada and the US.

Representative Legal Matters

  • Coordinating projects regarding transfer pricing compliance, planning, advance pricing agreements, and controversies for multinational companies operating in Latin America countries that have adopted transfer pricing rules such as Argentina, Brazil, Colombia, Ecuador, Mexico, Peru, Uruguay and Venezuela, among others.
  • Leading the successful negotiation of out-of-court settlements with the Mexican tax authority, through the PRODECON (Mexico tax ombudsman), in major tax audit cases involving advertising and promotional expenses, marketing intangibles, transfer pricing, and attribution of profits to permanent establishments.
  • Leading the negotiation of advance pricing agreements in the region, including the first advance pricing agreement issued in Colombia.
  • Coordinating projects involving stock and intangible assets valuation (brands, patents, know-how and intellectual property portfolios) for purposes of tax compliance, as well as in corporate reorganizations, mergers and acquisitions.
  • Coordinating Mutual Agreement Procedures under the double taxation treaties signed by Mexico with Switzerland, Luxembourg, Canada and the United States.

Professional Associations and Memberships

  • International Fiscal Association (Transfer Pricing Committee)
  • Colegio de Economistas de Nuevo Leon (Vice President)
  • Asociación Nacional de Especialistas Fiscales
  • Instituto Mexicano de Ejecutivos de Finanzas


  • Arizona State University (Latin American Business Exchange Program) (1992)
  • Universidad Autónoma de Nuevo León (B.A. Economics) (1993)
  • Harvard University (Diploma International Taxation) (1994)
  • Rice University (Ph.D. Economics) (2000)
  • Rice University (Master of Arts Economics) (2000)
  • Universidad de Monterrey (Diploma Energy Law) (2005)
  • TecMilenio University (Law Degree) (2021)


  • English
  • Spanish
  • Professor, "Transfer Pricing Issues in the Oil & Gas Industry," International Bureau of Fiscal Documentation, Amsterdam, The Netherlands, December 2015

  • Speaker, "Global Transfer Pricing Conference," Bloomberg BNA, Toronto, Canadá, October 2015

  • Speaker, "Transfer Pricing Developments in Latin America," Baker McKenzie Latin America Tax Conference, Miami, Florida, March 2015

  • Speaker, "Global Transfer Pricing Conference," Bloomberg BNA, Paris, France, March 2015

  • Speaker, "International Update - Transfer Pricing," Tax Executives Institute - Houston Chapter, Houston, Texas, November 2014