Raquel Guevara

Raquel is a tax specialist who focuses on the planning and implementation of cross border tax efficient structures. She advises clients on tax matters of transactions, for example during the acquisition, pre-disposal reorganization or disposal (e.g. due diligence, review and analysis of specific share purchase agreement) including transactions involving private equity players, as well as intra-group reorganizations.

Having joined MNKS in October 2011 to launch our Tax practice and build a team, Raquel spent over 13 years in a Big 4 audit firm in Luxembourg and abroad, advising major international groups and PE Houses on diverse tax aspects of acquisitions, disposals and restructuring deals. Raquel is fluent in English, French, German and Spanish (mother tongue), certainly a huge advantage in dealing with international clientele.

Raquel is specifically involved in transactions, advising domestic and international clients on tax matters related to refinancing, restructuring, cross-borders acquisitions and disposals. In this context, she has broad experience in project management where a significant number of parties are involved.

Over the years, she has particularly specialized in the taxation of international Private Equity Fund structures and has experience in the alternative investment industry focused on the tax structuring via Luxembourg of mainly but not limited to acquisition of continental European Targets.

In particular, since moving to Luxembourg she has been involved in the development of tax effective structures including hybrid instruments designed for different kinds of (US) investors and tailor-made management equity programs for top tier management.

She regularly takes part in the consultation process with the Direct tax authorities in Luxembourg.

She also has experience in providing training sessions on specific tax topics (i.e. holding companies, exit strategies).

Bar Admission

Member of the Pamplona Bar (Spain), 2009

Education

Law Degree, University of Navarra, Pamplona (Spain), 1999

Recent Transactions

Our Tax team recently acted as Luxembourg counsel to:

  • a client in relation to a sophisticated exit from an investment portfolio. Our tax team assessed the steps to be taken during the exit as to to reach a tax neutral result for all investors at all levels and supported the corporate team within the exit process;
  • the existing shareholders and managers of a Luxembourg start-up company operating in the e-commerce business, in connection with its financing, contributed by several PE funds. The Tax team advised on the implementation of a French structure ad hoc to complete and expand the activities of the group in Europe and particularly in France. The advice included a detailed analysis and tailor-made review of all decision-making-processes of the companies involved in order to prepare together with the corporate team a tailor-made guidance on substance measures to be implemented;
  • an Australian company providing an online auction and shopping platform website in the incorporation of two Luxembourg companies to hold and exploit several IP rights. This project, involving the transfer of e-commerce activities to Luxembourg, required a broad range of expertise in direct and indirect tax practice as well as coordination skills between all parties involved;
  • a client in the context of the migration of e-commerce activities from a European country to Luxembourg and in the framework of a corporate reorganization of its activities. The project required multidisciplinary knowledge and involved almost all of our practices, from Corporate through New Technologies & IP and Employment. Indirect taxation was a central topic of this project, particularly due to the specificities of e-commerce in Luxembourg;
  • a Middle East investor in relation to the acquisition of real estate objects located in Switzerland, held by a Luxembourg company;
  • one of the most active and respected real estate development and investment firms in New York in structuring work needed in order to allow different investors to efficiently participate in a Luxembourg joint venture vehicle. This work was supported by solid corporate and accounting understanding which complemented the tax advice.