Paola De La Cruz

Paola De la Cruz

pah-OH-lah deh lah KROOS ROH-hahsSenior Associate
Senior associate Paola De La Cruz focuses on tax audit proceedings in front of SUNAT.
— Legal 500 Ranking 2025
Lima
About

Paola De la Cruz is a senior associate specializing in domestic and international taxation, with a focus on advising multinational companies on complex cross-border transactions, corporate reorganizations, intra-group financing, and business models in the digital economy, fintech, and digital assets sectors, as well as industries such as agriculture, energy, hydrocarbons, distribution, and import businesses, among others. She has extensive experience in tax controversy, audit defense, and litigation before SUNAT and the Tax Court, as well as in transfer pricing matters under OECD standards.

Paola brings a strategic, results-oriented approach to identifying tax risks and structuring tax-efficient solutions in high-complexity environments.

Areas of FocusTax

EXPERIENCE

  • Advised a leading multinational digital payments platform on the tax structuring of a cross-border e-commerce model in Peru, including VAT and Corporate Income Tax implications and mitigation of long-term tax risks in digital economy transactions
  • Advised a global digital entertainment company on the tax implications of commercial campaigns targeting the Peruvian market, including VAT treatment of digital services provided by non-resident suppliers and related international tax issues
  • Advised an international investment management group with operations across Latin America, Europe and the United States on the Peruvian tax implications of a post-acquisition multinational corporate reorganization, including the application of the indirect transfer of shares regime
  • Participated in the tax structuring of an international corporate reorganization involving entities in the United Kingdom, Uruguay, Spain and Peru, assessing local tax risks and aligning the Peruvian tax strategy with global group objectives
  • Advised a multinational group on the tax aspects of a cross-border receivables assignment between entities in Latin America and the United States, including withholding tax considerations and potential double taxation issues
  • Participated in the structuring of a regional intra-group financing transaction, applying international tax principles, OECD standards and analyzing the tax treatment of complex cross-border financial flows
  • Member of the team advising a leading cryptocurrency and digital assets exchange platform in tax proceedings before the Peruvian Tax Authority regarding the tax treatment of digital economy and crypto asset transactions
Languages
  • English
  • Spanish

AWARDS AND RECOGNITION

The Legal 500 Latin America

  • The Legal 500 Latin America — Recommended Lawyer — Tax — (2025 – 2026)
Additional Awards
  • International Tax Review: Rising Star – Corporate Tax, (2026)
  • International Tax Review: Women in Tax Leader – Corporate Tax, (2026)
Education
  • ESAN University, Master's in Finance and Corporate Law, Major in Business Taxation, 2023
    Graduated first in her class
  • Carlos III University of Madrid, Postgraduate Specialization in Finance and European Law, 2022
  • Pontificia Universidad Católica del Perú, Second Specialization, 2016

Publications and media

  • Co-author, "Evidentiary Reasonableness in Intra-Group Services: Reflections on Benefit Test Audits," The Journal of the Peruvian Institute for Tax Research and Development (IPIDET).
  • Co-author, "Tax Audits of Corporate Groups and the Evidentiary Challenges of the Benefit Test," Tax Law Review of the Tax Studies Group (GET) of the Universidad Peruana de Ciencias Aplicadas (UPC).

Seminars

  • Speaker, "Tax Audits: Key Considerations," National Society of Industries (SNI), June 25, 2026
  • Lecturer, Module V – Transactions with Non-Residents, Specialization Program in Preventive Tax Audits and Tax Assessments, Lima Chamber of Commerce (CCL) / Quantum Business School, May 27 & June 2, 2026.
  • Speaker, "2025 Tax Year-End Closing: Strategies and Case Studies for Corporate Groups," National Society of Industries (SNI), March 12, 2026
  • Speaker, "Transactions with Non-Residents: Practical Cases, Controversies and Application of Income Tax and VAT," Quantum Business School, August 27, 2025
  • Speaker, "Tax Audits: Key Considerations," National Society of Industries (SNI), June 26, 2025
  • Speaker, "Transfer Pricing: Practical Compliance Guide," Quantum Business School, April 29, 2025
  • Speaker, "Tax Compliance Profile and Its Business Impact," National Society of Industries (SNI), April 10, 2025
  • Speaker, "Corporate Tax and VAT Compliance in Business Practice," Faculty of Business Administration, Universidad Tecnológica del Perú (UTP), December 2024
  • Conference, "Business Tax Accounting News: Review and Tax Compliance of the IGV" at the Faculty of Administration and Business of the Technological University of Peru, December 2024
  • Webinar, "Key aspects of intercompany taxation" by Thorne Echeandía & Lema Abogados, April 2024
  • Webinar, "Tax Closing 2023" by Thorne Echeandía & Lema Abogados, January 2024
  • Conference, "Causality and Reliability of Operations in Corporate Income Tax," Faculty of Administration and Business of the Technological University of Peru, June 2023
  • Seminar, "Finance and its Impact on Foreign Trade," PROMPERÚ, May 2023
  • Webinar, "Key aspects of the Tax Closure and the Annual Income Tax Return 2022" by Thorne Echeandía & Lema Abogados, December 2022
  • Event, "Affidavit of the Final Beneficiary," Diploma in Taxation of the College of Public Accountants of Lima, May 2022

Media Mentions

  • Quoted, "SUNAT sets limits on VAT collection involving foreign contractors," Gestión, March 16, 2026
  • Quoted, "Government formalizes taxation of streaming services and other digital services: learn which ones and how they will be taxed," Gestión, February 18, 2026

Prior Experience

Prior to joining DLA Piper, Paola served as a senior associate in the tax practice of a leading Peruvian law firm (2022 – 2024), and previously as an associate and legal assistant at another tax boutique (2018 – 2021).

Teaching Experience

  • Teaching assistant for "International Taxation and Agreements to Avoid Double Taxation" and "Taxation of Digital Business and Technology" course, taught by Professor Jesús A. Ramos Angeles at the Peruvian University of Applied Sciences – UPC
  • Teaching assistant for "Income Tax and IGV" course at the Faculty of Law of  Pontifica Universidad Católica del Perú

Memberships and Affiliations

Lima Bar Association

My latest insights

Publication

Peru establishes a new Private Special Economic Zones regime with up to 25-year tax...

27 April 2026

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Phone

+511 616 1200
(Work, Lima)

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