Silvia Muñoz Salgado


  • Juris Doctor, Universidad de Lima, Summa cum laude (1993).
  • Master’s in Tax Law (LLM), Georgetown University, Washington D.C. (2001).
  • Participant of the course “Advanced Transfer Prices. Specific Aspects ”taught by Vienna University of Economics and Business, Austria (2019).
  • Participant in the “Principles of transfer pricing” preparation seminar at the International Bureau of Fiscal Documentation (IBFD), the Netherlands (April 9-13, 2018).
  • Participant in the course “Advanced Transfer Pricing (General Aspects)” at the Vienna University of Economics and Business (2017).
  • “International Seminar on Non-Resident Taxation”, OECD, CIAT and Mexican Tax Administration, Mexico (2005).
  • “International Seminar on Financial Market Taxation”, OECD, CIAT and Mexican Tax Administration, Mexico (2004).
  • “International Seminar on International Tax Avoidance and Evasion”, OECD, CIAT and Mexican Tax Administration, Mexico (2004).
  • “International Seminar on Transfer Pricing”, OECD, CIAT and Mexican Tax Administration, Mexico (2003).
  • Participant in the 7th Annual International Conference on Practical Application of Agreements for Avoidance of International Double Taxation and Transfer Pricing, OECD, Paris, France (2002).
  • “International Seminar on E-Commerce and Tax Treaties”, OECD, CIAT and Mexican Tax Administration, Mexico (2002).
  • VI Postgraduate Program in Tax Law, Politics and Criminology, Universidad de Salamanca, Spain (2002).
  • Diploma in Foundations of American Law, Georgetown University, Washington D.C. (2000).
  • “Tax Specialist” Diploma, School of Accounting, Universidad de Lima (1995)
  • Participant in the IV Tax Administration Program, SUNAT (1993).

Professional Experience

  • Counsel – Rodrigo, Elías & Medrano Abogados law firm (July 2014- Dec 2015)
  • Senior Associate – Rodrigo, Elías & Medrano Abogados law firm (Sept 2006 – July 2014)
  • Claims Manager – Major National Taxpayers Division -SUNAT (Aug 2004-Sept 2005)
  • Tax Law Division Specialist – National Legal Office – SUNAT (July 2001- Aug 2004)
  • Head of Claims Department – Lima Regional Office – SUNAT (Aug 1993- Sept 1999)


  • Professor – “Tax Law I – Transfer Pricing”, Master’s in Taxation and Fiscal Policy, Universidad de Lima
  • Professor – “Financial Taxes”, Master’s in Taxation and Fiscal Policy. Universidad de Lima


  • Lima Bar Association
  • International Fiscal Association – IFA Peruvian Group
  • Peruvian Tax Law Institute (IPDT)

Work Highlights

  • During her years of experience in the Peruvian Tax Administration she intervened in several Income Tax reforms. In 2003, she was part of the team specialized in Income Tax and participated in projects related to the amendments made to norms regarding the Peruvian-source income rules, taxation of capital gains and institutional investors, transfer pricing and derivative financial instruments regulations, among other rules and regulations that are now in effect in Peru.
  • Her thesis presented to obtain her master’s degree in taxation in the United States was adapted and then published by SUNAT under the title “Electronic Commerce in International Operations – Tax Effects.” SUNAT NOTEBOOKS – Investigations Series No. 4. This work served for the later drafting of the Peruvian-source income rule related to digital services that today is part of the Income Tax regulations.
  • In the private sector she has participated as a legal advisor on regulatory proposals aimed at improving the taxation of the Peruvian capital market. She has participated in several legislative proposals since 2009 to date, covering issues related to cost basis, ADR’s and GDR’s, ETF’s, factoring, tax exemptions, the Latin American Integrated Market (otherwise known as MILA), among others.
  • Has successfully defended appeals before the Tax Court against assessments related to derivative financial instruments and transfer pricing, and actively participates in advising local and international economic groups on transfer pricing issues, intra-group transaction planning and providing legal defense in the first and second administrative instances.

Distinctions &Rankings



Phone: +511 299-5558 ext. 221 +511 99353-5909 ext. 221