Introduction

Ricardo advises on the tax dimensions of Spain's most complex cross-border M&A, real estate, and NPL transactions and on prevention and resolution of tax conflicts.

Ricardo García-Borregón is a partner in our tax practice with broad experience in tax planning, advising national and international clients in all aspects of Spanish taxation, above all in those with an international component.

In particular, he is knowledgeable in advising in connection to the tax aspects of M&A and restructuring transactions, both concerning direct and indirect taxation, being specially involved in real estate investments, infra and energy M&A, real estate funds (such as REITs), acquisitions of NPLs portfolios and debt refinancing deals, including their implications from a transfer pricing point of view. In addition, he has wide experience in prevention and resolution of tax litigation procedures, representing clients before the Spanish Administration in the course of tax audits as well as before the Spanish Courts and the EU institutions.

Ricardo has been involved in very innovative transactions in the real estate market such as the incorporation of the first FAB created by SAREB, or of one of the first SOCIMIs listed in Spain (REIT)  as well as in the structuring of complex acquisitions of NPLs and REOs portfolios, complex multi-investment share deals, the design of JVs and other strategic partnership to develop RE platforms or the design of Build-to-rent structures.

  • Global insurance company advising on the structuring, set-up and development of their build-to-rent platform in Spain with Layetana and the relevant acquisitions and developments under said platform.
  • Henderson Park on the structuring, implementation and financing of the acquisition of Islazul Shopping Centre Madrid (1 of the 10 top Shopping Centers in Spain) and on its subsequent sale.
  • Private equity firm on the structuring, establishment and implementation of a joint venture with Roebuck AM to develop a logistic platform in Spain and the relevant investments under said platform.
  • Lighthouse Properties on the structuring and ongoing tax advice of their SOCIMI platform in Spain, including the acquisition and refinancing of Alcalá Magna Shopping Centre, Espai Gironès in Girona "Salera" shopping center in Castellón and Espacio Mediterráneo. 
  • Private equity firm on the high-profile acquisition and leaseback, and financing, of a multi-jurisdictional 24-asset portfolio across the UK, Ireland, and Spain.
  • Several international online gaming operators in connection with tax audit processes and litigation procedures as regards their tax obligations in Spain. 
  • Green Energy Group on (i) a JV with a Spanish developer for the development, construction, finance and operation of 2GW of solar projects in Spain and Italy; (ii) a JV agreement with Spanish developer Univergy to invest in renewables; and (iii) their investment in several Solar PV development projects in Spain amounting to more than 1.5GW.
  • Kefren Capital and Tristan Capital Partners in their joint venture to invest in logistic assets in Spain, including tax structuring and the acquisition an developments of their first investments.
  • M&G Investments on the joint venture with Stoneweg for the acquisition from Dragados of plots of land in Madrid for the further development of two PRS premium towers.
  • Alantra on the purchase of a majority stake in the share capital of Hiperbaric (a world leader in the manufacture of high-pressure processing equipment for the food industry) and the subsequent sale of a majority stake to the founders of such company, keeping Alantra a minority stake.