Antonio A. Weffer

Biography

Antonio A. Weffer is a tax principal in Baker McKenzie's Tax Practice Group and the head of the Firm's transfer pricing practice in Luxembourg.

He has over 20 years of experience handling complex financial and non-financial multinational enterprises, cross-border transactions, reorganizations, mergers and acquisitions across a range of industry sectors.

Antonio is an active member of several international professional tax organizations, and regularly publishes articles on international tax issues and speaks at worldwide seminars and conferences. He is recognized as a highly regarded practitioner in the World Transfer Pricing 2023 guide and named once again as Leading Individual by Legal 500 EMEA in 2023. Other professional honours of this year include:

Tier 1 in Tax practice by Legal 500 in 2023
Top Tier Firm in Word Tax Guide 2023
Tier 2 in the World Transfer Pricing 2023 guide
Band 3 Tax practice by Chambers Europe in 2023
Highly regarded practitioner in the Word Tax Guide 2023
Highly regarded practitioner in the Expert Guide 2023
Excellent Corporate Tax practice and practitioner in Leaders League 2023
Leading Transfer Pricing practice and practitioner in Leaders League 2023
"Luxembourg Transfer Pricing Firm of the Year" for five consecutive years, from 2016 to 2020, International Tax Review European Awards

Practice Focus

Antonio's practice focuses on transfer pricing and valuation documentation, benchmarks, and other economic analysis services to the business community worldwide. He has over 22 years of experience handling complex financial and non-financial multinational enterprises, cross-border transactions, reorganizations, mergers and acquisitions across a range of industry sectors.

Representative Legal Matters

Advised the world’s largest infrastructure asset manager, with growing infrastructure and social infrastructure portfolio of more than USD 129 billion under management, on the restructuring of the financing/capital structure of one of its major fund structures with investments in multiple European countries and total commitments of GBP 2.7 billion.
Advised a unique highly renowned industrial designer looking for integrated transfer pricing solution to align the highly complex, competitive and continuously evolving value chain model of the industrial designing industry.
Assisted the Luxembourg management company of an international asset management group licensed under the UCITS regulation, in the context of the tax audit of its intra-group transactions, concluded with related companies located in Switzerland, Germany, Italy, France and Austria.
Assisted a New York-based distressed-focused hedge fund investment adviser in testing the arm's length nature of a total interest expense in the context of a multifactorial debt instrument, through which investments were mainly made in Western Europe.
Assisted a leading European financial services firm, specialised in equity brokerage, equity capital markets and asset management, in the restructuring process of their asset management division, designing a new business model and functional structure for the entities involved.

Professional Honors

Tier 1 practice by Legal 500 in 2020
Named as Leading Individual by Legal 500 in 2020
Luxembourg Transfer Pricing Firm of the Year for five consecutive years, from 2016 to 2020, International Tax Review European Awards
Band 3 practice by Chambers Europe in 2020
Highly regarded practitioner in the World Transfer Pricing 2020 Guide

Professional Associations and Memberships

AMCHAM Tax Committee working group member
ALFI Digital taxation and Transfer Pricing working groups' member
Camera di Commercio Italo-Lussemburghese (CCIL) member
British chamber of commerce (BCC) member
Chambre Française de Commerce et d'Industrie au Grand Duché du Luxembourg (CFCI) member
International Bar Association member (IBA) member
International Fiscal Association (IFA) - Luxembourg Branch member
Institut Luxembourgeois des Administrateurs (ILA) member
Luxembourg association of family offices (LAFO) member
Luxembourg Private Equity and Venture Capital Association member
The Luxembourg Banker's Association member
Association des compagnies d'assurances et de réassurances du GDL member
The Association of the Luxembourg Fund Industry member
Cámara de Comercio de España en Bélgica y Luxemburgo member
International Bureau of Fiscal Documentation (IBFD)
International Tax Center Leiden University – Holland
International Latin American Tax Law Association (ILADT) –Venezuelan Branch (AVDT) - Member
Venezuelan Tax Law Association (AVDT) and Financial Law Association - Member
Caracas and Miranda State Bar - Member
International Taxation in ESAN School of Business Diploma – Lima Peru - Professor

Education

Leiden University (LL.M. International Taxation) (2002)
Universidad Metropolitana (MS Taxation and Management) (2000)
Universidad Santa Maria (MS Tax Law and Public Finance) (1998)
Universidad Santa Maria (LL.B.) (1994)

