Aleph Holding (IMS Group S.A.C.) [Counterparty: TikTok USA]

Tax consultancy over new provision of services and consolidation. We are assisting Aleph with a tax consultancy encompassing a new provision of billing and collection services for TikTok USA and a consolidation transaction. Handling invoices for services provided by third party: Regarding the new provision of services, the client asked us to determine whether or not it should issue invoices to customers for consideration for the advertising services, since it would be issuing proof of payment for a service provided by a third party. Tax treatment applicable to a consolidation: We also assisted the client with the analysis of the implications and tax treatment applicable to a consolidation procedure in Peru. Our work consisted of communicating, analysing, and detailing to the client the options available for tax purposes under Peruvian regulations. Our analysis included the final destination of the balances in favour of income tax, as well as tax debts and credits. Global digital advertising powerhouse: Founded in 2005 as IMS Internet Media Services, Aleph is a global digital advertising powerhouse operating in over 140 countries. The client has partnerships with the world’s leading digital platforms, including TikTok, X (formerly known as Twitter), Microsoft, Amazon, Pinterest, Reddit, Spotify, and Google. Latest development: We continue assisting the client with this matter.

Matter value – include currency and amount in figures :

Aleph’s market value: USD 2 billion

Is this a cross-border matter? If yes, please indicate the jurisdictions involved :

Yes: Peru; USA

Lead partner :

Michael Morales

Other team members :

Fiorella Ríos

Other firms advising on the matter and their role(s) :

N/A

Date of completion or current status :

Ongoing