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THE COMPREHENSIVE GUIDE TO THE WORLD’S LEADING TAX CONTROVERSY ADVISERS

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Contents

2 Introduction and methodology3 Interview7 Global overview

AMERICAS

18 Interview29 Argentina31 Brazil51 Canada60 Chile62 Colombia67 Costa Rica67 Curaçao67 Dominican

Republic

67 Ecuador67 Guatemala67 Honduras68 Mexico74 Nicaragua75 Peru75 Puerto Rico76 United States100 Uruguay101 Venezuela

ASIA-PACIFIC

106 Interview116 Australia124 Cambodia125 China138 Hong Kong145 India151 Indonesia154 Japan

158 Malaysia160 New Zealand161 Philippines165 South Korea166 Sri Lanka166 Taiwan167 Thailand168 Vietnam

EUROPE, MIDDLE EAST & AFRICA

175 Interview185 Austria187 Belgium189 Bulgaria190 Croatia190 Cyprus190 Czech Republic190 Denmark192 Finland195 France200 Germany204 Greece205 Hungary206 Ireland207 Israel208 Italy219 Kuwait219 Luxembourg219 Malta

220 Netherlands223 Norway225 Oman226 Poland231 Portugal238 Romania240 Russia244 Saudi Arabia244 Slovak Republic244 Slovenia245 South Africa247 Spain253 Sweden264 Switzerland266 Turkey270 Ukraine271 United Arab

Emirates272 United Kingdom

TAX CONTROVERSY LEADERS www.itrworldtax.com | 1


IntroductionWelcome to the ninth edition of the Tax Controversy Leaders guidefrom World Tax – produced in association with the InternationalTax Review. This latest publication of the list of the world’s lead-ing tax controversy practitioners and marks a significant step in itsevolution, in both scope and scale. It covers more jurisdictions,reached out to more individuals and recognisea more practitionersthan ever before – from rising stars just making a name for them-selves to market leaders with decades of experience behind them

This year alone we reached out to more than 2,500 leading taxprofessionals from around the globe to gather their feedbackabout their markets and the individuals that stand out in them.The Tax Controversy Leaders guide now includes the names ofmore than 1,500 experts from jurisdictions in every corner of theworld; more than ever before.

These individuals are nominated by their peers and recom-mended as trusted advisors. We ask professionals to name the peo-ple they would refer their clients to in the event of a conflict, orrecommend as a local representative in another jurisdiction. Theyare also selected as those with the highest reputation amongclients in the market, collected from feedback from subject matterexperts. The resulting list is therefore a collection of tax contro-versy leaders recognised – by the leading names in their own andinternational markets – as those who perform strongest in theirfield. Market leaders chosen by market leaders.

As part of commitment to develop the guide, practitioners canalso provide online profiles if they are included this year. Thesewill offer them a chance to showcase their work to clients, offermore information about their skills and experience and displayfeedback given to our research team by clients from a broad rangeof industries.

We hope to do more moving forward. Reach out to more prac-titioners, receive feedback from more clients and provide coverageof more leaders from every market. We would like to thank thosewho took the time to provide feedback to help us put this guidetogether this year and would encourage everyone to do so in thefuture to ensure we are providing the broadest, most accurateassessment of the leaders in tax controversy that we can.

Jonathan Moore, Editor,World Tax and World TP



What is the most significant change to your region/jurisdiction’s tax controversy/disputes legislation in thepast 12 months?From a global perspective, the last 12 months have seen thecontinuance of countries embracing the concept of globalaction towards tax. The recent example of countries signing upto the Multilateral Instrument (MLI), is another example of afuture state in which taxpayers face a far more global challengeto their tax affairs. In concept, this global enveloping provides amore consistent approach to the management of disputes butwill no doubt involve a number of challenges in practice ontechnical interpretation, boundaries between countries and theability to efficiently move forward disputes that involve contrarypositions among participating countries.

What has been the most significant impact of thatchange?Where tax controversy was traditionally managed on a country-by-country basis, taxpayers must take a more macro perspectiveon the management of disputes, verify central coordination andmake sure that their people are appropriately equipped to dealwith the ever-increasing challenges. Moreover, in an era wheretaxpayer reputation is paramount and social responsibility isfront of mind, the globalisation of tax scrutiny means that tax-payers must demonstrate positive profile and acceptance ofchange in this sphere.

How do you anticipate that change impacting your workand the market moving forwards?This change has required a rethink and redesign of the manner inwhich Deloitte delivers services. While the need for market-leading

INTERVIEW

James FabijancicDeloitte

GLOBALRegional interview

James Fabijancic, the Deloitte global leader for tax controversy, answers questions about recentlegislative changes that impact jurisdictions around the world



Interview

technical ability, strategic thinking and resolution-based skills will always be central to ourservices, the assistance provided to clients is moving towards more regular teaming acrossmultiple jurisdictions in the Deloitte network. Also, it is enabling the emergence of newdemand for offerings around project management, technology enablement and design think-ing in helping our clients evolve with their new environment.

How has this changed the way you offer tax advice?As noted above, the way in which we offer tax advice is changing, the need for contributionsfrom client service teams in multiple jurisdictions is increasing and the delivery of advicerequires adherence to global standards to implement responsibility as a key participant in thetax profession. Finally, the development of new services have quickly emerged to providesolutions to the management and co-ordination challenges faced by clients.

What potential other legislative changes are on the horizon that you think willhave a big impact on your region/jurisdiction? Continued legislative change is inevitable, particularly as business practice and technologiesevolve further. In addition, to change in legislative instruments, I expect that the nature in whichauthorities coordinate review activities and testing of compliance with new laws will becomemore aligned, faster and delivered with the benefit of digital platforms. This is already becom-ing more commonplace with common reporting standards, multi-jurisdiction reviews andincreased information sharing and enforcement activities.

What are the potential outcomes that might occur if those changes areimplemented?This change will increase the need for clients to manage their affairs from a global perspective.I expect this will create new roles and responsibilities within client tax teams and, as is beingobserved already, a need for greater investment in these functions, a challenge enhanced bythe observation that talent pools in larger markets are thinning. This has fascinating potentialfor the future tax workforce, particularly as taxpayers within large markets turn towards small-er markets to recruit talent and invest heavily in training and development.

Do you think that change will have a positive effect on both your practice and thewider regional/jurisdictional market?With a number of excellent practices across the globe, these changes provide an exciting timefor Deloitte tax professionals including greater mobility of work opportunities and the needto embrace and develop best practice models from each of our practices.

A major benefit from this changing landscape will be the need for a greater level of proac-tivity of tax controversy professionals with our clients. This will lead to more enduring rela-tionships and ability to influence strategy.

How are issues surrounding the taxation of the digital economy affecting yourjurisdiction?In local markets, the taxation of the digital economy has been a major challenge. It hasbecome clear that existing and well-developed taxation systems were designed in a different



era focused on a more industrial society, designed around local market conditions. This is per-haps one of the great advantages of a more global system of taxation, as it provides an abilityfor jurisdictions to combine thinking on the appropriate manner in which to shape the futuretaxation of this area. Propositions of value contribution, importance of customer residenceand recognising the high cost and effort of investment will continue to be important factorsto keep appropriate balance of outcomes.

What is the tax authorities’ approach to tax auditing?A common piece of feedback from countries all over the world has been the increase in tech-nology-enabled audit with heavy investment in data analytics. There is a common trend ofinformation sharing with other regulators and the various common reporting regimes are cre-ating a situation where revenue authorities are more informed than ever before. This, coupledwith heavy investment by a number of countries in growing their workforce, is quickly result-ing in market-wide and continuing review activity becoming the new norm.

How has tax advice adapted to the changing tax audit approach, and how do youexpect it to change further?The skillsets of modern professionals are quickly shifting in response to this change. The tradi-tional legal and commerce backgrounds are now being supplemented by technologists and con-sultants. A far greater emphasis on governance, focus on automation of processes and functiondesign is being expected by our clients and a focus on all aspects of advisory through transactions,compliance and tax controversy are now geared towards the reality of review in real-time.

For disputes that require litigation (pre-litigation, and court proceedings), howare matters evolving in your jurisdiction/region? Are pre-court settlementsbecoming easier, and why?Litigation continues to be a difficult, expensive and a time-consuming exercise throughoutthe globe. In practice, many of the changes noted above are likely to remain years away fromformal contest and the market will need to form views in a measured fashion to deal with theinherent uncertainty of the lack of judicial precedent.

There does appear to be a movement away from litigation as an outcome of tax disputes.For reasons of reputation, increased complexity and the greater principles based underpin-nings of many of these modern legislative changes, pre-court resolution is becoming moreprevalent, though not necessarily easier, and it will be essential that a more globally focusedset of resolution techniques and standards be developed.

Interview



Interview

This document has been prepared solely for the purpose of publishing in the 2019 Tax Controversy Leaders guide andmay not be used for any other purpose. This document and its contents may not be reproduced, redistributed or passedon, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written consent.Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms,and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separateand independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and relatedservices. Our network of member firms in more than 150 countries and territories serves four out of five Fortune Global500® companies. Learn how Deloitte’s approximately 286,000 people make an impact that matters at www.deloitte.comThis communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its memberfirms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering profes-sional advice or services. Before making any decision or taking any action that may affect your finances or your business,you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any losswhatsoever sustained by any person who relies on this communication.© 2019. For information, contact Deloitte Touche Tohmatsu Limited.



The global tax audit and controversy environment is becomingmore complex and challenging. Increased transparency and riskassessments are leading to more tax audits and the pace is accel-erating as tax authorities become sophisticated in the use of dataanalytics to process vast amounts of information. Transfer pric-ing remains an area of heightened focus by tax administrationsand profit split approaches are being developed and relied onmore often (and even preferred by certain jurisdictions).Defining ‘value creation’ to determine the proper allocation ofprofits is, however, subjective in nature and it is difficult toreach consensus on a standardised approach, or even the com-mon elements in a suggested methodology. Consequently, thereare significant questions as to whether tax administrations arelikely to accept allocations of profits based on methods withvariable elements, thereby creating uncertainty and the risk ofdouble taxation.

This risk is becoming more visible in the emerging digitalworld, where there is no consistent international framework.The Organization for Economic Cooperation and Development(OECD), the European Commission, and individual countriesin the European region are proposing new policies for taxingthe digital economy with the aim to better align taxable incomewith value creation. The OECD is pressured to find a solutionin the near future, given unilateral measures to tax the digitaleconomy will increase the risk of double taxation. Multinationalcorporations (MNCs) are closely monitoring these develop-ments in the digital space, as well as the promulgation of newinternational tax rules in the United States and in a number ofcountries, with an eye towards understanding how these newrules will impact supply chain operations. In this fast-paced andcomplex environment, where data moves more rapidly and new

GLOBAL OVERVIEW

David SwensonPwC

Tax audit risks andassessments – risingcomplexity and uncertaintyDavid Swenson, global tax controversy leader in the Washington DC office of PwC, discussesthe global tax audit and controversy environment and what complexities and challenges it raisesfor regimes and companies alike.



Global overview

rules are developing with greater frequency, MNCs are strongly encouraged to take proactiveapproaches to mitigating risk via audit readiness from a globally based platform.

Transparency and audits in the post-BEPS audit environmentThe OECD has undertaken substantial work to develop and employ tools to assist tax author-ities in performing tax risk assessments. Most notable is the country-by-country reporting(CbCR) requirement that has now been adopted throughout the world. The CbCR providesa comprehensive view into the profits earned and the taxes paid by MNCs in each jurisdictionin which they operate. MNCs were first required to submit the filing in 2017 and govern-ments started to exchange the reports in 2018. In this environment, there is little doubt thatthe data will be used by tax authorities to initiate and conduct tax audits. As a result, manyobservers believe that MNCs will experience a significant uptick in audits directly attributableto the CbCR.

We are also experiencing increased cooperation among tax administrations through theautomatic exchange of information, including an increase in simultaneous and /or jointaudits. There is also a trend in the more frequent use of data analytics to target audits. In theUS, the Internal Revenue Service (IRS) has taken on a number of initiatives to better collectand process data, including entering into long-term contracts with third party technologycompanies to use data analytics as a key tool in performing risk assessments.

The OECD’s Forum on Tax Administration Large Business and International Programhas also implemented two key risk assessment projects. The first project is theInternational Compliance Assurance Program (ICAP), which was launched in January of2018 as a pilot initiative with seven participating tax administrations (Australia, Canada,Italy, Japan, the Netherlands, the United Kingdom and the United States). The secondphase of ICAP (referred to as ‘ICAP 2.0’) is in its initial stages and involves a number ofnew jurisdictions, now including 17 or more tax administrations. ICAP will continue itsfocus on achieving consistent interpretation and use of CbC reports as well as achievingmore efficient multilateral tax certainty. The second project is the Comparative RiskAssessment initiative that is intended to assist tax administrations to determine how theycan use the CbCR in parallel with other sources of data to identify transactions that posetax risks. These risk assessment approaches are being launched to help tax administrationsindividually and collectively manage international tax risks through the development ofbest practices.

MNCs facing audits in the post-BEPs environment are increasingly vocalising concernsabout enquiries that are often accompanied by aggressive audit tactics and the assertion ofunprincipled positions. In certain cases, contentious audits are creating reputational concernsand even harming business relationships. This is producing significant challenges for MNCsin terms of time invested and costs incurred. On the other hand, certain jurisdictions recog-nise the need for improved collaboration between the exam level and competent authority.For example, in the US, the Commissioner of the IRS Large Business and InternationalDivision (LB&I) recently issued a memorandum requiring the LB&I issue teams that exam-ine transfer pricing issues involving a treaty partner to consult with the Advance Pricing andMutual Agreement (APMA) office. This approach provides a means for APMA to becomeinvolved in transfer pricing examinations well before a mutual agreement procedure (MAP)



request is filed, and it also provides IRS exam teams with an understanding of the perspectiveof the US competent authority on the potential transfer pricing issues early in the examprocess. This early involvement of APMA could lead to a reduction in cross-border disputesby limiting US-based adjustments that are not consistent with transfer pricing principles orexpected competent authority outcomes.

Increased reliance on profit split approaches Profit split approaches have become more common, not only in the context of issuing newguidelines and local legislation, but also in audits and in applying alternative dispute resolu-tion options. The underlying issue in many transfer pricing disputes is centered on the con-cept of value creation and issues concerning how to attribute profit related to the creation ofthat value. These disputes tend to be complex, and as a result audits and negotiated settle-ments are often protracted.

Action 10 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan relatedto the development of rules or measures that clarified the application of profit splitapproaches in the context of global value chains. In June of 2018, the OECD released itsfinal report titled Revised Guidance on the Application of the Transactional Profit SplitMethod. This report provided that a profit split approach may be appropriate when thecontributions of the parties cannot be reliably evaluated in isolation where the relevantbusiness operations are highly integrated, or where the parties share the assumption ofeconomically significant risks or assume closely related risks. Determining what actuallyconstitutes “highly integrated”, or “economically significant risks”, or “closely relatedrisks”, often requires a subjective determination and, accordingly, may be extremely diffi-cult to implement in practice.

In the context of alternative dispute resolution options, the US APMA programmerecently announced the release of a Functional Cost Diagnostic Model (FCD Model), whichis an Excel-based tool for collecting and processing taxpayer financial data through a resid-ual profit split method (RPSM). The FCD Model reflects APMA’s view that a diagnosticevaluation of taxpayer data under an RPSM model may be appropriate in cases where APMAbelieves two or more parties are making significant value-added contributions to the rele-vant business operations, regardless of industry or whether the proposed covered transactionis inbound or outbound to the United States. In these cases, taxpayers may be asked to col-lect and populate certain financial data with the outcome of the inputs into the FCD Modelbeing a pro forma split of residual profits or losses based upon the relative stocks of accu-mulated and capitalised functional costs. To the extent a taxpayer is required to completethe FCD Model, it should anticipate facing numerous factual and economic questions dur-ing the course of interactions with APMA on applying the model.

The new reality is that profit split approaches will continue to apply in the context of trans-fer pricing disputes and MNCs will need to adapt, particularly in the digital world. Digitalbusiness models are complex, where data flows at heightened speed and value moves withgreater functional complexity. The challenge is that there is no consistent or uniform set ofinternational rules to appropriately perform transfer pricing analyses based on value creationin this area. A solution to this challenge may be on the horizon through the combined effortsof the OECD and other key stakeholders.

Global overview



Global overview

BEPS 2.0 – the Digitalisation Project ‘BEPS 2.0’ or the ‘Digitalisation Project’ refers to the OECD’s efforts to develop a mul-tilateral set of rules related to the jurisdiction to tax and the allocation of profits in thedigital world. Led by the Inclusive Framework, a body of jurisdictions involved in theproject, a number of interim policy notes and reports have been issued over the last twoyears. The Inclusive Framework has explicitly recognised that if a comprehensive consen-sus-based solution is not reached within the agreed G20 time frame, there is a fundamen-tal risk that jurisdictions will increasingly adopt uncoordinated unilateral tax measures. Inthis regard, the OECD recently released the highly anticipated Programme of Work toDevelop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of theEconomy, which sets forth a blueprint for two key pillars – (i) new rules on profit allocationand nexus; and (ii) a new global minimum tax and anti-base erosion provisions. Underthe first pillar, a new standard of taxable presence would be developed that allows a coun-try to impose tax in cases where an MNC does not have a physical presence and to real-locate profits to market jurisdictions where a consumer is located. This is considered anotable departure from historic rules that are based largely on the functions, assets, andrisks located in a country to determine the appropriate allocation of profits. The OECDwill, however, continue to carefully evaluate the proposed nexus and profit allocationrules that have been set forth by various jurisdictions to help build consensus. This con-tinued work will need to move forward rapidly, given the G20’s mandate to find a solu-tion that appeases more than 100 jurisdictions (many of which have different interests) inthe next 18-24 months. Although this is an aggressive timeline, it is deemed necessarybased on the number of countries with digital tax plans in progress that will result in uni-lateral measures and could inevitably lead to double taxation.