Languages

English
French
Italian
Spanish

Co-author:, Luxembourg: Clarifications on reverse hybrid entities, ITR & Baker McKenzie InsightPlus, July 2023
Co-author, Transfer pricing documentation requirements and new advance pricing procedures - highlights of the main changes, ITR & Baker McKenzie InsightPlus, June 2023
Co-author, Interactions between transfer pricing and customs rules further to the Hamamatsu case: a potential turmoil in Luxembourg? ITR & AGEFI, May 2023
Co-author, New Bill of Law on simplification and modernization of certain procedural aspects in tax matters, ITR & Baker McKenzie InsightPlus, April 2023
Co-author, Tripartite Agreement - New tax and real estate measures to mitigate inflation impacts, Baker McKenzie InsightPlus, March 2023
Author,"Las interacciones entre el IVA y los precios de transferencia en una economía cada vez más digitalizada", XXI Jornadas Latinoamericanas de Derecho Tributario, Guatemala, October 2022

Luxembourg branch reporter, " Sharing and Shifting of Corporate Losses — the New Profit Shifting?", IFA 2023 Cancun Congress.
Co-author, ATAD III - Between fair objectives and uncertain outcome, Baker McKenzie InsightPlus, March 2022
Co-author, Real Estate Levy - Two months left for Luxembourg investment fund vehicles to comply with filing obligations, Baker McKenzie InsightPlus, March 2022
Co-author, Advocate General urges the annulment of the judgment in the Fiat State aid ruling, Baker McKenzie, December 2021
Co-author, "Tax Challenges of the Digitalized Enterprise", Baker McKenzie in partnership with Bloomberg Tax and Accounting, June 2021
Co-author, "Private Wealth Newsletter - First Quarter 2021", Baker McKenzie, April 2021
Author, Luxembourg chapters "Law and Practice" and "Trends and Developments", Chambers Global Transfer Pricing 2021, April 2021
Contributor, Chambers ‘Transfer Pricing 2021’ Global Practice Guide - Luxembourg chapter: Latest legal information on transfer pricing methods, intangibles, cross-border information sharing, advance pricing agreements (APAs), penalties, the OECD Transfer Pricing Guidelines, the United Nations Practical Manual on Transfer Pricing, safe harbours and the impact of COVID-19 - April 2021
Co-author, "Interest Deduction Limitation Rule - New Guidance Released by the Luxembourg Tax Authorities," Baker McKenzie InsightPlus, February 2021
Co-author, "Clarifications on the Newly Introduced Profit Participating Incentive Scheme," Baker McKenzie InsightPlus, February 2021
Co-author, Law on the denial of deductibility of interest and royalty payments made to related parties located in non-cooperative jurisdictions adopted, Baker McKenzie InsightPlus, February 2021
Co-author, Application of the parent subsidiary directive to Gibraltar companies - new guidance released by the Luxembourg tax authorities, Baker McKenzie Insight Plus, December 2020
Co-author, Incentive scheme for hiring highly skilled employees - an update of the regime, Baker McKenzie Insight Plus, December 2020
Co-author, Adoption of the 2021 budget bill, Baker McKenzie Insight Plus, December 2020
Author, “Overview of two recent Luxembourg transfer pricing case laws: if you are on time, you are too late “ - Revue générale de fiscalité luxembourgeoise, November 2020
Co-author, Main tax measures of the 2021 draft budget law announced during State of the Nation Speech, Baker McKenzie Insight Plus, October 2020
Co-author, Luxembourg tax unity regime breaches EU freedom of establishment, Baker McKenzie Insight Plus , July 2020
Author, "Reconsidering the finance function of digital companies," International Tax Review - TP Supplement, April 2020
Contributor, Contemplating force majeure and other contractual considerations in intercompany agreements, in collaboration with Bloomberg Tax & Accounting & Baker McKenzie Insight Plus, April 2020
Co-author, Controlled foreign company "CFC" rules documentation requirement: are you ready? Baker McKenzie Insight Plus , April 2020
Co-author, Gibraltar companies no longer eligible to the EU Parent Subsidiary Directive, Baker McKenzie Insight Plus , April 2020
Co-author, Denial of deductibility of interest and royalty expenses charged by related parties located in non-cooperative jurisdictions (Bill of Law 7547), Baker McKenzie Insight Plus , April 2020
2020 Luxembourg Budget Bill - Rulings granted 1 January 2015 no longer valid, Baker McKenzie Insight Plus, October 2019
Speaker, 6th Annual Bloomberg Tax and Baker McKenzie Global Transfer Pricing Conference 2018
Author, BEPS Interest Expense Deductions, PaperJam, December 2016
Speaker, BEPS action plan, practical implication on Action 4, AVDT Annual Congress, November 2016
Contributor, Transfer Pricing Chapter on Luxembourg, IBFD, since 2015
Overview of today’s Luxembourg Transfer Pricing practice and evolution of the methodologies applied since the inception of the TP Circular. Revue Générale de Fiscalité Luxembourgeoise “RGFL” (publisher’s hands 2015)