Guillermo Aguayo

Local Partner, Mexico City



Guillermo's professional practice focuses on tax law. As part of his practice, he constantly provides tax advice to clients in cross-border and domestic mergers, acquisitions and corporate reorganizations and in general advises and represents clients in complex tax matters.

Guillermo also advises clients on Mexican customs and foreign trade issues working together with the Firm's International Trade experts from other jurisdictions.

Bars and Courts
Authorized to practice law in Mexico
Georgetown University Law Center
Attorney at Law (Abogado)
Universidad de Monterrey
Campus Monterrey


Recent matters include the representation of:

  • Newmont Mining Corp., a gold and copper producer based in the United States with operations worldwide, on its US$10 billion acquisition of Goldcorp Inc., a Canadian senior gold producer.
  • The issuer on the IPO of the first Energy and Infrastructure Investment Trust (Fibra E) specialized in the electric sector in Mexico through which ~US$880 million were raised.
  • Banks and financial institutions in various tax matters related to investment banking, securities, commercial banking, syndicated loans, asset management and day-to-day operations. Recent examples of such work include:
    • Afirme Grupo Financiero, on tax aspects related to the acquisition of all equity participation in UBS Bank México.
    • ConCrédito on the sale of an equity stake in FinUtil and Comfu, to Gentera, an international entrepreneurial banking group focused on the financial inclusion of low-income individuals. Our tax team advised on the structuring and negotiation of tax aspects of the transaction.
    • The Mexican brokerage house of a global financial group on the tax consequences of clearing certain interest rate swaps through the Chicago Mercantile Exchange.
    • An investment bank on the restructuring of certain cross-border activities in response to concerns about changes to the permanent establishment definition as consequence of the execution by Mexico of the Multilateral Instrument (the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting).
    • One of the world's largest investment management companies in a wide range of tax matters related to its start of operations in Mexico.
    • A Mexican Administrator of Retirement Funds in negotiations and structuring of a co-investment with a real estate investment management fund.
  • A leading pet retailer in Mexico in negotiations for the reception of an equity investment from a private equity fund.
  • A multinational independent power producer in the acquisition of a solar project in Mexico.
  • One of the most important railroad freight companies with operations in Mexico. Guillermo has advised such client in various tax matters of strategic importance, including the structuring and negotiation of two joint ventures for the construction of a unit train liquid fuels terminal and the construction and operation of a refined energy products fuel terminal, respectively. He also represents such client in tax audits and tax litigation.
  • Numerous clients on customs and foreign trade related matters, such as the restructuring and expansion of IMMEX operations, on custom and foreign trade audits, on administrative customs procedures and on customs related litigation. Working together with International Trade experts from other jurisdictions, Guillermo has participated in negotiations among authorities regarding the amendment of rules of origin set forth in free trade agreements entered into by Mexico.
  • A well-known investment banking advisory firm in the structuring and placement of two Mexican exchange traded funds.
  • A Mexican non-bank mortgage and construction lender on tax advice related to its debt restructuring and bankruptcy processes.
  • Banks, multilaterals and investors in the structuring of infrastructure projects.
  • Various companies and international groups in structuring real estate projects for the tourist, commercial and industrial sectors on tax related matters.
  • Investment bankers, offshore firms and investors on matters related to tax compliance, structuring, repatriation and disposition of inbound and outbound investments of companies and high-net-worth individuals.
  • Clients on the structuring of personal and family wealth preservation and estate plans.