US tax reform and controversy on the horizonThe international tax provisions in the US Tax Cuts and Jobs Act (TCJA), coupled with aninterconnected, complex, and challenging global tax environment relating to BEPS 2.0, willcomplicate MNCs’ supply chain decisions on where to locate business functions, assets, risks,and intangibles. MNCs are to be particularly well-advised to consider transfer pricing riskwith respect to the Base Erosion Anti-Abuse Tax (BEAT), the Global Intangible Low-TaxedIncome (GILTI) tax, and the Foreign-Derived Intangible Income (FDII) deduction. Theinteractions between the three must be closely evaluated because the tax consequences of oneprovision may significantly impact the tax consequences of another. As MNCs consider dif-ferent supply chain locations based on the interaction of the three provisions within theirglobal structures, MNCs must also consider the risk of transfer pricing audits and examina-tions, and develop and implement appropriate strategies and best practices.

New limitations on income shifting through intangible property transfers now place morefocus on functions performed as compared to capital at risk. The US TCJA also modifies thedefinition of intangibles to include goodwill, going-concern value and workforce in place.Further, in most cases, intangible property transfers are now subject to valuation on an aggre-gate basis or a realistic alternative basis. In this regard, it will be important for MNCs to con-sider how these new provisions impact the cost of intangible property migration and theincreased risk of transfer pricing audits, both inside and outside of the United States.



Audit readiness and dispute resolution options – global strategiesHistorically, taxpayers have handled transfer pricing audits on a case-by-case or ad-hoc basis,driven by local country resources. This approach is no longer viable in today’s volatile taxenvironment, where audit readiness on a global basis is critical. Tax departments are revisitingrisk mitigation procedures and deploying global strategies to assess risk and develop a coor-dinated, centralised approach to transfer pricing disputes. This requires an understanding ofimportant nuances in audit processes on a country-by-country basis. In that connection, thedispute resolution process, including the right to administrative appeals, competent authorityprocedures, and litigation, varies across jurisdictions, requiring enhanced awareness of proce-dural options and requirements.

Moreover, in an era of global transparency, MNCs need to own one set of facts withrespect to a clear understanding of the company’s business operations, including the overallsupply chain as well as contractual and functional profiles and transfer pricing policies. Thisavoids local country responses that may inadvertently portray incorrect positions leading toinconsistencies between countries. As a result, a standardized set of comprehensive documen-tation is critical. Equally important is training of staff on transfer pricing policies and auditstrategies as well as ensuring the integrity of internal controls and systems.

Assessing audit readiness is also prudent in the context of planning opportunities byaddressing uncertainty upfront and developing a proactive approach to assess the risk of cur-rent and potential positions through the lens of the future tax landscape while consideringproposed and finalised legislation. This has become increasingly important as a result of BEPS2.0 and local tax reform initiatives.

Effective dispute resolution capabilities have become more critical, with tax departmentsincreasingly considering alternative dispute resolution options including MAPs, as well asAPAs and other pre-filing rulings. Such options, however, must be evaluated on an issue-by-issue and country-by-county basis as to whether the dispute resolution option at hand will bemost effective and efficient. The OECD’s Action 14, relating to more effective dispute reso-lution mechanisms, recommended the development of a minimum standard to improvecross-border dispute resolution processes and provided certain best practices for participatingcountries as adopted through the multilateral instrument (MLI). In this regard, certain coun-tries have made progress in working to improve domestic processes and procedures. TheUnited States, for example, has received a favorable review by OECD peers and continues toimprove MAP, taking into account a recent report issued by the US GovernmentAccountability Office that outlines eight recommendations for improving the resolution ofinternational tax disputes. This report, along with BEPS Action 14, contains needed reformsand reflects positive trends toward making dispute resolution mechanisms more effective.

TakeawayThe global tax community expects uncertainty and complexity in the tax audits and disputesarea will continue for the foreseeable future, particularly where enhanced transparency andrisk assessments are common themes and the risk of audits are increasing. Tax administrationsare becoming more invested in the use of data analytics and intelligence to develop data andidentify audit targets. Profit split approaches may be used more frequently in situations wherea particular tax administration deems such an approach necessary to achieve its fair share of

Global overview



Global overview

income and tax. Moreover, the OECD’s blueprint for a global minimum tax and the alloca-tion of profits may result in a fundamental change to the international tax system that hasexisted for many decades. Until consensus is reached on these proposals, individual countrieswill continue to move forward with unilateral steps in taxing the digital economy, and, as aresult, the risk of double taxation of MNCs may substantially increase. In this ever changingand complex environment, MNCs will face new challenges to being taxed and are well-advised to develop strategies to prevent and manage audits on a global scale.

The author would like to acknowledge and thank Crystal A. Thorpe, PwC, Director – GlobalRestructuring, for her contribution to this article.


Americas



AMERICAS

Americas The Deloitte network of member firms in the Americas deploys the applicable local andregional teams in a time-efficient manner. In the Americas, Deloitte’s tax controversyteams consist of more than 166 professionals in offices in 32 locations across the net-work of member firms.

In Canada, Deloitte Tax Law has 15 lawyers specialising in tax controversy acrossthree offices: Montreal, Toronto and Vancouver. Deloitte Tax Law is an independentnational law firm affiliated with Deloitte in Canada, which has offices across Canada.

Professional services teams are present in Deloitte firms across the globe to provideservices locally, while coordinating engagements regionally or globally from a centrallocation.

Deloitte in the Americas tax controversy teams also draw on the capabilities andstrengths of Deloitte’s other businesses – audit and assurance, consulting, and risk andfinancial advisory – to provide broad-scale, tax-aligned business insights.

Deloitte in the Americas region has been developing a cross-border standards and gov-ernance model and a network of virtual and physical centres that is aligned with Deloitte’sglobal platforms. This model offers a broad scope of integrated services including tax con-troversy, compliance, tax provision, statutory accounting, tax advisory services includinginternational tax, global customs and trade advisory and transfer pricing.

Tax capabilities include the following services:• Business tax: tax controversy; tax compliance and reporting; tax implications of busi-

ness change; tax advice regarding cryptocurrency, tokenized business models andblockchain enterprise solutions; business, high net worth, and international tax con-sulting business process insights

• Global employer services• Global investments and innovation incentives • Indirect tax• M&A• Tax management consulting• Transfer pricing • Deloitte Legal (in applicable countries)• Global information reporting and withholding, including FATCA (Foreign Account

Tax Compliance Act) and the common reporting standardTax Controversy professionals of Deloitte firms in the Americas provide assistance

spanning the various stages of federal, state, and local examinations – from dispute mit-igation/planning to issue resolution and post-exam improvements. Through decades ofworking with clients on a broad range of tax issues, Deloitte firms in the Americas havefine-tuned their technology, analytical procedures and planning methodologies to offer



AMERICAS

a broad-based, scalable solution that can be tailored to the specific circumstances of eachclient and each tax controversy.

Deloitte firms in the Americas offer various cross-border tax controversy capabilities,including the following services:• Re-controversy audit readiness assessments including: • Risk assessments • Documentation readiness and retention preparation• Mock audits• Examinations• Litigation, appeals and settlement • Proactive resolution services• Transfer pricing• Tax controversy software tools and support

Innovation is a key component of Deloitte’s Tax Controversy offerings across theAmericas region. Deloitte’s network of firms is investing heavily in tax technology andanalytics capabilities and developing solutions to help clients mitigate the potential for,manage, and learn from the various types of tax disputes – which in turn, translates tovalue for our clients. Collaboration allows Deloitte firms to develop tax technology solu-tions that address specific and complex tax requirements in the Americas region.Deloitte firms in the Americas can provide innovative tax controversy software tools andsupport including:• Tax Controversy Manager: Proprietary web-based tool for managing examination-

related data and reporting.• Interest Analyzer: Service to verify the accuracy of complex federal and state tax

agency interest calculations.• Data Management: Assistance with integrating systems to capture, retain, process, and

analyse information, and respond quickly to high-volume information requests.Assistance with planning for tax data retention related to ERP systems implementation.

Recent wins:• Deloitte’s Mexico tax controversy practice worked on and accomplished a series of

settlements with the Mexican Tax authority pertaining to the cancellation of the con-solidation tax regime. These settlements were achieved without litigation and includ-ed more than $300 million in savings for several important corporate clients.

• Effective resolution of a Canadian transfer pricing dispute for a Fortune 50 companyin relation to transfer pricing adjustments of intra-group costs and services of approx-imately CAD$13 million.

• A successful appeal to the Tax Court of Canada as a result of an agreed upon Consentto Judgment in relation to an assessment denying expenditures on or in respect toscientific research and experimental development (SRED) of more than CAD$7 mil-lion and corresponding investment tax credits of more than CAD$1 million.

• Efficient resolution of a SRED dispute for an important mining company in rela-tion to the denial of a deduction for expenditures on, or in respect to, SRED of



AMERICAS

approximately CAD$18.5 million, and corresponding investment tax credits ofCAD$5.5 million.

• Effective judicial review application for a major Canadian insurance company to chal-lenge a decision by the Canada Revenue Agency to deny the retroactive revocationof an election.

Awards: 2018 International Tax Review (ITR) Americas Tax: • Regional Awards: • Americas Tax Compliance & Reporting Firm of the Year (fourth consecutive year) • Americas Tax Technology Firm of the Year • Americas Transfer Pricing Firm of the Year (second consecutive year)• National Tax Firms of the Year: Deloitte Venezuela • National Transfer Pricing Firms of the Year: Deloitte Colombia, Deloitte Peru,

Deloitte United States • Other Transfer Pricing Firms of the Year: North America, Central America

2018 ITR World Tax & World Transfer Pricing:• World Tax: Eight countries ranked Tier 1 (Argentina, Brazil, Canada, Colombia,

United States) or Tier 2 (Chile, Mexico, Uruguay)• World Transfer Pricing: 10 countries ranked Tier 1 (Argentina, Brazil, Canada Chile,

Colombia, Mexico, Peru, United States, Venezuela) or Tier 2 (Uruguay)

Recognised Leader: Euromoney and International Tax Review – Tax leader guides: 67 leaders across theregion were recognised for their individual abilities, as well as for their in-depth capabil-ities, experience, and specialist knowledge:• 46 in Euromoney Guide to the World’s Leading Tax Advisers 2018• 46 in ITR Tax Controversy Leaders Guide 2018• 23 in ITR Indirect Tax Leaders Guide 2018• 75 in ITR Women in Tax Leaders Guide 2018• 56 in 2017 Guide to the World’s Leading Transfer Pricing Advisers

Phone: +12022202118Email: [email protected]: @DeloitteTaxWebsite: www2.deloitte.com/us/en/pages/tax/solutions/

tax-controversy-services.html?icid=nav2_tax-controversy-services



AMERICAS

This document has been prepared solely for the purpose of publishing in the 2019 Tax Controversy Leaders guideand may not be used for any other purpose. This document and its contents may not be reproduced, redistributedor passed on, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written con-sent.Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of memberfirms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms arelegally separate and independent entities. DTTL does not provide services to clients. Please seewww.deloitte.com/about to learn more.Deloitte Legal refers to the legal practices of Deloitte Touche Tohmatsu Limited member firms (or their respectiveaffiliates) that provide legal services outside of the US. For legal and regulatory reasons, some member firms,including the US member firm, do not provide legal services.Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax andrelated services. Our network of member firms in more than 150 countries and territories serves four out of fiveFortune Global 500® companies. Learn how Deloitte’s approximately 286,000 people make an impact that mattersat www.deloitte.comThis communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its mem-ber firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, render-ing professional advice or services. Before making any decision or taking any action that may affect your financesor your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall beresponsible for any loss whatsoever sustained by any person who relies on this communication.© 2019. For information, contact Deloitte Touche Tohmatsu Limited.



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What is the most significant change to yourregion/jurisdiction’s tax controversy/disputes legislationin the past 12 months?The Americas continue to address a number of changes that willimpact controversy. Some countries have recently enacted majortax legislation that increased the need for alternative dispute res-olution strategies to avoid costly and unnecessary litigation.Additionally, funding disparities across the taxing authoritieswill have an impact on the compliance approaches that author-ities may take to encourage voluntary compliance, and deployresources to the most significant non-compliance. Appropriatefunding, coupled with recently enacted tax legislation, will likelyaffect the way audits will be conducted in the Americas.

What has been the most significant impact of thatchange?It is too early to assess the impact of tax reform on tax controversy.Some countries have implemented an issue-focused approach.Centralised decision-making and the deployment of limitedresources, should enable a more strategic approach. That said, itmay take time for the tax authorities to see real change as many taxaudit personnel have traditionally scoped their examinations inde-pendently and may not adjust to the new approach immediately.

How do you anticipate that change impacting your workand the market moving forwards?Published guidance for much of the new legislation has broughtmany added challenges to the tax preparation process. Tax con-troversy specialists are more involved in supporting compliancepersonnel in providing advice on tax preparation matters. In addi-tion, due to the uncertainty stemming from new law, controversy

INTERVIEW

Rosemary SeretiDeloitte Tax

AMERICASRegional interview

Rosemary Sereti, managing director of the Washington national tax and Americas taxcontroversy services practice at Deloitte Tax, answers questions about recent legislative changesin the US.



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Interview

specialists are focusing more on the examination process with the goal of trying to resolve issuesat the lowest level possible. As a result, it is essential to have controversy specialists who are notonly technically proficient and procedurally savvy, but also know how and when to elevate anissue to the appropriate levels within a taxing authority. Clients are likely to demand such com-petencies, as issues become more difficult to resolve at the examination level.

How has this changed the way you offer tax advice?Deloitte’s tax controversy professionals in the Americas take the premise of financial state-ment certainty seriously, and issue resolutions are key goals of the chief financial officers andtax executives. Moreover, our controversy professionals appreciate that tax and reputationalrisks are concerns of tax-oriented corporate executives. We continue to strive to provideclients with relevant and practical tax advice, augmented by our insights into the merits ofregional campaign processes and how the issues are developed in various countries.

What potential other legislative changes are on the horizon that you think willhave a big impact on your region/jurisdiction? The recently enacted tax reform (i.e. Tax Cuts and Jobs Act) legislation in the United Stateshas been followed byformal guidance in the form of regulations, procedures and other inter-pretive rulings. As a result, tax administrators and executives are being forced to deal withvarious issues that arise as a result of the new interpretive guidance. Even with such guidancein place, there continue to be areas of uncertainty for taxpayers and practitioners — and tax-payers will likely be required to address issues without any clear answers.

What are the potential outcomes that might occur if those changes areimplemented?Tax administrators are in the process of hiring staff who will provide much-needed guidancewith respect to the new tax laws. Such guidance may result in the need to amend tax filingsby taxpayers who file tax returns prior to such final guidance being issued. Dedicated profes-sionals on both sides of tax administration should work diligently to get up to speed on thetechnical changes presented by the new tax law. Examinations may slow down as filing mat-ters take precedence.

Do you think that change will have a positive effect on both your practice and thewider regional/jurisdictional market?As these changes occur, clients seek a tax controversy practice that has a deep bench of expe-rienced tax controversy specialists. More specifically, clients want firms with professionals thathave experience in pre-filing, examinations and appeals. In addition, a tax controversy prac-tice should be staffed with respected senior executives that have significant experience andknowledge of the inner workings of taxing authorities.

How are issues surrounding the taxation of the digital economy affecting yourjurisdiction?Tax administrators are evolving to adapt to the new ways taxpayers do business. While sometime may still be needed to catch up to changes in the digital economy, ultimately, taxing



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authorities should employ needed safeguards to implement the equal application of tax lawsto all taxpayers, regardless of their exposure to the digital economy.

What is the tax authorities’ approach to tax auditing?Taxing authorities are transitioning to a centralised, automated approach to select the highestrisk taxpayers for examination. Using data analytics, taxpayers will be selected for examina-tions guided by an issue-focused approach. With the exception of taxpayers involved inaggressive tax planning, authorities may no longer target specific industries or taxpayers foraudit. As a result, authorities are likely to be more cooperative and transparent with taxpay-ers.

How has tax advice adapted to the changing tax audit approach, and how do youexpect it to change further?Educating taxpayers on the taxing authorities compliance programmes and enforcement ini-tiatives will be a major component of the educational curriculum for taxpayers. One of themain points that tax controversy professionals in Deloitte firms in the Americas stress is theelevation of an unresolved issue within the taxing authority. These professionals rightlybelieve that effective use of elevation will be necessary in taxpayers’ audit defense considera-tions.

For disputes that require litigation (pre-litigation, and court proceedings), howare matters evolving in your jurisdiction/region? Are pre-court settlementsbecoming easier, and why?Pre-litigation resolution is often accomplished at an appellate function. Traditionally, appealshave been handled by seasoned professionals and recently, such functions have been adverselyaffected by retirements. It takes longer to schedule an appeals conference, and as such,appeals-based settlements are more difficult to timely accomplish. Because of these hurdles,taxpayers should escalate their unresolved issues during the course of the examination toavoid delays in appeals’ determinations.


Interview



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What is the most significant change to your region/jurisdiction’s tax controversy/disputes legislation in thepast 12 months?The courts are still evolving towards a more authority-friendlyposition and the tax administrations are also being more aggres-sive in their collection efforts, as an indirect result of the former(the need for additional tax revenues is also a strong motivationfor this).

What has been the most significant impact of thatchange?More opportunities for services, additional opportunities forgrowth, more need for specialisation and development of capa-bilities to deal with alternative means of dispute resolution(negotiations, Mutual Agreement Procedure, arbitrage).

How do you anticipate that change impacting your workand the market moving forwards?Tax controversy should become much more relevant while alsofostering the need for more sophisticated tax and negotiationcompetency.

How has this changed the way you offer tax advice?Tax Controversy is now offered as a part of a more extensive serv-ice, and including alternative resolution processes, were applicable.

