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Sandra Viviana
Africano F.

vafricano@pgplegal.com
Director | Impuestos, tasas y contribuciones
About Sandra Viviana

Head of the Tax Law department with more than 13 years of experience in territorial, national, and international tax planning and tax litigation. She advises on the structuring of domestic and cross-border transactions from a tax and foreign exchange perspective, as well as on wealth, estate, and family structuring.

Her experience spans the construction, education, religious and non-profit sectors, healthcare, medical and pharmaceutical industries, commercial and industrial sectors, as well as law firm practice.

Sobre el cliente

«The customer and the satisfaction of their needs represent the focus of our daily training, updating, and professional development.» —Sandra Viviana

PROFESSIONAL ACHIEVEMENTS

  • Annulment of administrative acts through which the Municipality of Chía denied the refund of an overpayment of the urban delineation tax following a partial waiver of a construction license (2024).
  • Reduction of the assessed income tax liability of a non-profit entity during a tax audit process, primarily concerning the reinvestment of the entity’s net benefit or surplus (2024).
  • Legal advisory and representation in judicial proceedings against the Special Administrative Unit of Cadastre regarding the improper and disproportionate valuation of commercial premises within a shopping center owned by a Latin American business group (2024).
  • Wealth, estate, and family structuring for individuals, enabling family organization aligned with clients’ needs and objectives, with tax efficiency considerations (2024).
  • Legal advisory to an investment fund in the structuring of a mixed-use real estate project in a prime area of Medellín, aimed at identifying and mitigating tax impacts and regulating contractual relationships among stakeholders for tax purposes, including the hotel operator (2023).
  • Annulment of administrative acts denying a refund request related to the funeral services fee in the Municipality of Los Patios (Norte de Santander) (2023).
  • Structuring of the sale of key corporate real estate assets to facilitate the acquisition of a recognized university, ensuring minimal tax impact for the parties involved (2022).
  • Member of the tax team responsible for compiling and analyzing the Colombian Tax Code for PwC Colombia.
  • Refund of an overpayment of the unified property tax in the Municipality of Anapoima.

PROFESSIONAL EXPERIENCE

  • Provides legal and tax advisory services for the development of domestic and cross-border business transactions.
  • Advises on tax and legal matters related to various commercial and corporate structures.
  • Advises on personal and family budget organization.
  • Designs and implements wealth and family planning strategies.

EDUCATION

  • 2024. LL.M. in International Law with an emphasis in Business Law, Universidad Externado de Colombia and Université Panthéon-Assas (Paris II).
  • 2019. Specialist Degree in International Tax Law, Universidad Externado de Colombia.
  • 2017. Specialist Degree in Tax Law, Universidad Externado de Colombia.
  • 2013. Law degree, Universidad del Rosario.

ACADEMIC ACTIVITIES

  • Professor of the Tax Law module within the course Real Estate Legal Management, Universidad del Rosario, 2023–2024.
  • Adjunct Professor of Tax Law, Faculty of Commercial Engineering, Universidad de Ciencias Aplicadas y Ambientales, 2019–2020.
  • Co-author of the Colombian Tax Code (Estatuto Tributario), PricewaterhouseCoopers (PwC) Colombia, 2016 and 2017 editions.
  • Researcher, Critical Studies on Tax Case Law, Volume II, Colombian Institute of Tax Law, 2012.
  • Researcher at the Tax Law Department, Universidad del Rosario, on Double Taxation Treaties, under the direction of Dr. Esperanza Buitrago Díaz, 2012.
  • Teaching Assistant, Tax Law course, Universidad del Rosario, 2012.
  • Researcher in the book Women’s Rights in the Jurisprudence of the Colombian Constitutional Court 2005–2009, a study conducted by Universidad del Rosario with the support of the Presidency of the Republic and the Presidential High Council for Women’s Equality, 2011.

RECOGNITIONS

  • Nominated and finalist for the “Women in Tax Award” granted by the International Fiscal Association (IFA), 2025.
  • Recognition in "Legal 500 Latin America" for the Tax Law team in Band 5, 2025.
  • Recognition in "Legal 500 Latin America" for the Tax Law team in Band 4, 2023-2024.
  • Recognition in "Leaders League" for the Tax Law team, 2022.
  • French.
  • La reforma tributaria recicla incentivos para saldar deudas. Diario: Asuntos Legales, 2021.
  • Alcances del informe de la comisión de expertos en materia tributaria. Diario Legis, 2021.
  • Principales novedades en tributación nacional y en Bogotá para el 2021. Business Mail, AmCham, 2021.
  • Beneficios tributarios por donaciones en tiempos del Covid-19. Diario: Asuntos Legales, 2020.