Carlos Morales Ribas is a tax manager in the Tax Group of Baker McKenzie’s Luxembourg office. Prior to joining the Firm in 2015, he gathered over seven years' experience in international tax law at major consultancy companies, mainly in transfer pricing, tax risks and aspects of business restructuring.
Mr. Morales assists multinationals from a range of industries in valuations and transfer pricing risk assessment and management, design and implementation of transfer pricing policies, tax audits, tax litigation, mutual agreement procedures, and advance pricing arrangements, on a local and global basis. He has extensive experience in the preparation of valuation analysis reports and transfer pricing analysis for regulated and unregulated funds, namely SIFs, SICARs, UCITs, SCS and SCSp, as well as for Mancos chapter 16 and Mancos chapter 15 under UCITS AIFMD and SIF regulatory frameworks.
Representative Legal Matters
- Prepares transfer pricing studies for intra-group financing activities, royalties, remuneration for hybrid instruments and interest rate on intra-group loans.
- Assisted the Luxembourg Management Company of a large investment manager licensed under the UCITS regulation, in the context of the tax audit of its intra-group transactions.
- Advised a large investment fund manager on the coordination of tax audits by the French tax authorities, having impact on Luxembourg tax aspects as well as transfer pricing policies.
- Advised a global asset management firm in connection with the regressive transfer pricing policy and the onward transfer pricing policy at the level of two structures.
- Carries out benchmarking analyses covering all types of inter-company transactions of goods and services in a wide range of countries.
- Manages transfer pricing and tax risks and opportunities in relation to any type of business restructuring.
- Luxembourg (2015)
- Madrid~Spain (2011)
- Erasmus University Rotterdam (Master of Laws (LL.M.) Business and Corporate Law) (2011)
- Complutense University of Madrid (Master's Degree Economics and Finance) (2008)
- Complutense University of Madrid (Master's Degree Law) (2008)