What potential other legislative changes are on thehorizon that you think will have a big impact on yourregion/jurisdiction? Implementation of Base Erosion Profit Shifting (BEPS) reportcould put additional strain on taxpayers’ need to support

INTERVIEW

Mauricio Martínez MezaDeloitte Mexico

AMERICASRegional interview

Mauricio Martínez Meza, a partner with Deloitte Mexico, answers questions about recentlegislative changes in Mexico.



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Interview

economic substance in operations, transactions, structures. Also, limitation on access to consti-tutional challenges (where applicable) to tax amendments should result in taxpayers focusing onalternative dispute resolution processes, i.e. avoiding litigation in favor of agreed settlements.

What are the potential outcomes that might occur if those changes areimplemented?An increase in the need to develop regional or local go-to-market (G2M) strategies to high-light proficient capabilities to multinationals.

Do you think that change will have a positive effect on both your practice and thewider regional/jurisdictional market? Yes. More work with better pricing, should tax and negotiation capabilities become a focalpoint for clients making a decision on who to engage.

How are issues surrounding the taxation of the digital economy affecting yourjurisdiction?It’s starting to have an effect, but LATAM is a little bit behind the curve in implementing digitaltaxation. It should gain momentum in the coming years as LATAM countries believe an impor-tant amount of ‘source’ taxation is lost due to the development of the digital economy.

What is the tax authorities’ approach to tax auditing?Generally very aggressive, with the preconception that any transaction or operation thatresults in lower taxation is due to incorrect application of the tax laws by the taxpayer, if notoutright tax evasion tactics. This aggressive attitude is paired, in many cases across theLATAM region, with a lack of know-how in the government’s auditing teams.

How has tax advice adapted to the changing tax audit approach, and how do youexpect it to change further?Economic substance and business support is being highlighted as a pivotal element of an effi-cient tax planning process. Also, it has created the need for the further involvement of taxcontroversy practitioners in the early stages of tax advisory service.

For disputes that require litigation (pre-litigation, and court proceedings), howare matters evolving in your jurisdiction/region? Are pre-court settlementsbecoming easier, and why?Pre-court settlements have become more popular and in some countries, they are the pre-ferred means for settling a tax dispute. This may include Mutual Agreement Procedures(MAP) or formal negotiation processes. The tax controversy professional is adding a negoti-ation element to his or her skillset as a result.



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Interview


TAX CONTROVERSY LEADERS www.internationaltaxreview.com | 24

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Cynthia CalligaroDeloitte Argentina

Tte. Gral. J. D. Perón 646, 2do Piso,C1038AAN, Buenos Aires, ArgentinaTel: +54 11 4320 [email protected]

Olivier FournierDeloitte Legal Canada LLP

La Tour Deloitte, 1190 Avenue desCanadiens-de-Montréal, Bureau 500,Montréal, QC H3B 0M7, CanadaTel: [email protected]

Norma KraayDeloitte Canada

Bay Adelaide Centre, East Tower 8Adelaide Street West, Suite 200,Toronto, ON M5H 0A9, CanadaTel: [email protected]

Markus NavikenasDeloitte Canada

850- 2nd Street S.W. Suite 700,Calgary, AB T2P 0R8, CanadaTel: [email protected]

Christine RamsayDeloitte Canada

8 Adelaide Street West, Suite 200,Toronto, ON M5H 0A9, CanadaTel: [email protected]

Patrick BilodeauDeloitte Canada

100 Queen Street Suite 1600, Ottawa,ON K1P 5T8, CanadaTel: [email protected]

Richard GarlandDeloitte Canada

8 Adelaide Street West, Suite 200,Toronto, ON M5H 0A9, CanadaTel: [email protected]

David MuhaDeloitte Legal Canada LLP

Bay Adelaide Centre East, 8 AdelaideStreet West, Suite 200, Toronto, ONM5H 0A9, CanadaTel: [email protected]

Rob O’ConnorDeloitte Canada

Bay Adelaide Centre, East Tower 8Adelaide Street West, Suite 200,Toronto, ON M5H 0A9, CanadaTel: [email protected]

Christopher SladeDeloitte Legal Canada LLP

Bay Adelaide East, 8 Adelaide StreetWest, Suite 200, Toronto, ON M5H0A9, CanadaTel: [email protected]

24 | www.internationaltaxreview.com TAX CONTROVERSY LEADERS


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Mario Andrade-PerillaDeloitte Colombia | DeloitteAsesores y Consultores Ltda.

Cra 7 # 74 - 09, Bogota, A.A. 07854,ColombiaTel: +57 1 [email protected]

Alan SaboríoDeloitte Costa Rica

Centro Corporativo El Cafetal, EdificioDeloitte, La Ribera, Belén, Heredia,Costa RicaTel: +506 2246 [email protected]

Rita María SilvaDeloitte Honduras

Edificio Plaza América, ColoniaFlorencia Norte, Tegucigalpa,HondurasTel: +504 2276 [email protected]

Ricardo GonzalezOrtaDeloitte Mexico

Av Paseo de la Reforma 505 P28 Col.Cuauhtémoc, Mexico, Ciudad deMéxico 06500, MexicoTel: [email protected]

Mauricio Martinez-D’MezaDeloitte Mexico


Anabelle León FeoliDeloitte Costa Rica

Centro Corporativo El Cafetal, EdificioDeloitte, La Ribera, Belén, Heredia,Costa RicaTel: +506 2246 [email protected]

David InfanteDeloitte Dominican Republic

Calle Rafael Augusto Sanchez No. 65,Edificio Deloitte, Ensanche Piantini,Santo Domingo, Dominican RepublicTel: +1 809 563 [email protected]

Martha DorantesDeloitte Mexico


Jorge JimenezDeloitte Mexico


Carlos AlbertoRamírez LarsenDeloitte Mexico

Avenida Juárez 1102, Piso 40 CENTRO,Monterrey, Nuevo Léon 64000, MexicoTel: [email protected]



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Eduardo RevillaDeloitte Mexico


Ricardo SantoyoDeloitte Mexico


Hernaldo VegaDeloitte Mexico


Yanira ArmasDeloitte Peru

Las Begonias 441 Piso 6 San Isidro,Lima, Lima Lima 27, PeruTel: +511 [email protected]

Michael BryanDeloitte Tax LLP

1700 Market St, Philadelphia, PA19103-3984, United StatesTel: +1 215 [email protected]

Hugo RomeroDeloitte Mexico


Simon SomohanoDeloitte Mexico

Misión de Sn Javier 10643 P.8 Col.Zona Urbana Río Tijuana, BajaCalifornia N 22010, MexicoTel: [email protected]

Juan Carlos CortezEspinozaDeloitte Nicaragua

Los Robles No. 351, Managua,NicaraguaTel: +505 2278 [email protected]

Howard BermanDeloitte Tax LLP

30 Rockefeller Plaza, New York, NY10112-0015, United StatesTel: +1 212 [email protected]

ChristopherCampbellDeloitte Tax LLP

555 West 5th St. Suite 2700, LosAngeles, CA 90013-1010, United StatesTel: +1 [email protected]



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Kerwin ChungDeloitte Tax LLP

555 12th St NW Ste 400, Washington,DC 20004-1207, United StatesTel: +1 202 [email protected]

Daniel CookDeloitte Tax LLP

111 S. Wacker Drive, Chicago, IL60606-4301, United StatesTel: +1 312 [email protected]

Thomas J DriscollDeloitte Tax LLP

111 S. Wacker Drive Chicago, IL60606-4301 United StatesTel: [email protected]

Edward GradyDeloitte Tax LLP


Darrin LitskyDeloitte Tax LLP


Jon ContrerasDeloitte Tax LLP

5250 N Palm Ave Ste 300, Fresno, CA93704-2212, United StatesTel: +1 559 [email protected]

Valerie DickersonDeloitte Tax LLP


Daniel DumezichDeloitte Tax LLP

111 S. Wacker Drive, Chicago, IL60606-4301, United StatesTel: +1 [email protected]

John KeenanDeloitte Tax LLP


Wade McKnightDeloitte Tax LLP

1111 Bagby St. Ste 4500, Houston, TX77002-2591, United StatesTel: +1 713 [email protected]



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Mark NehorayDeloitte Tax LLP

555 West 5th St. Suite 2700, LosAngeles, CA 90013-1010, UnitedStatesTel: +1 213 [email protected]

Keith ReamsDeloitte Tax LLP


Joseph TobinDeloitte Tax LLP


Kimberley PetersonDeloitte Tax LLP

225 West Santa Clara Street, SanJose, CA 95113-2303, United StatesTel: +1 408 [email protected]

Rosemary SeretiDeloitte Tax LLP

555 12th Street NW Ste 400,Washington, DC 20004-1207, UnitedStatesTel: +1 202 [email protected]

Jack TrachtenbergDeloitte Tax LLP




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ARGENTINA

Mariano BalloneTeijeiro & Ballone Abogados

Martín BarreiroBaker McKenzie

Manuel BenitesPerez Alati Grondona Benites & Arntsen

María Inés BrandtMarval O’Farrell & Mairal

Enrique Guillermo Bulit GoñiBulit Goñi | Lema Abogados

Gabriela Inés BurattiAbeledo Gottheil Abogados

Cynthia CalligaroDeloitte & Co See page 24

Luciano CativaFB Tax & Legal

Jorge Héctor DamarcoBertazza Nicolini Corti & Asociados

Ignacio Fernandez BorzeseFB Tax & Legal

Horacio Garcia PrietoMarval O’Farrell & Mairal

Eduardo Gil RocaPrice Waterhouse & Co

Rafael González ArzacMitrani Caballero & Ruiz Moreno

Gloria María GurbistaTeijeiro & Ballone Abogados

Liban KusaBruchou Fernández Madero & Lombardi

Guillermo LalanneEstudio O’Farrell

Santiago MontezantiEstudio Beccar Varela

Susana Camila NavarrineAsorey & Navarrine

Luis Marcelo NúñezPérez Alati Grondona Benites & Arntsen



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Argentina

Matías Olivero VilaBruchou Fernández Madero & Lombardi

Juan Marcos RougèsRosso Alba Francia & Asociados Abogados

Guillermo TeijeiroTeijeiro & Ballone Abogados

Miguel TesónEstudio O’Farrell



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Languages: Portuguese, English, SpanishBar Admissions: Brazil

BiographyFabio Pallaretti Calcini is the managing partner and head ofdepartment for federal tax (IRPJ, CSLL, PIS COFINS, CON-TRIBUIÇOES PREVIDENCIÁRIAS, ITR, IR, IPI, IOF,Imposto importação, exportação). He is based in São Paulo andhas been practicing law in Brazil since 2002.

His practice is focused on tax law (litigation, advisory, legalopinions, corporate tax, M&A, restructuring, tax consulting,international tax, audit defense and planning).

Recent matter highlights • Represented a company in the acquisition of an agribusiness

firm.• Lawyer in the representative judicial and administrative tax

litigation of the Council of Fiscal Resources of the Ministryof Finance (CARF) and judiciary.

• Lawyer in Supremo Tribunal Federal – STF – (High Court in Brazil) about most tax cases.• Drafted opinion about tax for international corporate clients.

Practice areasAudit defense, Litigation, Controversy, Tax consulting, M&A, Corporate tax, International tax

Sector specialisationsAgribusiness, Agriculture, Consumer and services, Food and beverage, Technology,Industrial, Transportation and logistics, Health, among others

Association membershipsBrazilian Bar Association (OAB), Brazilian Academy of Tax Law (ABDT), São PauloAssociation of tax Studies (APET), Brazilian Association Bar tax (ABAT), Brazilian Institutetax law (IBDT), Brazilian Association financial law (ABDF), Federal committee on tax law ofBrazilian Bar Association (OAB), Deputy legal director on Center Of Industries of State ofSao Paulo (CIESP), Brazilian Association of Democratic Constitutionalists (ABCD)

Academic qualificationsMaster’s Degree in public law from Pontificia Universidade Católica de São Paulo/PUC/SP,Doctoral Degree in public law from Pontificia Universidade Católica de São Paulo/PUC/SP, Pos Doctoral in tax law from Universidade de Coimbra – Portugal (ongoning),Specialisation degree tax law from Brazilian Institute of Tax Studies (IBET)

BRAZIL

Fabio Pallaretti Calcini

Partner

Brasil Salomão e MatthesAdvocacia

São Paulo /SP+55 11 3087 [email protected] www.brasilsalomao.com.br



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Languages: Portuguese, English

BiographyGilberto de Castro Moreira Jr is a managing partner and thehead of the tax department of LRI Advogados. He is based inSão Paulo.

Gilberto has been practicing law in São Paulo since 1990.Gilberto’s practice is focused on tax law (litigation, advisory andplanning).

Recent matter highlights• Nominated for the 5th, 6th and 7th editions of International

Tax Review’s Tax Controversy Leaders Guide (2015, 2016and 2017)

• Nominated as the 2016 and 2018 Leading Tax Advisor ofthe Year, Brazil (Acquisition International Magazine); as the2017 and 2018 Tax Planning

• Lawyer of the Year – Brazil (Finance Monthly Magazine); asthe 2018 Tax Lawyer of the year – Brazil (InternationalAdvisory Experts)

Practice areasGilberto’s practice is focused on tax law (litigation, advisory and planning)

Association membershipsHe is the coordinator of the LLM in international taxation at the Brazilian Institute of TaxLaw (IBDT), an arbitrator of the Association of European Chambers of Commerce andIndustry’s mediation and arbitration chamber (CAE), a member of tax litigation committeeof the São Paulo Bar Association, of the Brazilian Institute of Tax Law (IBDT), of the scien-tific council of the Tax Law Association of São Paulo (APET), of the InternationalAssociation of Tax Judges (IATJ) and a sitting member of the Lawyers’ Institute of São Paulo(IASP). Former councillor of the 3rd Section of the Administrative Court of Tax Appeals(CARF), former tax law professor of the Mackenzie Presbyterian University.

Academic qualificationsGilberto holds a JD degree from the University of São Paulo (USP) and a PhD degree in eco-nomics and financial law from the University of São Paulo. Giractice is folberto’s pcused ontax law (litigation, advisory and planning).

Brazil

Gilberto de Castro Moreira Jr

Managing partner and the headof the tax department of LRIAdvogados

Lautenschlager, Romeiro eIwamizu Advogados

São Paulo+55 11 2126 [email protected]



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Júlio de Oliveira has acted in many significant tax proceedingsrelating to direct and indirect taxes, as well as taxes levied on thepayroll, in addition to rendering consulting services to largedomestic and international companies. He is part of severalcommittees and associations made up of companies that seek toimprove the Brazilian tax system.

He holds a Master of Laws and a PhD in tax law fromPontifícia Universidade Católica de São Paulo (PUC/SP). He isa professor at major universities in São Paulo, such as FGV Lawand PUC/SP, and has acted as examining professor on boardsgranting Master of Laws at PUC/SP. Júlio was a judge of the TaxAdministrative Court of the State of São Paulo (TIT), and he is acounselor at the Movimento de Defesa da Advocacia (MDA).

As a result of Júlio’s life’s work, he has been recognised sev-eral times as an outstanding lawyer in the tax area in Brazil bynational and international publications and he has written sev-eral books and articles.

Brazil

Júlio de Oliveira

Machado Associados

São Paulo +55 11 3819 [email protected]



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Paulo Rogério Garcia Ribeiro has been a partner in the tax liti-gation area since 2010, working in administrative and judicialmatters. He has extensive experience in presenting oral argu-ments before all judicial courts, including superior courts andjudicial administrative bodies in a wide range of tax matters. Hisdual academic background in Law and Accounting enables himto conduct more complex and technical cases and hold a moreassertive communication with clients and judges.

Ribeiro holds a Bachelor of laws and a bachelor’s inAccounting at the Universidade de São Paulo (USP). He also par-ticipated on a leadership programme with WTS Global. Over theyears, he has been recognised by major international publications.

Brazil

Paulo Rogério Garcia Ribeiro

Machado Associados




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Specialising in tax litigation, Daniel Lacasa Maya has been han-dling judicial and administrative litigation in matters of federal,state and municipal taxes, including advising on cases before theFederal Supreme Court, presenting oral arguments before theFull Session of the Court, the Superior Court of Justice, and the1st and 2nd panels of the Court. He has also presented oralarguments before the Administrative Council of Tax Appeals(CARF) and before panels of the High Court of Tax Appeals.

He also conducts more strategic cases as a lawyer for entitiesrepresenting sectors of the economy, such as Federação dasIndústrias do Estado do Rio de Janeiro (FIRJAN), AssociaçãoBrasileira da Indústria de Higiene Pessoal, Perfumaria eCosméticos (ABIHPEC) and Associação Brasileira de Empresasde Vendas Diretas (ABEVD).

Maya started his career in tax in 1993, when he joinedMachado Associados. He graduated at FaculdadesMetropolitanas Unidas (FMU/SP) in 1998, completed hisPostgraduate Studies in Tax Law at Pontifícia Universidade Católica de São Paulo(PUC/SP), 2001 and holds a LLM in tax law at Pontifícia Universidade Católica de SãoPaulo (PUC/SP), 2007. He has been a tax litigation partner since 2005.

Brazil

Daniel Lacasa Maya

Machado Associados

São Paulo+55 11 3819 4855 (tel)+55 11 3819 5322 (fax)[email protected]



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Partner Fernando Loeser started working at Loeser Blanchet &Hadad Advogados (formerly Loeser & Portela Advogados) inNovember 1989. Initially as senior lawyer and became a manag-er in 1992, before being admitted as a partner five years later, in1997.

Member of the São Paulo, Rio de Janeiro, Brasília, Bahia andMinas Gerais chapters of the Brazilian Bar Association (OAB),and also member of several chambers of commerce in Brazil.Fernando holds a bachelor’s degree in law from the Law Schoolof PUC/SP (1991).

Fernando has more than 30 years’ experience in tax litigationand controversy resolution in the administrative and judicialcourts related to federal, state and city taxes at all levels as wellas tax consultancy services. Fernando is also experienced in cor-porate law, M&A and antitrust law.

During his career he has provided legal advice in severalM&As, spin-offs, due diligence and structuring and restructur-ing processes, as well as in the incorporation of subsidiary com-panies in Brazil, the drafting of articles of association, corporate amendments, transfer ofshares agreements and shareholder’s agreements.

Fernando has also coordinated several projects related to the review of procedures adopt-ed by national and multinational companies in compliance with Brazilian tax laws and regu-lations. He has also provided tax advice in structuring and restructuring projects carried outby national and multinational companies. His clients include companies in the construction,retail, mining and oil, and education sectors.

He writes chapters and articles in various books and journals and is a native speaker inPortuguese as well as being fluent in English and Spanish.

Recognised by the Análise Advocacia 500 magazine, 2018 edition, as one of the mostadmired tax lawyers in Brazil, the publication presents the results of research with legal direc-tors of the 1,500 largest companies in Brazil.

Brazil

Fernando Loeser

Partner

Loeser Blanchet & HadadAdvogados




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Biography Marcos Matsunaga is a tax and legal partner and leads KPMG’stax dispute resolution and controversy services in Brazil. Inaddition to his national role, Marcos is also the LATAM leaderwithin KPMG International’s Global Tax Dispute Resolution &Controversy Services network. Matsunaga joined KPMG Brazilin 1998 and has been a partner since 2008.

Association membershipsMember of the Brazilian Bar Association and an advisory boardmember of ENACTUS Brasil

Academic qualifications• Bachelor’s degree in law from Pontifícia Universidade

Católica de São Paulo – PUC/SP – 1999• Specialisation degree in tax law from Fundação Getúlio

Vargas• Master degree in tax law from Pontifícia Universidade Católica de São Paulo – PUC/SP

Recent matter highlights Marcos has represented several national and international corporate clients before the admin-istrative and judicial tax courts in Brazil, dealing with complex controversial matters. He hasa wide range of experience in tax law and different industry sectors, with a focus on advisingon the prevention and resolution of tax disputes, from the pre-dispute phase through exam-inations and appeals. Due to his international role, he has coordinated and participated in anumber of cross-border projects throughout Latin America.

Practice areas • Audit defence• Dispute resolution• Pre-litigation• Litigation• Controversy management• Tax consulting• M&A• R&D tax incentives• Corporate tax

Sector specialisations Automotive, Financial services, Industrials, Insurance, Tech and telecoms

Brazil

Marcos H. M. Matsunaga

Latin America Leader, Tax DisputeResolution & Controversy

KPMG

São Paulo+55 11 [email protected]



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Languages: Portuguese, EnglishBar admissions: OAB, CRC

BiographyDurval Portela is the managing partner of the tax and corporateconsulting area of PwC Brazil. He has 30 years of experience intax and corporate consulting services, focusing on the restruc-turing of local and international companies and on tax litigationat the administrative level.

Practice areas • Restructuring• Transactions• Corporate taxes• Litigation• Tax consulting.

Sector specialisations • Construction and materials• Consumer goods and services• Industrials• Oil and gas• Infrastructure

Association membershipsCenter for Tax Studies of São Paulo (NUPET), the Brazilian Institute of Tax Law (IBDT),the Brazilian Financial Law Association (ABDF), and the International Fiscal Association(IFA); board member of the Applied Tax Studies Group (GETAP), and leader of the TaxEfficiency Group of the American Chamber of Commerce for Brazil (AMCHAM).

Academic qualifications• Bachelor’s degree in Law at the Universidade Federal da Bahia (UFBA) in 1990• Bachelor’s degree in Accounting Sciences at Universidade do Sul de Santa Catarina

(UNISUL) in 2016• Master’s Degree in Economic Law at the Universidade Federal da Bahia (UFBA) in 1998• Specialisation in Tax Law from Pontifícia Universidade Católica de São Paulo (PUC-SP)

in 2009

Brazil

Durval Portela

Managing partner of the tax andcorporate consulting area

PwC

São Paulo+55 11 [email protected]



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Languages: Portuguese, EnglishBar admissions: Brazillian Bar Association

BiographyMarcos has an extensive experience in tax litigation and tax con-sultancy (direct and indirect taxation), participation in due dili-gence and legal advice rendered to departments of foreign tradeand logistics of import/export companies.

Recent matter highlights• Acted on lawsuits against tax assessments aimed at the collec-

tion of taxes charged over payments abroad related to theacquisition of software and services. These cases involved dis-putes among federal, state and municipal tax authorities.

• Acted on behalf of a client against a tax assessment by federaltax authorities challenging the use of foreign losses to reduceprofits of foreign subsidiaries subject to tax in Brazil. Thecase involved a subject matter that is highly controversial atthe administrative courts.

• Acted on behalf of a large multinational to produce court-friendly evidence to support theunlawfulness of the position of the tax authorities on a relevant transfer pricing matter.

Practice areasCorporate taxes, Tax consulting, Tax controversy, VAT (Value-Added Tax), Customs

Sector specialisationsAgriculture, Automotive, Consumer goods and services, Industrials, Tech and telecoms

Association memberships• Comitê tributário – Centro de Estudos das Sociedades de Advogados – CESA • Instituto Brasileiro de Direito Tributário – IBDT• Comitê tributário – Ordem dos Advogados do Brasil

Academic qualifications• Law degree, Faculdades Metropolitanas Unidas (FMU), 1996• LLM in Capital Markets, Instituto Brasileiro de Mercado de Capitais (IBMEC), 2005

Brazil

Marcos Carvalho

Partner

Lefosse Advogados

São Paulo+55 11 3024 [email protected] www.lefosse.com



AMERICAS

Languages: English, French

BiographyValter Lobato is a senior partner at Sacha Calmon Misabel DerziConsultores & Advogados and is responsible for the administra-tive and financial management of the firm. He has a strong trackrecord in his representation of clients in administrative and judi-cial courts as well as a solid tax consulting practice. Valter hasconsiderable expertise in the steel and mining sectors.

Valter Lobato studied at the Federal University of MinasGerais (UFMG), where he gained a degree in law (receiving theBarão do Rio Branco Prize for being the best graduating stu-dent) in 1993, a master’s degree in law 10 years later and a doc-torate in law in 2014. He teaches at Milton Campos Law Schoolin both the undergraduate and graduate programmes and is thecoordinator of the school’s taxation LLM.

He is the president of the Brazilian Association of Tax Law(ABRADT) and chairman of the board of tax affairs of theMinas Gerais Trade Federation (FECOMERCIO). He is also a counsellor for the BrazilianBar Association (OAB) in Minas Gerais and represents the OAB at the standing committeefor the review and simplification of the Minas Gerais tax regime. He has published numerousarticles in books and national journals. He has acted as a dissertation adviser at renownededucational institutions and is frequently invited to give lectures in conferences and seminarsof international prominence.

Since 2013 he has been highly regarded and ranked by Chambers Latin America,Chambers Global and the Brazilian legal directory Análise Advocacia. He has also been rec-ommended by LACCA since 2014.

Academic qualificationsGraduated in Law, Universidade Federal de Minas Gerais (UFMG), 1993; Master’s Degreein Tax Law, Universidade Federal de Minas Gerais (UFMG), 2004; PhD in Tax Law,Universidade Federal de Minas Gerais (UFMG), 2014; Best student award, UniversidadeFederal de Minas Gerais (UFMG), 1993; Best student in Civil Law, Universidade Federal deMinas Gerais (UFMG), 1993; Nominated for the award of best student in Civil and CriminalProcedure, Universidade Federal de Minas Gerais (UFMG), 1993; Leading Tax Lawyer inBrazil, indicated by the British publications Chambers and Partners Latin America 2013-2016, Chambers Global 2013-2016; Considered one of the most admired Tax Lawyers inBrazil, according to the Análise Advocacia’s annual ranking: 2013, 2014 and 2015; LeadingTax Lawyer in Latin America, indicated by The Latin American Corporate CounselAssociation – LACCA: 2014, 2015, 2016 and 2017; Santos Dumont Medal, Government ofthe State of Minas Gerais (2018).

Brazil

Valter de Souza Lobato

Senior Partner

Sacha Calmon Misabel DerziConsultores & Advogados

Belo Horizonte+55 31 3289 [email protected]



AMERICAS

Languages: English, PortugueseBar admissions: Brazil

Biography Marcos Joaquim Gonçalves Alves is a founding partner at MJAlves e Burle Advogados e Consultores (MJAB), the firstBrazilian law firm specialised in advocacy.

Marcos Joaquim has developed a solid career in the past 20years by representing clients before the Brazilian High Courts,handling complex public law cases involving tax and administra-tive laws in particular. He has been successfully practicing advo-cacy for the past 10 years and has dealt with a broad range ofmatters, from fiscal and regulatory issues to agribusiness andsports law. Marcos Joaquim is a regular speaker at tax confer-ences, a former professor of tax law and the author of severalarticles, chapters and books.

Recent matter highlights• Represented a refinery company in a R$2 Billion matter regarding the taxation of the

international acquisition of Oil.• Represented a refinery company in a R$574 Million matter regarding the previous pay-

ment of the indirect tax system.• Represented a renewable energy company on the solution of 22 years of litigation with

the Brazilian Tax Authorities and approximately 300 judicial procedures.

Practice areas Corporate taxes, Dispute resolution, Litigation, Controversy management, Tax consulting

Sector specialisations Construction and materials, Financial services, Food and beverage, Government and publicpolicy, Oil and gas

Association membershipsFounding member of the Tax Research Institute; Vice President of the Special Commissionfor Oil and Gas Law of the Brazilian Bar Association; Advisor to the Special Committee forTax Law of the Brazilian Bar Association; Member of the Steering Committee ofGovernment Relations of CESA (Brazilian Law Firm Think Tank).

Academic qualifications • Bachelor of Laws, Pontifícia Universidade Católica de São Paulo;• Specialisation in Administrative and Tax Law, Pontifícia Universidade Católica de São Paulo

Brazil

Marcos Joaquim Gonçalves Alves

Founding partner

MJ Alves e Burle

Brasília+55 61 [email protected]



AMERICAS

Languages: Portuguese, English, Spanish

BiographyFabio worked as a lawyer at Petrobras, 7th place in the entryexamination competition. He is the author of several articlespublished in specialised reviews and a speaker at events in Braziland abroad. He received the Sacha Calmon Award for the bestthesis at the VIII Congress of Tax Law.

Practice areas• Business Model Optimisation• Restructuring• Cost-sharing Arrangements• Litigation• Tax Consulting

Sector specialisations• Energy• Food and Beverage• Industrials• Oil and Gas• Tech and Telecoms

Association memberships• Director of the Tax Debates Group of Rio de Janeiro (GDT-RIO)• Director of the Brazilian Financial Law Association (ABDF)• Member of the Practice Council of the LLM in International Taxation Program of New

York University (NYU)• Professor of the LLM in Tax Law at the Getúlio Vargas Foundation (FGV)

Academic qualifications• Degree in Law, Pontifical Catholic University of Rio de Janeiro, 2003• Postgraduate degree in Tax Law, University of Salamanca, 2005• Postgraduate degree in Gas and Oil, Brazilian Oil Institute, Center of Advanced Studies

and Oil Research from the University of the State of Rio de Janeiro (UERJ) and from theCampos School of Law, 2005

• PhD Candidate, Autonomous University of Lisbon

Brazil

Fábio Fraga

Partner

Trouw & Fraga Advogados

Rio de Janeiro+55 21 2504 [email protected]



AMERICAS

Languages: Portuguese, EnglishBar admissions: Brazilian Bar Association

Biography Gustavo Haddad has extensive experience as trusted advisor oflocal and international clients on their investments in theBrazilian market. His experience includes tax consulting and taxlitigation on high-profile cases. He is a professor at Insper, a for-mer member of the administrative tax court (CARF) and one ofthe ten leading tax lawyers in Brazil according to the Legal 500.

Recent matter highlights• Acted on a judicial action against a tax assessment aimed at

the collection of a federal tax charged over payments remit-ted abroad related to the acquisition of standard software thecompany resells in Brazil.

• Acted on behalf of a large multinational to produce a court-friendly evidence to support the unlawfulness of the positionof the tax authorities on a relevant transfer pricing matter.

• Acted on behalf of a giant technology company to challenge the application of state taxon online advertising.

Practice areasCorporate taxes, Tax consulting, Tax controversy, International tax advisory, Wealth planning.

Sector specialisationsTechnology, Financial services, Agriculture, Food and beverage, Consumer goods and services.

Association memberships• Instituto Brasileiro de Direito Tributário (IBDT)• International Bar Association• Comissão das Sociedades de Advogados - Ordem dos Advogados do Brasil

Academic qualifications• Bachelor’s degree in Law, USP – Universidade de São Paulo, 1995• Post-graduated in Constitucional Law, Escola Superior de Direito Constitucional, 2007

Brazil

Gustavo Haddad

Partner, head of tax

Lefosse Advogados




AMERICAS

Languages: English, Spanish, Dutch, Portuguese

BiographyErnesto previously worked as a lawyer/partner in the law firmBichara Barata Costa & Rocha Advogados, being responsiblefor the tax area. He is the author of several articles published inspecialised reviews and a speaker at events in Brazil and abroad.

Practice areas• Business Model Optimisation• Restructuring• Cost-sharing Arrangements• Litigation• Tax Consulting

Sector specialisations• Energy• Media• Industrials• Oil and Gas• Tech and Telecoms

Association memberships• Director of the Tax Debates Group of Rio de Janeiro (GDT-RIO)• Director of the Brazilian Financial Law Association (ABDF)• Director of Entrepreneurs’ Organization (EO Rio de Janeiro)• Director of the Dutch Brazil Chamber of Commerce (Dutcham)

Academic qualifications• Degree in Law, Federal University of Rio de Janeiro, 2002• Postgraduate degree in Tax Law, Brazilian Institute of Tax Studies (IBET), 2004• Postgraduate degree in Tax Law, University of Salamanca, 2005• PhD Candidate, Autonomous University of Lisbon

Brazil

Ernesto Trouw

Partner

Trouw & Fraga Advogados

Rio de Janeiro+5521 2504 [email protected]



Brazil

Ernesto Johannes TrouwTrouw & Fraga Advogados See page 44

Pedro Guilherme Accorsi LunardelliAdvocacia Lunardelli

Marcel Alcades TheodoroMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Marcos Joaquim Gonçalves AlvesMJ Alves & Burle Advogados & Consultores See page 41

Antonio AmendolaDias Carneiro Advogados

Sergio André RochaSergio André Rocha

Marcelo Salles AnnunziataDemarest Advogados

Carlos Henrique Tranjan BecharaPinheiro Neto Advogados

Daniel Vitor BellanLacaz Martins Pereira Neto Gurevich & Schoueri Advogados

João Francisco BiancoMariz de Oliveira & Siqueira Campos Advogados

Luiz Gustavo BicharaBichara Advogados

José Luis Ribeiro BrazunaBrazuna Ruschmann & Soriano Sociedade de Advogados

Alberto Martins BrentanoSilveiro Advogados

Gustavo BrigagãoBrigagão Duque Estrada Advogados

Isabel BuenoMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Mauricio de Carvalho Silveira BuenoHuck Otranto Camargo

Fabio Pallaretti CalciniBrasil Salomão and Matthes Advocacia See page 31

Marcos de CarvalhoLefosse Advogados See page 39

Vivian Casanova de Carvalho EskenaziBarbosa Müssnich Aragão

AMERICAS



Brazil

Oscar Sant’Anna de Freitas e CastroDaudt Casto & Gallotti Olinto Advogados

Marcos André Vinhas CatãoVinhas & Redenschi Advogados

Guilherme CezarotiCampos Mello Advogados

Christiano Chagas Monteiro de MeloDemarest Advogados

Tércio ChiavassaPinheiro Neto Advogados

Renata Correia CubasMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Guilherme de Almeida HenriquesHenriques Advogados

Júlio de OliveiraMachado Associados Advogados & Consultores See page 33

Karem Jureidini DiasRivitti & Dias

Hamilton Dias de SouzaDias de Souza Advogados Associados

Daniela Alves Portugal Duque EstradaCastro Barros Sobral Gomes Advogados

Roberto Duque EstradaBrigagão Duque Estrada Advogados

Wolmar Francisco Amélio EstevesBichara Advogados

Mauricio Pereira FaroBarbosa Müssnich Aragão

Gilberto FragaFraga Bekierman & Cristiano Advogados

Mario Junqueira Franco JúniorMartins Franco Teixeira

Maucir Fregonesi JúniorSiqueira Castro Advogados

Hugo FunaroDias de Souza Advogados Associados

Francisco Carlos Rosas GiardinaBichara Advogados

AMERICAS



Brazil

Alessandra GomensoroMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Luis Augusto da Silva GomesViseu Advogados

André Gomes de OliveiraCastro Barros Sobral Gomes Advogados

Antonio Carlos Guimarães GonçalvesDemarest Advogados

Celso GrisiTauil & Chequer Advogados

Antonio Carlos Guidoni FilhoVella Pugliese Buosi & Guidoni Advogados

Gustavo Lian HaddadLefosse Advogados See page 43

Fernanda Guimarães HernandezFernanda Hernandez Advocacia

Carlos IaciaCarlos Iacia Advocacia

Anna Flávia de Azevedo Izelli GrecoFelsberg & Associados

Leonardo KrakowiakAdvocacia Krakowiak

Ricardo KrakowiakAdvocacia Krakowiak

Glaucia Maria Lauletta FrascinoMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Valter de Souza LobatoSacha Calmon Misabel Derzi Consultores & Advogados See page 40

Fernando LoeserLoeser Blanchet & Hadad See page 36

Ana Paula Schincariol Lui BarretoMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Sandro Machado dos ReisBichara Advogados

João MaiaVeirano Advogados

Claudia Liguori Affonso MalufDemarest Advogados

AMERICAS



Brazil

Gabriel Manica Mendes de SenaCastro Barros Sobral Gomes Advogados

João Marcos ColussiMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Ana Luiza MartinsTauil & Chequer Advogados

Leonardo MartinsMachado Meyer Sendacz & Opice Advogados

Marcos MatsunagaFerraz de Camargo & Matsunaga See page 37

Daniel Lacasa MayaMachado Associados Advogados & Consultores See page 35

Enzo MegozziSevero Vaz Ferreira de Moura Olympio & Megozzi Advogados

Marcos Minichillo de AraújoAlmeida & Associados

Rogerio MollicaMollica & Rapozo Advogados

Oswaldo Leite de Moraes FilhoDemarest Advogados

Gilberto de Castro Moreira JrLautenschlager Romeiro & Iwamizu Advogados See page 32

Cláudio MorettiTrench Rossi Watanabe

Marcos Vinícius Neder de LimaTrench Rossi Watanabe

Raquel NovaisMachado Meyer Sendacz & Opice Advogados

Ricardo Mariz de OliveiraMariz de Oliveira & Siqueira Campos Advogados

Carlos Eduardo Marino OrsolonDemarest Advogados

Alvaro PereiraPwC

Luiz Roberto Peroba BarbosaPinheiro Neto Advogados

Durval PortelaPwC See page 38

AMERICAS



Brazil

Marcos Vinícius Passarelli PradoStocche Forbes Advogados

Roberto Quiroga MosqueraMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Lígia Regini da SilveiraBarbosa Müssnich Aragão

Paulo Rogério Garcia RibeiroMachado Associados Advogados & Consultores See page 34

Eduardo RoccaRocca Stahl Zveibil & Marquesi Advogados

Cristiano Frederico RuschmannBrazuna Ruschmann & Soriano Sociedade de Advogados

Andrea da Rocha SalviattiMundie Advogados

Luiza Sampaio de Lacerda BenjóBarbosa Müssnich Aragão

Daniel Souza Santiago da SilvaNeves & Battendieri Advogados

Paulo Rogério SehnTrench Rossi Watanabe

Gabriela Silva de LemosMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

Marcelo Bez Debatin da SilveiraLobo de Rizzo Advogados

Pedro Teixeira de SiqueiraBichara Advogados

Ciro César Soriano de OliveiraBrazuna Ruschmann & Soriano Sociedade de Advogados

Kátia Soriano de Oliveira MiharaBrazuna Ruschmann & Soriano Sociedade de Advogados

Ivan TauilTauil & Chequer Advogados

Paulo Camargo TedescoMattos Filho Veiga Filho Marrey Jr & Quiroga Advogados

André TeixeiraAndre Teixeira & Associados

Eduardo Maccari TellesTauil & Chequer Advogados

AMERICAS



AMERICAS

Brazil

Mariana Neves de VitoTrench Rossi Watanabe

Daniella ZagariMachado Meyer Sendacz & Opice Advogados



AMERICAS

BiographyTimothy is a partner in PwC Law’s Toronto office. His practicefocuses on tax dispute resolution and litigation. He also advisescharities and not-for-profits on tax and compliance matters.

Practice areasCorporate taxes, Audit defence, Audit support, Dispute resolution

Sector specialisationsConstruction and materials, Financial services, Mining, Oil andgas, Real estate

Association membershipsCanadian Tax FoundationOntario Bar Association

Academic qualificationsLLB, Osgoode Hall Law School, 2005MA, New York University, 2001BA (Hons.), McGill University, 1999

CANADA

Timothy Fitzsimmons

Partner

PwC Law LLP

Toronto+1 416 687 [email protected]://www.pwc.com/ca/en/contacts/pwc-law-llp/timothy-fitzsimmons.html



AMERICAS

Biography Paul has more than 34 years of tax experience, 18 years of whichwere at the Canada Revenue Agency. He knows and under-stands the best method ways to manage and present a tax casefor an effective resolution with the tax authorities.

Association membershipsCPA (1987), Canadian Tax Foundation

Academic qualificationsB Comm, University of Ottawa, 1985

Recent matter highlights • Favourable outcomes achieved at the notice of objection

stage to resolve complex disputes involving over $100 mil-lion of tax

• Negotiating audit agreements at the conclusion of audits toachieve certainty and avoid penalties

• Creative, non-linear solutions to effectively challenge tax authority discretionary decisions

Practice areas • Corporate taxes• Audit defence• Audit support• Dispute resolution• Litigation

Sector specialisations • Accounting• Automotive• Consumer goods and services• Financial services• Food and beverage

Canada

Paul Lynch

Partner, National Leader, TaxLitigation & Dispute ResolutionKPMG LLP

Toronto+1 416 777 [email protected]



AMERICAS

Languages: English

BiographyAndrew is a transfer pricing partner with PwC’s Toronto office.He has been with the firm for over 30 years, and has been a partnersince 1997. He began his career in transfer pricing in PwC’s NewYork office in 1994, assisting companies in complying with the firstUS contemporaneous documentation requirements and now spe-cialises in transfer pricing controversy and dispute resolution.

His extensive cross-border experience includes prospectivestudies for planning purposes, income tax audit defence, con-temporaneous documentation engagements, CompetentAuthority assistance, and Advance Pricing Agreements(“APAs”). He has helped clients in obtaining unilateral and bilat-eral APAs in a variety of industries, including mining, manufac-turing, automotive, entertainment, retail, and software, in coun-tries including the United States, United Kingdom, Germany,Australia, and most recently India.

Andrew is a CPA and a Chartered Business Valuator (“CBV”). As a CBV, Andrew bringsa wealth of valuation experience to international restructuring, cost sharing, and intellectualproperty migration assignments.

The Euromoney Guide to the World’s Leading Transfer Pricing Advisers has featuredAndrew since 2003, and in 2011 he was voted one of the “Best of the Best”, a ranking of thetop 5 advisers in Canada.

As a leader in the field, Andrew speaks regularly on transfer pricing and business valuationtopics for a number of professional organisations. He has also written articles for CAMagazine, the Canadian Tax Foundation, the Journal of Business Valuation, and TaxPlanning International Review. He has co-authored “The Dilemma of GlaxoSmithKline:Unreasonable in the Circumstances?” and “Transfer Pricing: A Critique of the CRA’sPosition on Range Issues”, both published by the Canadian Tax Foundation.

Academic QualificationsCPA, CBV

Practice areasAPAs, Dispute resolution, Transfer pricing

Sector expertiseAutomotive, Mining, Manufacturing, Entertainment, Retail and software

Canada

Andrew McCrodan

Partner

PwC

+1 416 869 [email protected]/ca



AMERICAS

Languages: EnglishBar admissions: Ontario

BiographyDavid W. Chodikoff, Certified Specialist (Taxation), LSO, B.A.(Spec. Hons.), M.A., LL.B., specializes in civil and criminal taxlitigation and is the national leader of the tax disputes resolutiongroup at Miller Thomson LLP. David was a former counsel anda Crown Prosecutor at the Department of Justice. He has over100 reported decisions. David has appeared in over 565 casesbefore the courts. David has been recognized by Canadian,American and European authorities as one of the leading taxcontroversy leaders in the world. He has edited and contributedto nine tax books. David is the recipient of numerous nationaland international awards.

Recent matter highlights• Akanda Innovation Inc. v. The Queen, 2018 FCA 200

Practice areasDispute resolution, audit defence, audit support, MAPs/ADRs, controversy management,corporate taxes, international tax advisory, GST, cryptocurrency and customs.

Sector specialisationsTax litigation, taxation, financial services, accounting, real estate, tech and telecoms, pharmaand life sciences, investment management and gaming.

Association membershipsAdvocate’s Society, American Bar Association (Section of Taxation and Senior LawyersDivision), Association for Corporate Growth, Ontario Bar Association, Canadian BarAssociation, Canadian Tax Foundation, International Bar Association, International FiscalAssociation, The Law Society of Ontario, Toronto Lawyers Association.

Academic qualificationsCalled to the Ontario Bar, LL.B., Dalhousie University, M.A., Dalhousie University, B.A.,(Specialized Honours), York University.

Canada

David W. Chodikoff

Certified Specialist (Taxation),(L.S.O.), Partner, Leader, TaxLitigation

Miller Thomson LLP

Toronto+1 416 595 [email protected]/welcome-bienvenue



Canada

François BaretteFasken Martineau DuMoulin

Neil BassAird & Berlis

Dominic BelleyNorton Rose Fulbright

Jacques BernierBaker McKenzie

Patrick BilodeauDeloitte See page 24

Monica BiringerOsler Hoskin & Harcourt

Nathan BoidmanDavies Ward Phillips & Vineberg

Michel BourqueKPMG

Wendy BrousseauMcCarthy Tétrault

Alexandra BrownBlake Cassels & Graydon

Michael BussmannGowling WLG

Maurice Chiasson QCStewart McKelvey

David ChodikoffMiller Thomson See page 54

Chia-yi ChuaMcCarthy Tétrault

Nicolas CloutierMcCarthy Tétrault

Louis-Frédérick CôtéSpiegel Sohmer

Carrie D’EliaOsler Hoskin & Harcourt

Guy Du PontDavies Ward Phillips & Vineberg

Kristen DuerhammerKPMG

AMERICAS



Canada

Timothy FitzsimmonsPwC See page 51

Olivier FournierDeloitte See page 24

Étienne GadboisGadbois Commodity Tax Law

Richard GarlandDeloitte See page 24

Cheryl Gibson QCDentons

Laurie GoldbachBorden Ladner Gervais

Nathalie GoyetteDavies Ward Phillips & Vineberg

Gerald GrenonOsler Hoskin & Harcourt

Geoff HallMcCarthy Tétrault

Jehad HaymourBennett Jones

Amanda HealeOsler Hoskin & Harcourt

David KempBaker Tilly Canada

Andrew KingisseppOsler Hoskin & Harcourt

Norma KraayDeloitte See page 24

Edwin Kroft QCBennett Jones

Justin KutyanKPMG

Wilfrid LefebvreNorton Rose Fulbright

Patrick LindsayPwC

Paul LynchKPMG See page 52

AMERICAS



Canada

Martha MacDonaldTorys

Peter MacdonaldOsler Hoskin & Harcourt

Bill MaclaganBlake Cassels & Graydon

Jenny MboutsiadisFasken Martineau DuMoulin

Janice McCartBlake Cassels & Graydon

Andrew McCrodanPwC See page 53

Carman R McNary, QCDentons

Al MeghjiOsler Hoskin & Harcourt

Pooja MihailovichOsler Hoskin & Harcourt

Warren Mitchell QCThorsteinssons

David MuhaDeloitte See page 24

Al-Nawaz NanjiOsler Hoskin & Harcourt

Markus NavikenasDeloitte See page 24

Joel NitikmanDentons

Stevan NovoselacGowling WLG

Rob O’ConnorDeloitte See page 24

Yves OuelletteGowling WLG

Jean-François PerreaultFasken Martineau DuMoulin

Christine RamsayDeloitte See page 24

AMERICAS



Canada

Sébastien RheaultBarsalou Lawson Rheault

David RobertsonEY

Edward RoweOsler Hoskin & Harcourt

Daniel SandlerEY

Alan SchwartzFasken Martineau DuMoulin

Jeffrey ShaferBlake Cassels & Graydon

Nicolas SimardFasken Martineau DuMoulin

Ken Skingle QCFelesky Flynn

Christopher SladeDeloitte See page 24

John SorensenGowling WLG

Yves St CyrDentons

Joe StarninoStarnino Mostovac

Craig SturrockThorsteinssons

Paul TamakiBlake Cassels & Graydon

Louis TasséEY

Roger TaylorEY

Deborah ToazeBennett Jones

Mark TonkovichBlake Cassels & Graydon

Marc VanassePwC

AMERICAS



Canada

Joanne VandaleOsler Hoskin & Harcourt

Scott WilkieBlake Cassels & Graydon

Matthew WilliamsThorsteinssons

John YuanMcCarthy Tétrault

AMERICAS



AMERICAS

Languages: Spanish and English.

Practice focuses on advising domestic and foreign clients on per-sonal and corporate tax planning, local and international taxconsulting, M&A, public offering of securities and foreigninvestment transactions. Significant experience in tax litigationbefore the Internal Revenue Service, Tax Courts, SupremeCourt and the Constitutional Court.

Previous experiencePartner at Dentons Chile, 2019 -Partner at Orellana & Hurtado Abogados, 2013-2018.Tax partner at Cariola, Diez Pérez Cotapos, 2000-2013.

Academic qualificationsUniversity of Chile, Master in Tax Law (LLM), 2001Universidad Diego Portales, School of Law, (LLB), 1995

Academic activitiesProfessor of Master in Tax Law, Universidad Los Andes (2009 – 2018)Professor of Master in Tax Law, Universidad Adolfo Ibañez 2018Course to update tax judges (Law 20.780 and 20.899), Universidad de Chile, Centro deEstudios Tributarios (2017 and 2018)Academic Director of Master in Tax Law Universidad Adolfo Ibañez and Universidad Los Andes.

Awards and RecognitionsOutstanding Lawyer in Tax, Chambers and Partners Latin America, 2015-2019.Outstanding Lawyer in Best lawyers, 2017 – 2019.Tax Deal of the Year 2013 International Tax Review.

PublicationsCo-author of: Tax treatment of mining in Chile, Thomson Reuters, 2014, Legal PublishingChile.Is there a permanent establishment, Cahiers de Droit Fiscal, International Fiscal Association,2009.The concept of permanent establishment, Universidad Adolfo Ibañez, Revista Derecho de laEmpresa, April 2007.

Association membershipsChilean Bar Association

CHILE

Juan Pablo Orellana Pavón

Partner

Dentons

Santiago+56 2 2411 [email protected]



Chile

Christian AsteVillarroel Lecaros Aste & Baraona

Jaime CareyCarey

Felipe Dominguez CelisPwC

Roberto EdwardsEdwards & Cía

Oscar Ferrari GarcíaGarrigues

Pablo González SuauSapag & González Abogados

Antonio Guzmán RiberaEY

Francisco Hurtado SotomayorDentons

David LagosSole practitioner

Francisco LyonKPMG

Juan Pablo OrellanaDentons See page 60

Jessica PowerCarey

Sergio SapagSapag & González Abogados

Gonzalo Schmidt GablerPwC

Luis SeguelKPMG

Mario Silva PobletePhilippi Prietocarrizosa Ferrero DU & Uría

Francisco Valdivia VillagránAlcalde & Cía Abogados

Adriana ZaidanUlloa & Cia

AMERICAS



AMERICAS

Languages: Spanish, English and FrenchBar admissions: Colombia

BiographySpecialised in the resolution of disputes related to nationaltaxes, local taxes, international tax law, community law (CANDecision 578), transfer pricing, customs, indirect taxation andforeign exchange controversies. Member of the Firm since2017. Professor of Tax Law Specialisations programmes atUniversidad Externado de Colombia and Universidad Javeriana.

Recent matter highlights• Has led and implemented successful litigation strategies for

national and multinational companies• Lead a dispute for a consumer goods company (Pepsico)

related to transfer pricing adjustments that have been closedby the tax authority (approx. $15 million)

• Lead a dispute of an oil and gas company (Gran Tierra) relat-ed to expenses of abandoned wells that tax administrationrejected as deductible expense. DIAN accepted the argu-ments presented by PwC and close the investigation (approx. $19 million)

• Lead a dispute of an oil and gas Company (Perenco) (approx. $3-5 million)

Practice areasLocal taxes, international tax law, community law, transfer pricing, customs and exchangeregime dispute resolution before tax authorities and jurisdiction.

Sector specialisationsOil and gas, Healthcare, Consumer goods and Agribusiness.

Association membershipsColombian Institute of Tax Law – ICDT

Academic qualificationsLawyer – JD (2006) Universidad Externado de ColombiaPostgraduate studies: Tax Law (2008) Universidad Externado de ColombiaPostgraduate studies: International Tax Law (2014) Universidad Externado de Colombia

COLOMBIA

Javier Blel Bitar

Director of the tax litigation anddispute resolution department

PricewaterhouseCoopersSLT

Bogotá +57 – 1- 6340555 ext. [email protected]/co



AMERICAS

Languages: Spanish and English

BiographyGraduated as a lawyer from Colegio Mayor de Nuestra Señoradel Rosario (1986), specialised in Taxation from Universidad deLos Andes (1988), in Companies Law (1991), and inCommercial Law (1993) from Pontificia Universidad Javeriana.He took postgraduate courses in International Tax Law (2004),and in Constitutional Law (2009) at Universidad de Salamanca.Founder and Director of the Tax Law Specialization, inPontificia Universidad Javeriana. Former president and hon-orary member of the Colombian Institute of Tax Law.

Recent matter highlights• Trustee advisor, transfer pricing and change consultant, and

litigation for a group of fashion companies (Texmoda). Thiscompany has companies such as Zara Pull & Bear, MassimoDutti, among others.

• Trustee advisor, tax controversy advisor and permanent taxand litigation advisor for all General Electric group.

Sector specialisations Transfer pricing, international taxation

Association membershipsFormer president and honorary member of the Colombian Institute of Tax Law

Academic qualificationsCo-author of Estatuto Tributario PwC ed. 2016, 17, 18, 19.

Colombia

Carlos Mario Lafaurie

Partner


Bogotá+57 1 6340555 ext. [email protected]/co/



AMERICAS

Languages: Spanish and English

BiographyNacira Lamprea is the leader of the PwC Tax and Legal Servicesdepartments in the Bogotá, Barranquilla and Medellin offices. Heis also the leader of the litigation and tax processes team. He hasadvised various clients on Tax Compliance and Tax Managementsissues and has been a member of the firm since 1991.

Nacira has taught a course on Advanced Taxation in both thePontificia Javeriana University, Bogotá and the Chamber ofCommerce, Bogotá and is a Former Postgraduate Lecturer atthe University of Medellín.

He has been a speaker at conferences organised by the ACEF(Association of Financial Executives) on matters such as changesin the tax statutes and corporate tax issues at the end of the year.He has also been a speaker at the ANDI, FENALCO TaxChamber and other Binational Chambers of Commerce and isa Member of the Colombian Institute of Tax Law.

Recent matter highlights• Nacir recently led important projects on tax management and the outsourcing of compa-

nies’ tax functions, in particular for companies in the pharmaceutical, aeronautical andretail sectors. He has advised many domestic and international companies on importantmatters related to income, sales and industry and commerce taxes, as well as providingadvice and assistance on tax withholding issues. He also advises on tax planning. He hasconsiderable experience in the development, management and leadership of tax litigationand tax processes at both governmental and jurisdictional levels.

• He is a tax advisor for litigation and tax outsourcing for a pharmaceutical multinational(Pfzier).

• He provides tax advisory services and tax management for another multinational pharma-ceutical company (Basf Química).

Practice areas• International taxation• Tax controversy• Tax management

Sector specialisations• Pharmaceutical• Retail and commerce• Health

Colombia

Nacira Lamprea Okamel

Partner


Bogotá+57 1 6340555 ext. [email protected]/co



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Catalina Hoyos is a well-known and experienced tax lawyer withmore than 18 years of experience in international and local taxlaw. As the partner in charge of tax services, she leads the tax lit-igation, transfer pricing, tax planning, tax consultancy and taxcompliance lines of practice of the firm. She has been thePresident of the Colombian Institute of Tax Law, a member ofthe board of Directors of IFA Colombia and an HonoraryMember of the Colombian Institute of Tax Law. She is a mem-ber of the list of arbitrators of the Chamber of Commerce ofBogotá and of TRIBUTE.

Based in Bogota, Catalina works with local and multinationalcompanies. As a sharp, skilled, versatile tax lawyer she handles awide array of difficult cases ranging from the design and revisionof fiscal policies to implementing complex tax structures. Herareas of practice include digital economy, financial markets, taxlitigation, insurance and reinsurance and transfer pricing mat-ters, among others. Clients know they can rely on Catalina forany complex issues they may have to deal with.

Catalina is very well known in the academic world as well, where she has been teachingand doing research for more than 18 years. Author of many papers and books, she is muchrespected in matters of international and local tax law. She is a PhD candidate at theUniversidad de Salamanca. She has attended the Comparative Tax Policy and Administrationprogramme at Harvard Kennedy School, the MIT Blockchain Program, and the OxfordFintech Programme from the Saïd Business School, University of Oxford, among others.

Colombia

Catalina Hoyos Jimenez

Godoy & Hoyos Abogados

Cra 14 94-44 Torre B Pisos 2 y 6BogotáColombia+57 (1) [email protected]



Colombia

Mario Andrade-PerillaDeloitte See page 25

David Bedoya GoyesBedoya Goyes Abogados

Javier Blel BitarPwC See page 62

César CermeñoGarrigues

Camilo CortésDentons Cardenas & Cardenas

Lucy Cruz de QuiñonesQuiñones Cruz Abogados

Catalina Hoyos JimenézGodoy & Hoyos Abogados See page 65

Catalina Jaramillo HernándezBrigard & Urrutia Abogados

Carlos LafauriePwC See page 63

Nacira LampreaPwC See page 64

Camilo RodriguezKPMG

Margarita SalasEY

Vicente Javier TorresKPMG

Juan Carlos Vinasco EscarriaBaker McKenzie

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COSTA RICA

Luis ChacónBLP

Rafael González SaboríoGrant Thornton Costa Rica

Mario Hidalgo-MatlockGrant Thornton

Anabelle León FeoliDeloitte See page 25

Alan SaborioDeloitte See page 25

CURAÇAO

Xandra Kleine-van DijkTax-Insight

DOMINICAN REPUBLIC

David InfanteDeloitte See page 25

ECUADOR

Pablo AguirrePwC

GUATEMALA

Olga María MeléndezConsortium Legal

HONDURAS

Rita María SilvaDeloitte Honduras See page 25

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Luis Carbajo Martínez has been the head partner of BakerMcKenzie’s Mexican tax practice group for the last three years.He is currently located in Mexico City, where he advises multina-tionals on international tax planning, M&A, cross-border transac-tions and other business issues. He is a member of the Firm’sLatin America regional tax steering committee, and an adviser tothe tax committee of the National Maquiladora Council.

Luis frequently authors tax articles in Tax NotesInternational and the Practical Mexican Tax Strategies maga-zine. He also speaks at various seminars organized by the IFA,CANIETI, CANACINTRA, Tax Executives Institute,Executive Enterprise Institute, Cámara de Comercio de Bogotáand the local Maquiladora Associations across Mexico. He is aformer member of the Management Committee of the CiudadJuárez office of the Firm.

Practice focusLuis Carbajo focuses his practice on litigating and lobbying highlycomplex issues in the energy sector. He has extensive experience advising on permanent estab-lishment issues, inter-company pricing, taxation of non-resident entities and individuals andother corporate and tax matters. These include VAT, assets tax, planning and litigation on socialsecurity contributions and local and municipal taxes. His practice also covers tax planning andtransfer pricing, particularly in the energy sector.

MEXICO

Luis Carbajo Martínez

Partner, tax

Baker McKenzie

Mexico City+52 55 5351 [email protected]



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Fernando is a tax and legal and tax controversy practice partner.He has more than 25 years of experience in national and inter-national taxes for private and public companies.

Under his responsibilities, he negotiated several mutualagreement (MAPs) procedures under tax treaties (i.e. the MAPthat included the LLCs as beneficiaries under the US-Mexicotax treaty). He also served as a delegate for Mexico in theOECD’s Tax Treaties and Related Matters working group,where he drafted paragraphs that were included in theCommentaries on the Articles of the Model Tax ConventionOECD Model Tax Convention Commentaries.

Fernando has vast experience in both consultancy servicesand tax litigation on international taxes and transfer pricingmatters. Moreover, he has been engaged in important projectsthat have successfully resolved international disputes in differentindustries through tax audits, MAPs and BAPAs betweenMexican Competent Authority and the competent authoritiesof different jurisdictions.

He also has published different articles including those pub-lished by the International Tax Review and the International Tax Journal.

He is member of the Barra Mexicana Colegio de Abogados, the American Chamber ofCommerce and the International Fiscal Association (IFA).

Fernando graduated as a lawyer from the Escuela Libre de Derecho and has a Master’sDegree on taxes and international commerce from the University of Warwick in the UnitedKingdom.

Mexico

Fernando Lorenzo Salazar

Partner, tax and legal servicesand tax controversy practice

PwC




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With 32 years of experience, Jorge Narváez Hasfura has beenvoted for many years as a leading tax practitioner in Mexico ontax litigation, transfer pricing and indirect taxation by well-known and respected international publications. He is praisedfor his transfer pricing and corporate reorganisation work along-side his very strong practice in tax litigation, rulings and treaties.

He is founder member of the Legislative Tax Analysis Group(ATRIL); in March 2012 he was appointed by the MexicanPresident, for a four-year term, as an honorary IndependentAdvisor and Member of the Sounding Board of the MexicanTaxpayers’ Ombudsman (the PRODECON) and last year hewrote the foreword of the book Taxpayers Rights in aTransparent and Global Society, which was globally publishedby the PRODECON. Last year Mr. Narvaez presented at the5th Meeting of Vienna Multi-Stakeholder Group on ImprovingCross-border Dispute Resolution organised by the UnitedNations and the OECD. He also participated as an author in thespecial edition recently published by IDC Mexico dealing withBEPS, writing about Action 12. In May 2019, he participated as a speaker at the Global TaxConference, Driving the Future, organised by the Harvard ASH Center, Kennedy School ofGovernment and the Irish Tax Institute in Dublin, Ireland.

As of October 2014, he has been chairing the global tax dispute resolution group of BakerMcKenzie. Formerly, he has acted as chair of the Latin American tax practice group andmember of the global tax steering committee of Baker McKenzie, as well as member of theglobal transfer pricing sub-group of Baker McKenzie and chair of the Latin American valueadded tax practice group, and member of the global value added tax steering committee ofBaker McKenzie. As of October 2013, he was appointed as member of the global financialcommittee of Baker McKenzie, representing the Latin American region.

Practice areasHis areas of his expertise include tax litigation (Mexico), corporate income tax (Mexico),transfer pricing, international tax planning, corporate reorganisations (Mexico), tax rulingsand tax treaties, estate planning, wealth management and value added tax (Mexico).

Mexico

Jorge Narváez Hasfura

Partner, tax

Baker & McKenzie México




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Ángel specializes in tax, international trade and anti-moneylaundering (AML). He is recognised as one of Mexico s keyexperts in complicated tax matters that involve both litigationand fiscal planning.

Furthermore, he is specialised in criminal law matters. Headvises leading multinational companies interested in expandingand strengthening their business in Mexico as well as in the restof Latin America. He is also advisor to HNW individuals seek-ing advice on the management of their wealth in Mexico andinternationally.

Ángel has a solid and thorough background in tax, interna-tional trade and AML and has more than 15 years of expertisecounseling different sectors, including real estate, the pharmaceu-tical sector, transport and logistics, consumer goods and retail.

He is a lawyer that actively participates in various interna-tional associations and chambers of commerce including TheInternational Bar Association (IBA), The InternationalChamber of Commerce (ICC) and The Society of Trust andState Practitioners (STEP).

Ángel obtained his law degree from Escuela Libre de Derecho. He is a certified profes-sional in AML/CFT (Anti-Money Laundering / Counter-Terrorist Financing) by theMexican Banking and Securities Commission. Additionally, he is currently pursuing a degreeas Public Accountant from the Escuela Bancaria y Comercial in Mexico City.

Ángel is recognised by various leading legal publications, such as the Legal 500, Who sWho Legal and the International Tax Review. He has been identified as a leading lawyer inMexico in tax and international trade by numerous editorials. ITR shortlisted his previousfirm for the Best Mexican law firm in tax in 2017 and 2018.

Who’s Who Legal has praised him for his expertise in tax, international trade on both aninternational and local level. In 2019 he was distinguished as Thought Leader in CorporateTax. The Legal 500 launched in September 2018 states: “‘Straightforward’ founding partnerÁngel Escalante led on all cases. He is ‘very experienced and has considerable technicalknowledge’”.

He periodically publishes in prominent national and international media such as PuntosFinos, Práctica Fiscal, Latin Lawyer and Lex Latin.

Mexico

Angel Escalante

Partner

Nader Hayaux & Goebel

Mexico City+52 55 [email protected]



Mexico

Mauricio Ambrosi HerreraTuranzas Bravo & Ambrosi

Pedro Arias GarridoArias & Meurinne

Alejandro Barrera FernandezBasham Ringe & Correa

Mario Barrera VázquezThompson & Knight

Jorge Alberto Cabello AlcérrecaCancino Ayuso Abogados

Adolfo CalatayudPwC

Mariano CalderónSantamarina + Steta

Alejandro Calderón AguileraCalderón González & Carvajal

Luis CarbajoBaker McKenzie See page 68

César Gerardo Castañeda GuerreroKroy Abogados

Ulises Castilla FloresBaker McKenzie

Pablo Fernández de Cevallos y TorresTuranzas Bravo & Ambrosi

Martha DorantesDeloitte See page 25

Jaime Espinosa de los MonterosHogan Lovells

Roxana Gómez-OrtaBaker McKenzie

Manuel González LópezMancera - EY

Jorge JimenezDeloitte See page 25

Edgar KleeHaynes and Boone

Carl Edward Koller LucioTuranzas Bravo & Ambrosi

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Mexico

Jorge LibrerosMancera - EY

Miguel Ángel Llaca GarcíaLB & Cía

Manuel Llaca RazoGarrigues

Carlos Martínez BetanzosCreel García-Cuéllar Aiza & Enriquez

Mauricio Martinez-D’MezaDeloitte See page 25

Nora MoralesMancera - EY

Jorge Narváez-HasfuraBaker McKenzie See page 70

Ricardo González OrtaDeloitte See page 25

Luis Ortiz HidalgoOrtiz Hernández & Orendain

César Gregorio de la Parra BelloChevez Ruiz Zamarripa

Sergio Luis Perez CruzPwC

Karina Perez DelgadilloPwC

Antonio RamirezKPMG Cárdenas Dosal

Enrique RamírezMancera - EY

Carlos Alberto Ramírez LarsenDeloitte See page 25

Eduardo RevillaDeloitte See page 26

Ismael Reyes Retana TelloWhite & Case

Hugo RomeroDeloitte See page 26

Ricardo León SantacruzSánchez DeVanny

AMERICAS



Mexico

Ricardo SantoyoDeloitte See page 26

Manuel SolanoMancera - EY

Christian Solís MartínezSMPS Legal

Simon SomohanoDeloitte See page 26

Arturo TiburcioHogan Lovells

Juan Carlos Valles ZavalaBaker McKenzie

Luis VázquezCreel García-Cuéllar Aiza & Enriquez

Hernaldo VegaDeloitte See page 26

NICARAGUA

Juan Carlos Cortez EspinozaDeloitte See page 26

AMERICAS



PERU

Yanira ArmasDeloitte See page 26

María Eugenia Caller FerreyrosEY

César CastroCMS Grau

Lourdes ChauPwC

Alex CórdovaRodrigo Elías & Medrano Abogados

David de la Torre DelgadoEY

Luis Hernández BerenguelHernández & Cía Abogados

Lorgio MorenoZuzunaga Assereto & Zegarra Abogados

Rolando Ramírez-Gastón HornyEstudio Echecopar

César Talledo MazúEstudio Talledo

Fernando ZuzunagaZuzunaga Assereto & Zegarra Abogados

PUERTO RICO

Rolando LopezKPMG

AMERICAS



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The landscape of transfer pricing in the United States is subjectto continuing change. The IRS is close to promulgating perma-nent aggregation regulations to replace temporary regulationsdue to expire. These anticipated new regulations may make iteasier for the IRS to disregard complex transfer pricing struc-tures and, further, reflect the US taxing authority’s continuedfocus on transfer pricing issues. Court decisions affect the trans-fer landscape as well. For example, the United States recentlyprevailed on an appeal of the Altera decision in the NinthCircuit Court of Appeals, a leading appellate court in theUnited States. The taxpayer is now seeking full court review ofthat decision. The final decision in that case not only may affectcompanies that have entered into cost sharing agreements, butalso may further empower tax authorities worldwide to defineby regulation or administrative decision what they conceive tobe arm’s length behavior.

One development in the United States, however, meritsextended comment. Several years ago, the IRS announced,without significant fanfare, new audit guidelines for transferpricing audits. We have now had sufficient time to see thoseguidelines (announced in IRS Publication 5125) actually be putinto practice by IRS examiners across the country and we cansay, indeed, the landscape is changing. With these new guide-lines, the IRS has sharpened its tools and is using them to iden-tify and develop transfer pricing issues and thereby collect rev-enue from perceived taxpayer abuse.

These guidelines are called the Transfer Pricing ExaminationProcess. They describe audit procedures in detail for all poten-tial transfer pricing issues. They establish three phases for trans-fer pricing audits: the planning phase, the execution phase andthe resolution phase. The detailed focus and measures in each of

UNITED STATES

Kenneth ClarkFenwick & West

The changing landscape oftransfer pricing in the UnitedStates: Section 482 auditsKenneth Clark, head of the tax litigation subgroup at Fenwick & West, discusses changes to thetransfer pricing regime in the US



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United States

these phases needs to be well understood by any company subject to a transfer pricing audit– if it wants to forestall an adjustment or, at the very least, present its best defense possible.

In the planning phase, IRS auditors are charged under the guidelines with gathering infor-mation, analysing the taxpayer’s position, and preparing a ratio analysis of various financialmetrics to help it determine whether cross border income shifting is occurring. As a theoret-ical matter, much of this procedure is not new. However, as a practical matter, the planningphase of the IRS has, we have found, intensified and sharpened. For example, in actual auditsexamination teams are increasingly rigorous in their initial collection of materials that theguidelines suggest assembling, such as prior IRS workpapers, the taxpayer’s § 6662 docu-mentation, board of directors’ minutes, SEC filings, and the like. The guidelines explicitlydirect auditors to analyse country-by-country reports and to coordinate with other taxauthorities under information exchange programmes. The latter two sources of informationare, of course, relatively new and, we find, are being pursued by the IRS with vigour.

The planning phase directives charge the IRS audit team to develop a “preliminary work-ing hypothesis”. In the course of collecting and reviewing material documents, but before theexecution phase of the examination itself, IRS auditors will identify the transactions or struc-tures that it will subject to scrutiny and then will actually internally define the case it will betrying to establish. With this clear instruction to its auditors, the IRS has now thrown downthe gauntlet to taxpayers. Expect the IRS to have developed its own duelling theory of whyan adjustment is appropriate before the substantive part of the audit even begins.

The IRS now has a number of developed internal instructions for tax issues, including trans-fer pricing issues, called Practice Units, which are maintained in a database, are readily availableto IRS examiners and are also accessible to taxpayers. Expect that the IRS audit team will havedeveloped its charging theories using its increasingly substantial Practice Unit library.

The execution phase of a transfer pricing examination follows the IRS’s opening confer-ence with the taxpayer. During the execution phase, examiners are directed to further reviewcompany agreements, and use Information Document Requests (IDRs) to gather informa-tion from the taxpayer and to develop a functional analysis. The IRS now has specific IDRs(both mandatory and discretionary) tailored for transfer pricing issues. With the guidelines,we are seeing much more uniform use of standardised IDRs seeking written responses – andmore systematic information collection than ever before. Expect that the IRS audit team willissue extensive information requests for documents and will adhere to its required IDR timeframes, which have been in place for several years. Though not explicitly spelled out in theguidelines, also expect the examination team as part of the IDR process to conduct witnessinterviews, a tool that the IRS widely uses to develop transfer pricing issues.

The guidelines provide that during the execution phase, the taxpayer will be expected toprovide a “transfer pricing/supply chain orientation”. This orientation is typically an extensivepresentation by the taxpayer to provide background on its industry, to explain its transfer pric-ing structure and to provide detailed transaction information. It is an opportunity for the tax-payer to educate the auditors and support its position. Bearing in mind that the examiners willalready have formed their “hypothesis”, this meeting will provide an opportunity to the exam-ination team to accelerate its information collection, ask unbounded questions and sharpen itstheories. In actual practice, this “industry presentation” has become very important. It oftenrequires extensive preparation and should be planned for very early by taxpayers.



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We have found that examiners trained in the new procedures are more often than in thepast adhering to instructions to confer with the taxpayer. The new guidelines contain explicitinstructions that periodic meetings should be held. Further, the guidelines state that theexaminers should “consider” an open discussion with the taxpayer concerning their “workinghypothesis(es)”. The procedures also encourage auditors to “engage in a meaningful discus-sion about any missing facts or any misinterpreted facts”. Other provisions encourage “openand continuous communication between the taxpayer and the issue team”. These variousprovisions of the guidelines are very important for taxpayers, who are well served to persist-ently inquire about the IRS’s theories and preliminary findings so that they can address themhead on, as early as possible during an audit.

The IRS is directed under its guidelines to prepare a draft economic report and to discussthat report, even if not complete, with the taxpayer. The template for this draft reportinstructs the IRS to develop a specific critique of the taxpayer’s methodology and analysis.However, under recent guidance by the Large Business and International (LB&I) division,this economic analysis will more likely accept the taxpayer’s transfer pricing method, ratherthan propose an adjustment with a different transfer pricing method. If the auditors want tochange the taxpayer’s method they must develop and articulate a compelling case to do soand are now required to secure various approvals from IRS senior management to pursue anadjustment based on an alternative method. Consequently, the taxpayer can and should pressIRS auditors to reveal their economic thinking – including their critique of the taxpayer’sanalysis – without material concern that doing so will push the auditors to an alternativetransfer pricing method.

The guidelines direct the IRS to develop its Notice of Proposed Adjustment, along withits economic analysis, all founded on the IRS’s functional analysis of the taxpayer. Since thefunctional analysis is supposed to be the backbone of the examination team’s position, theseguideline provisions further elevate the importance of the taxpayer fully and accurately devel-oping a description of its various related parties’ functions in its Section 6662 documenta-tion, as well as during the audit process itself. We find that the transfer pricing examiners arenow routinely and uniformly issuing final IDRs to secure acknowledgement of all relevantfacts supporting the IRS’s functional analysis, as is directed by the guidelines.

In acknowledging the facts for the IRS, taxpayers now must be extremely careful to makesure that all material facts supporting their position are well supported and developed duringthe audit phase. Toward the conclusion of the audit, taxpayers will be asked for an “agreedstatement of facts”, and can be effectively foreclosed from presenting new facts later (duringadministrative proceedings with the IRS Appeals group, for example) if an adjustment is notresolved at the examination stage.

The guidelines suggest that groups within the IRS coordinate regarding transfer pricingissues generally and on specific adjustments. We also are finding that there is, in fact,increased coordination concerning transfer pricing adjustments among and between groupssuch as the IRS audit team, legal counsel and the IRS personnel who generate Practice Units.

The last phase in the guidelines is called the “resolution” phase, but the term resolutionis not meant to imply that the audit team itself will try to resolve the case with the taxpayer.There is no directive for it to do so. In fact, the guidelines contemplate the scenario that“field resolution [will not be] reached”. The guidelines provide examiners clear instructions

United States



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United States

for closing the case – with an adjustment – and contemplate the taxpayer’s potential steps toresist an adjustment, such as engaging in the Appeals process or making a CompetentAuthority request, all of which are considered by the guidelines to be paths to “resolution”.

The guidelines provide examples of 24- and 36-month examinations. As a practical matter,notwithstanding the precise steps enunciated in the guidelines, we have found that transferpricing audits are not shorter than in the past. Accordingly, the taxpayer (and its senior man-agement) need to be apprised that the commencement of a transfer pricing audit is likely totrigger a long and involved process, that the IRS likely will develop its theories early and morevigorously than ever before, and that when transfer pricing transactions involving largeamounts of money or significant complexity are subject to scrutiny, adjustments are common.



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Kenneth Clark is a partner in the Tax Group of Fenwick & Westand has served as Chair of its Tax Controversy Practice since itsformation. Fenwick has received numerous accolades for its taxcontroversy practice, including recognition by International TaxReview as the top controversy practice in North America and asU.S. tax litigation firm of the year in several different years. Theprincipal focus of Kenneth’s practice is complex federal tax liti-gation and tax controversy work, particularly involving interna-tional matters. He regularly practices in the U.S. Tax Court andhas published a number of articles relating to tax controversies.Fenwick has worked on more than 75 federal tax litigations.

Kenneth has worked on numerous high profile tax controversymatters, for clients such as Xilinx, The Limited, L Brands, Textron,Chrysler AG, G.M. Trading, Dover Corporation, Adaptec, AnalogDevices, Sanofi SA, Cameco and CBS. A number of these mattershave resulted in important reported decisions.

With four decades of experience, Kenneth also has manageda variety of complex tax disputes in the U.S. and in a number of foreign countries. He isincluded in International Tax Review’s World’s Controversy Leaders and Euromoney’sWorld’s Leading Transfer Pricing Advisors. Litigation prevention and alternative dispute res-olution have been important parts of his practice; he has served as Fenwick’s ADR coordina-tor, been an AAA arbitrator, and been involved in numerous mediations and arbitrations.

Ken received a B.A. from the University of Redlands, where he graduated summa cumlaude, and was first in his class. He received a J.D. from New York University School of Law,cum laude, and was a member of that school’s Law Review. Kenneth also received an MBAfrom the University of California, Berkeley. He has extensive experience in teaching speakingtechniques.

Kenneth is a member of the State Bars of California and New York. He is also admittedto practice in the U.S. Tax Court and numerous federal courts.

United States

Kenneth Clark

Chair, Tax Litigation Group /Partner, Tax Group

Fenwick & West LLP

+1 650 335 [email protected]



AMERICAS

Languages: English

BiographyWard represents both U.S. and foreign multinationalCorporations with complex tax issues. Ward has been recog-nized as one of the World’s Leading Tax Controversy Advisersby ITR, and recognized in Legal Media Group’s Expert Guidesand ITR’s “World Tax” for his skills in transfer pricing.

Recent matter highlightsWard has resolved a substantial number of tax disputes at theIRS exam level, with IRS Appeals, through mediation, and viaadvance pricing agreements (APAs).

Practice areas• Cost-sharing arrangements• APAs• Audit defence• Dispute resolution• Transfer pricing

Sector specialisations• Automotive• Consumer goods and services• Media• Pharma and life sciences• Tech and telecoms

Academic qualifications• J.D., with Honors, Duke University School of Law, 1996• Ph.D. in economics, University of South Carolina, 1989• B.A., University of South Carolina, 1984

United States

Ward Connolly

Principal

PwC

San Jose, California+1 408 817 [email protected]



AMERICAS

Languages: English

BiographyAnthony Curtis is a senior economist and Principal at PwC. Inhis current role, Tony is U.S. Consumer Markets TransferPricing Sector Leader for PwC. Tony has 29 years of experienceconducting economic analysis and for the last 27 years, he hasspecialized primarily in transfer pricing including economicanalyses for examinations, appeals, APAs, and competentauthority negotiations with the IRS and foreign tax authoritiesas well as TP planning and documentation.

As the TP Consumer Markets leader, Tony serves PwC’sleading retail, luxury goods, and consumer products clients toensure that they have access to the latest ideas and the mostexperienced personnel of the PwC Global Network. Over hiscareer, Tony has functioned as the NYC Tax ControversyPractice Leader and the TP leader for PwC’s NY metro transferpricing region. In addition, he has led the practice’s GloballyCoordinated Documentation service offering, and was the Americas editor for PwC’s transferpricing news articles.

Practice areasTransfer pricing, Economic modelling, APAs, MAP proceedings, Litigation support,Controversy management

Sector specialisationsConsumer goods, retail and services

Academic qualificationsPost Graduate Taxation studies 1999 Fordham UniversityMBA 1992 George Washington UniversityBBA 1990 George Washington University

United States

Anthony Curtis

U.S. Consumer Markets TransferPricing Leader at PwC

PwC

New York+1 646 471 [email protected]



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David Forst focuses on international corporate taxation. Davidis included in Euromoney’s Tax Advisors Expert Guides(World’s Leading Tax Advisors, World’s Leading TransferPricing Advisors and was named one of the Top 30 U.S. TaxAdvisors). He is also in the Legal 500 Hall of Fame and Lawand Business Research’s International Who’s Who of Corporateand Tax Lawyers (for the past seven years). David is listed inChambers USA America’s Leading Lawyers for Business, andhas been named a Northern California Super Lawyer in Tax bySan Francisco Magazine.

David is a lecturer at Stanford Law School and UC BerkeleyLaw School where he focuses on international taxation. He is aneditor of and regular contributor to the Journal of Taxation,where his publications have included articles on internationaljoint ventures, international tax aspects of mergers and acquisi-tions, the dual consolidated loss regulations, and foreign cur-rency issues. He is a regular contributor to the Journal of Passthrough Entities, where hewrites a column on international issues. David is a frequent chair and speaker at tax confer-ences, including the NYU Tax Institute, the Tax Executives Institute, and the InternationalFiscal Association.

David graduated with an A.B. (cum laude) Phi Beta Kappa from Princeton University’sWoodrow Wilson School of Public and International Affairs, and received his J.D., with dis-tinction, from Stanford Law School.

David is a member of the State Bar of California.

United States

David Forst

Partner, Tax Group

Fenwick & West LLP




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Jim Fuller is a partner in the Tax Group at Fenwick & West LLPin Mountain View, California. Euromoney named Fuller seventimes as one of the world’s top 25 tax advisers.

He is the only U.S. tax adviser to receive a Chambers starperformer rating (higher than first tier) in Chambers USA(2018). He also is one of the three “most highly regarded” U.S.tax practitioners according to Who’s Who Legal (Law &Business Research Ltd).

Fuller is the only U.S. tax advisor in Tier 1 for bothCorporate Tax and International Tax according to ChambersGlobal (2018). The Corporate Tax Tier 1 category has fifteenUS persons; International Tax Tier 1 has six.

He also is one the US’s top 30 transfer-pricing advisors,according to Euromoney (2018).

Among his other recognitions, Legal 500 has included Fullerin its Tax “Hall of Fame.”

Ten Fenwick tax partners have appeared in Euromoney’sWorld’s Leading Tax Advisors, eight appear in ITR’s World’s Tax Controversy Leaders andfive have appeared in Euromoney’s World’s Leading Transfer Pricing Advisors.

Fenwick has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100companies, and over 100 of the Fortune 500 companies in federal tax matters.

Fuller and his firm have served as counsel in over 150 large corporate IRS Appeals pro-ceedings and over 75 large-corporate federal tax court cases. Some of these have been forFortune Top 10 companies.

Fenwick is first tier in Tax Planning, Tax Transactional, World Tax and Transfer Pricing,according to International Tax Review published in 2017–2018. Only 4 US law firms are firsttier in each of these surveys/publications.

International Tax Review named Fenwick & West “Tax Firm of the Year for the SanFrancisco Area” nine times in the past 12 years and “US (or Americas) Tax Litigation Firm ofthe Year” four times. These ITR awards were given at ITR’s very well-attended black-tie awardsdinners in New York City. All of the big US law and accounting firms attend these dinners.

Fenwick also was named US West Transfer Pricing Firm of the Year. Fenwick was named“Americas M&A Tax Firm of the Year” at one of these dinners, and in 2014–2018 Fenwickreceived a number of ITR’s M&A Tax Deal of the Year awards. Most involved internationalM&A transactions. Fenwick also received ITR’s Joint Venture of the Year award forSymphony Communications, a JV in which 13 major NY banks were involved.

United States

James Fuller

Partner, Tax Group

Fenwick & West LLP




AMERICAS

Jennifer Fuller is a Partner Emeritus in the Tax Group atFenwick & West LLP in Mountain View, California. She wasincluded for the fourth time as one of the world’s top 25women tax advisers in Euromoney’s Worlds Leading WomenBusiness Lawyers (2015), and was invited again to write anintroduction to the publication.

Ms. Fuller was named “America’s Best in Tax DisputeResolution” by Euromoney at its 2014 and 2015 AmericasWomen in Business Law Awards Dinner. She also has been onEuromoney’s Women in Business Law short list three times forthe award “Best in Tax.”

Ms. Fuller’s work during 2015 included large-corporate taxlitigation and M&A matters, including work on some of therecent and widely publicized “inversion” transactions.

Ms. Fuller has been on the Executive Leadership Committeeof the International Fiscal Association, which is a highly-regard-ed worldwide association of leading tax advisors, and hasappeared regularly in Euromoney’s World’s Leading Tax Lawyers.

Ms. Fuller has served as the Northern California Chair for the California State BarInternational Tax Committee. She has spoken at and chaired numerous seminars on interna-tional tax subjects. Ms. Fuller’s articles have appeared in Tax Notes International magazineand in Tax Notes magazine.

Whittier College awarded Ms. Fuller its Alumna Achievement Award in 2013 “for supe-rior accomplishments in her career.” Later that year, Ms. Fuller was elected to serve, and shecontinues to serve, on the Whittier College Board of Trustees.

Ms. Fuller has been a tax partner at Fenwick for over 20 years, and plays an instrumental rolein the firm’s tax practice. The firm has represented 6 of the Fortune top 10 companies, over 50of the Fortune 100 and over 100 of the Fortune 500 companies in federal tax matters.

International Tax Review gave Fenwick & West its San Francisco Tax Firm of the YearAward nine times through 2017, and has given F&W its America’s (or US’s) Tax LitigationFirm of the Year award four times. F&W also has received M&A tax awards at the ITRAmericas Awards dinners, including Americas M&A Tax Firm of the Year.

Ms. Fuller also has been included in Euromoney’s Guide to the World’s Leading TaxAdvisors, Law and Business Research’s International Who’s Who of Corporate Tax Lawyers,ITR’s Leading Lawyers in the Western U.S., Euromoney’s Guide to the Leading U.S. TaxLawyers, and International Tax Review’s Best Tax Advisers in North America.

Jennifer is a member of the State Bar of California.

United States

Jennifer Fuller

Partner Emeritus, Tax Group

Fenwick & West LLP




AMERICAS

Adam Halpern is the Chair of the Tax Group at Fenwick &West LLP. His practice focuses on the US federal income taxa-tion of international transactions. He regularly advises on thetaxation of cross-border operations, acquisitions, dispositionsand restructurings. He has successfully represented clients infederal tax controversies at all levels.

Adam is a lecturer in law at Stanford Law School, teachingclasses in international tax, and is a frequent speaker at TEIand PLI.

Adam is recognised as a leading tax lawyer by Euromoney’sWorld’s Leading Tax Advisors, International Tax Review andChambers USA. He also appears in ITR’s Tax ControversyLeaders.

The Fenwick & West Tax Group has advised over 100Fortune 500 companies on tax matters, and has served as coun-sel in more than 150 large-corporate IRS Appeals proceedingsand more than 75 federal court tax cases. Recent publishedcases include Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), CBS Corp. v.United States, 2012-1 U.S.T.C. ¶50,346 (Fed. Cl.), and the landmark Xilinx, Inc. v.Commissioner, 125 T.C. 37 (2005), aff ’d, 598 F.3d 1191 (9th Cir. 2010), described by theWall Street Journal as “the biggest tax case in the last 20 years.”

Fenwick has been named San Francisco Tax Firm of the Year and U.S. Tax Litigation Firmof the Year numerous times by International Tax Review.

Adam graduated summa cum laude from the University of California, Hastings Collegeof the Law, and has an AB in Philosophy from Princeton University.

He is a member of the State Bar of California and the American Bar Association Sectionof Taxation.

United States

Adam Halpern

Chair, Tax Group

Fenwick & West LLP




AMERICAS

Biography Sharon represents multinationals and financial institutionsbefore the IRS. She advises on various disputes matters withsubstantial experience in transfer pricing, competent authorityand domestic corporate issues. An Adjunct Professor of Law atNYU Law School, where she teaches Civil Tax Controversies &Litigation, she is also a member of the UN Tax Committee’sSubcommittee on MAP, Dispute Avoidance and Resolution,which is currently drafting the United Nations Handbook onDispute Avoidance and Resolution.

Association memberships• American Bar Association• New York State Bar Association

Academic qualifications• LLM (Tax); New York University School of Law• JD, cum laude: Cardozo School of Law, Yeshiva University• BA, cum laude; Barnard College, Colum

Recent matter highlights • Represents a major financial institution in its IRS exam and MAP proceeding, obtaining a

resolution on a billion dollar issue involving losses from the financial crisis• Works with multinationals facing disputes in multiple jurisdictions to manage their

processes• Representation of a major multinational on variety of US domestic issues• Obtained pre-filing agreements on a variety of corporate issues, providing certainty in

advance of return filing

Practice areas • Audit defence• Dispute resolution• Pre-litigation• MAPs/ADRs• Controversy management• Voluntary disclosures• Cross border project management• Transfer pricing

Sector specialisations Banking, Consumer goods and services, Financial services, Tech and telecoms

United States

Sharon Katz-Pearlman

Global Head and US NationalPrincipal in Charge, Tax DisputeResolution & Controversy

KPMG LLP

New York+1 212 872 [email protected]/xx/en/home/services/tax/dispute-resolutioncontroversy.html



AMERICAS

Recent matter highlights• Counsel in the important taxpayer victory for Analog

Devices, Inc. v. Commissioner, and the successful resolutionfor Sanofi in Aventis, S.A. v. United States.

• Currently counsel for VF Corporation/Timberland in TBLLicensing LLC v. Commissioner.

• Handled recent acquisitions including Workday’s $1.55Bacquisition of Adaptive Insights; Callidus Software andGigya’s acquisitions by SAP; and Facebook’s acquisitions ofRedkix, Ozlo, Source3, CrowdTangle, etc.

Practice areas• Corporate taxes• Audit defence• Litigation• International tax advisory• Transfer pricing

Sector specialisations• Gaming• Healthcare• Pharma and life sciences• Tech and telecoms

Association memberships• Member of the ABA Section of Taxation• Executive Committee Member of International Fiscal Association and Chair of the

Technology Committee• Member of the IFA NorCal Region Steering Committee• Member of the ABA International Law Section Tax Committee• Member of the Animal Legal Defense Fund

Academic qualifications• J.D., University of California, Berkeley, School of Law, 2005• M.A., Public Health• Yale University, 2002• B.S., Molecular Cell Biology• University of California, Berkeley, 2000

United States

Larissa Neumann

Partner, Tax Group

Fenwick & West LLP

Mountain View, CA+1 650 335 [email protected]



AMERICAS

BiographyKathryn is a Principal in PwC’s National Tax Transfer Pricingpractice and is PwC’s Global Asset Management TransferPricing Leader. She is assisting clients with all aspects of transferpricing: planning, compliance, APAs and controversy. She is oneof PwC’s leading experts on BEPS transfer pricing and perma-nent establishment matters.

Recent matter highlights• Kathryn has been working, personally, with more than 25%

of the Fortune 100 in their efforts to comply with BEPSAction 13.

• Kathryn is also assisting with the application of the transferpricing elements of US Tax Reform.

Practice areas• Business model optimisation• APAs• Financial services• Value chains• Controversy management• Transfer pricing

Sector specialisations• Banking• Financial services• Industrials• Investment management• Oil and gas

Academic qualifications• LLM, Georgtown University Law School, 1991• JD, George Washington Law School, 1987• BA, Finance, Michigan State University, 1984

United States

Kathryn Horton O’Brien

Principal

PwC




AMERICAS

Ronald Schrotenboer’s published decisions include Xilinx, Inc.v. Commissioner, 125 T.C. 37 (2005), aff ’d (9th Cir. 2010)(stock option amounts not required to be cost shared under §482); Sun Microsystems v. Commissioner 69 T.C.M. 1884(1995), (incentive stock option deduction qualifies for R&Dcredit); Appeal of Finnigan Corporation, CCH 401-797(1990), (throwback rule is applied on a unitary basis; Appeal ofJoyce overruled); and Petition of Intel Corporation, CCH 402-675 (1992), (technology transfers are not subject to Californiasales tax).

Ronald received his BA degree, with honours, in 1977 fromCalvin College in Grand Rapids, Michigan. He received his JDdegree magna cum laude from the University of Michigan in1980. He graduated as a member of the Order of the Coif andwas an editor on the Michigan Law Review for two years.

United States

Ronald Schrotenboer

Tax Group

Fenwick & West LLP




AMERICAS

David Swenson is the global leader of PwC’s tax controversyand dispute resolution (TCDR) network and is resident in theWashington, DC office. The TCDR global network includesmore than 1000 tax controversy professionals, located inupwards of 80 countries across the globe, who assist multina-tional enterprises to prevent, manage, and resolve tax auditsand disputes worldwide.

Following a prominent legal career spanning 25 years, Davidhas substantial experience in advising multinational enterprises(MNEs) on international tax matters, and assisting companies intheir efforts to pursue a variety of measures aimed at proactivelypreventing, efficiently managing, and favourably resolving taxaudits and disputes worldwide. Over the years, David has partici-pated in more than 250 tax controversies involving audits and dis-putes between MNEs and the Internal Revenue Service (IRS), aswell as dozens of other revenue authorities around the world.

Many of these tax disputes were resolved at the audit level orthrough the proactive use of administrative appeals, mediation,arbitration, APAs, or the Competent Authority/MAP process.Other controversies were docketed in a US court of law, proceeded to trial, and resulted inimportant decisions for MNEs, including cases involving transfer pricing (Bausch & Lomb I),the foreign tax credit (Ampex), Competent Authority matters (Yamaha), the definition of‘manufacturing’ for Subpart F purposes (Bausch & Lomb II), foreign currency(Carborundum), and intellectual property rights (Exide/Exxon). David also participated inseveral landmark tax cases before the US Supreme Court, including the Barclays Bank, Boeing,and Goodyear cases. David has been described as “one of the top five tax controversy expertsin the US”, and he received recognition as a “leading attorney” in US tax litigation byChambers US, and as one of the world’s top 25 transfer pricing specialists.

In addition, David received a Meritorious Service Certificate from the TreasuryDepartment and IRS, and has been an adjunct professor at Georgetown University LawCenter, where he continuously taught courses for 25 years relating to international corporateincome taxation. David received his MLT from Georgetown University Law School, and hisJD, with honours, and BA, with distinction, from the University of Mississippi. David alsohas been admitted to practice before the US Tax Court, the US Court of Federal Claims,numerous US Federal Courts of Appeal, and the US Supreme Court.

United States

David Swenson

Global Network Leader, TaxControversy and DisputeResolution

PwC

Washington, [email protected]/taxcontroversy



United States

David AbbottMayer Brown

Robert AlbaralBaker McKenzie

Michael AlterFried Frank

Brad AnwyllCrowell & Moring

Jenny AustinMorgan Lewis & Bockius

Summer AustinBaker McKenzie

Howard BermanDeloitte See page 26

David BlairCrowell & Moring

Peter BlessingKPMG

William BonanoPillsbury Winthrop Shaw Pittman

Kim Marie BoylanWhite & Case

Jennifer BreenMorgan Lewis & Bockius

Kevin BrownPwC

Steven BrownClark Hill

Michael BryanDeloitte See page 26

Thomas CallahanThompson Hine

Christopher CampbellDeloitte See page 26

Nathaniel CardenSkadden Arps Slate Meagher & Flom

Cabell ChinnisMayer Brown

AMERICAS



United States

Kerwin ChungDeloitte See page 27

Kenneth ClarkFenwick & West See page 80

George ClarkeBaker McKenzie

Jerold CohenEversheds Sutherland

Erin CollinsKPMG

Ward ConnollyPwC See page 81

Jon ContrerasDeloitte See page 27

Daniel CookDeloitte See page 27

Andrew CrousoreBaker McKenzie

Anthony CurtisPwC See page 82

Michael DanilackPwC

Valerie DickersonDeloitte See page 27

Paul DiSangroMayer Brown

Steven DixonMiller & Chevalier

Mike DolanKPMG

Rod DonnellyMorgan Lewis & Bockius

Thomas DriscollDeloitte See page 27

Daniel DumezichDeloitte See page 27

Michael DurneyLaw Offices of Michael C Durney

AMERICAS



United States

Elizabeth EricksonMcDermott Will & Emery

Jeffry ErneyDentons

David ErnickPwC

Michelle FerreiraGreenberg Traurig

Miriam FisherLatham & Watkins

Sean FoleyKPMG

David ForstFenwick & West See page 83

Scott FrewingBaker McKenzie

James FullerFenwick & West See page 84

Jennifer FullerFenwick & West See page 85

Stephen GardnerCooley

George GerachisVinson & Elkins

Imke GerdesBaker McKenzie

Stephen GertzmanMiller & Chevalier

Erin GladneyBaker McKenzie

Fred Goldberg JrSkadden Arps Slate Meagher & Flom

Edward GradyDeloitte See page 27

Charles HallNorton Rose Fulbright

Adam HalpernFenwick & West See page 86

AMERICAS



United States

George HaniMiller & Chevalier

Rob HansonEY

John HildyMayer Brown

Lawrence HillWinston & Strawn

Charles HodgesJones Day

Alan HorowitzMiller & Chevalier

Kathryn Horton O’BrienPwC See page 89

Charles HurleyNorton Rose Fulbright

Kevin JohnsonBaker Hostetler

Thomas JohnstonShearman & Sterling

Maria O’Toole JonesMiller & Chevalier

Richard JonesSullivan & Worcester

Roger JonesMcDermott Will & Emery

Joseph JudkinsBaker McKenzie

Philip KarterChamberlain Hrdlicka White Williams & Aughtry

Sharon Katz-PearlmanKPMG See page 87

John KeenanDeloitte See page 27

Kevin KenworthyMiller & Chevalier

Andrew KimPwC

AMERICAS



United States

Brian KittleMayer Brown

Thomas Kittle-KampMayer Brown

Kenneth KleinMayer Brown

Donald KorbSullivan & Cromwell

Stephen KranzMcDermott Will & Emery

Larry LangdonMayer Brown

Frank LavaderaKPMG

Marc LeveyBaker McKenzie

Patricia Gimbel LewisCaplin & Drysdale

Jerome LibinEversheds Sutherland

Thomas LinguantiMorgan Lewis & Bockius

Darrin LitskyDeloitte See page 27

Dante LucasKPMG

Ching LunBDO

Raj MadanSkadden Arps Slate Meagher & Flom

John MageeMorgan Lewis & Bockius

James MastracchioDentons

Jane Wells MayMcDermott Will & Emery

Todd MaynesKirkland & Ellis

AMERICAS



United States

William McGarrityMayer Brown

Wade McKnightDeloitte See page 27

Victor MieselMazars

Robert MorrisNorton Rose Fulbright

Christopher MurphySkadden Arps Slate Meagher & Flom

Joseph MyszkaBaker McKenzie

David NagleSullivan & Worcester

Mark NehorayDeloitte See page 28

William NelsonMorgan Lewis & Bockius

Larissa NeumannFenwick & West See page 88

Deborah NolanEY

David NorenMcDermott Will & Emery

Shawn O’BrienMayer Brown

Mark OatesBaker McKenzie

Joshua OdintzBaker McKenzie

Pam OlsonPwC

Edward Osterberg JrMayer Brown

Kevin OteroCovington & Burling

Emily ParkerThompson & Knight

AMERICAS



United States

Jean PawlowLatham & Watkins

Kim PetersonDeloitte See page 28

Martin PressGunster

Jose Manuel RamirezKPMG

Keith ReamsDeloitte See page 28

Mark RocheBaker McKenzie

Daniel RosenBaker McKenzie

David RosenbloomCaplin & Drysdale

Susan RybaBaker McKenzie

Leslie SamuelsCleary Gottlieb Steen & Hamilton

Paul SchickBaker McKenzie

William SchmalzlMayer Brown

Leslie SchneiderIvins Phillips & Barker

Ronald SchrotenboerFenwick & West

Rosemary SeretiDeloitte See page 28

William SharpHolland & Knight

Sanford StarkMorgan Lewis & Bockius

Scott StewartMayer Brown

Cathy StopyraBDO

AMERICAS



United States

Douglas StranskySullivan & Worcester

Patricia SweeneyMiller & Chevalier

David SwensonPwC See page 91

Phillip TaylorBaker McKenzie

Jasper Taylor IIINorton Rose Fulbright

Mary ThomasWeaver

Joseph TobinDeloitte See page 28

Jack TrachtenbergDeloitte See page 28

Brian TraumanKPMG

Josh UngermanMeadows Collier Reed Cousins Crouch & Ungerman

Juan Vasquez JrChamberlain Hrdlicka White Williams & Aughtry

Mario VerdoliniDavis Polk & Wardwell

Robert WaltonBaker McKenzie

Duane WebberBaker McKenzie

Jay WeillSideman & Bancroft

Gary WilcoxMayer Brown

John Williams JrSkadden Arps Slate Meagher & Flom

Joel WilliamsonMayer Brown

Robert WillmoreCrowell & Moring

AMERICAS



United States

Diana WollmanCleary Gottlieb Steen & Hamilton

Steven WrappeGrant Thornton

Russell YoungBaker McKenzie

Shanwu YuanBaker McKenzie

Alexander ZakupowskyMiller & Chevalier

Thomas ZolloKPMG

URUGUAY

Juan Manuel AlbaceteGuyer & Regules

Sebastián Arcia NodariArcia Storace Fuentes Medina Abogados

AMERICAS



AMERICAS

VENEZUELA

José Barnola JrBaker McKenzie

Alberto BenshimolD’Empaire Reyna Abogados

Alberto Blanco-Uribe QuinteroAsociación Venezolana de Derecho Tributario

Valmy Díaz IbarraTorres Plaz & Araujo

Ronald EvansBaker McKenzie

Andrés Luis Halvorssen VillegasRaffalli de Lemos Halvorssen Ortega Ortiz Abogados

Jorge Jraige RoaAltum Abogados

Alaska MoscatoMendoza Delgado Labrador & Asociados

Humberto Romero-MuciD’Empaire Reyna Abogados

Rafael Enrique Tobía DíazRodríguez & Mendoza

José ValecillosD’Empaire Reyna Abogados


Asia-Pacific



ASIA-PACIFIC

APACCurrent trends suggest that multinational organisations will continue to spend moretime and resources managing tax controversies in both their local and foreign markets.Tax authorities are sharing information about companies and are increasingly focusingon not only the technical merit of a tax position but also on implementation. Deloitte’s tax controversy teams in Asia Pacific include former tax authority officials,

alternative dispute resolution specialists, and in many countries, tax litigation specialistswho can assist multinational businesses at all phases of the tax controversy cycle.Dedicated tax controversy professionals within the Deloitte network provide cover-

age across Asia Pacific with presence in all key markets across the region.Deloitte operates a global tax controversy group with leaders assigned across a num-

ber of countries. The leaders within the Asia Pacific region are able to draw upon theconnections within this community from all parts of the world, to deliver cross-borderbased solutions in a coordinated and aligned manner.This approach in dealing with the tax controversy related problems of clients provides

common methodologies and development of technology-based tools used collaborative-ly across jurisdictions to enhance success for clients.Deloitte in Asia Pacific includes offices in more than 120 cities in over 20 countries,

with over 600 partners and 9,000 client service professionals, and forms part of one ofthe world’s largest professional services firms capable of drawing on the firm’s multidis-ciplinary skills to deliver cross-border solutions to clients in local markets.Deloitte in Asia Pacific is innovative because it has developed a coordinated network

of professionals sharing insight and approaches, designed in response to trends beingobserved over the course of the past five years.The delivery of services and solutions within this network entails approaching prob-

lems in an innovative fashion by embedding technology-based solutions. This is done byusing data analytics and forensic tools to assist in large-scale reviews and audits in con-junction with the skill and decision-making of highly experienced professionals.

Our key service offerings include: Consulting services to help clients manage, understand and resolve complex disputes withrevenue taxing authorities, including pre-audit procedures or dispute prevention, tax audits orassessments, and dispute resolution or settlement; audit readiness assessments (income, estate,gift, inheritance tax etc.) and support for clients undergoing tax authority reviews and audits.

Recent wins: • Assistance in a large multijurisdictional-based dispute involving a leading pharmaceu-tical group



ASIA-PACIFIC

• Assistance to an Asia Pacific headquartered multinational regarding cross-borderfinancing reviews in the consumer business industry

• Risk Assessment reviews of an Asia Pacific headquartered multinational group cover-ing more than a dozen countries

• Assistance on formal disputes involving cross-border financing in the oil and gas industry

Awards: International Tax Review Awards in the last three years:

2019 – 10 awards• Tax Firm of the Year: Indonesia, Malaysia, Singapore• Transfer Pricing Firm of the Year: India, Indonesia, Thailand• Tax Disputes & Litigation Firm of the Year: Taiwan, Thailand• Regional Impact Cases of the Year: Landmark application of product sharing contracttransfer tax on cross border M&A transactions in the oil & gas industry: DeloitteIndonesia

• Tax policy development for Labuan International Insurance Association Malaysia:Deloitte Malaysia

2018 – 14 awards • Asia Transfer Pricing Firm of the Year• Asia Indirect Tax Firm of the Year• Asia Tax Technology Firm of the Year• Tax Firm of the Year: China, Japan, Indonesia, New Zealand, and Taiwan • Transfer Pricing Firm of the Year India, Indonesia, New Zealand, Philippines,Taiwan, and Thailand

• Tax Disputes & Litigation Firm of the Year: Taiwan and Vietnam

2017 – 12 awards• Asia Transfer Pricing Firm of the Year• Asia Indirect Tax Firm of the Year • Tax Firm of the Year: China, Malaysia, Thailand, Vietnam• Transfer Pricing Firms of the Year: Australia, Indonesia, Japan, New Zealand, andTaiwan

• Disputes & Litigation Firms of the Year: Cambodia

Deloitte in Asia Pacific region includes approximately 120 plus offices, 600 partners and9,000 plus service professionals

Phone: +613 9671 7370Email: [email protected]: @DeloitteWebsite: Deloitte.com/tax



ASIA-PACIFIC

This document has been prepared solely for the purpose of publishing in the 2019 Tax Controversy Leaders guideand may not be used for any other purpose. This document and its contents may not be reproduced, redistributedor passed on, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written con-sent.Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of memberfirms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms arelegally separate and independent entities. DTTL does not provide services to clients. Please seewww.deloitte.com/about to learn more.Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates thatprovide legal services outside of the US. For legal, regulatory and other reasons, some member firms, including theUS member firm, do not provide legal services.Certain services may not be available to attest clients under the rules and regulations of public accounting.Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax andrelated services. Our network of member firms in more than 150 countries and territories serves four out of fiveFortune Global 500® companies. Learn how Deloitte’s approximately 286,000 people make an impact that mattersat www.deloitte.com/about.This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its mem-ber firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, render-ing professional advice or services. Before making any decision or taking any action that may affect your financesor your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall beresponsible for any loss whatsoever sustained by any person who relies on this communication.© 2019. For information, contact Deloitte Touche Tohmatsu Limited.



ASIA-PACIFIC

What is the most significant change to yourregion/jurisdiction’s tax controversy/disputes legislationin the past 12 months?The most significant changes would be the introduction of thediscounted cash flow (DCF) method and the commensuratewith income standard.

What has been the most significant impact of thatchange?Japanese companies had a tendency to not transfer their IP.However, as a result of the above, it is anticipated that suchtransactions will increase in the future. In an M&A situation wemay see cases where a Japanese parent company would purchasethe IP held in a foreign subsidiary before the subsidiary is pur-chased. In such cases, it would be necessary to look into a bilat-eral Advanced Pricing Agreement (APA) and maintain properdocumentation.

How do you anticipate that change impacting your workand the market moving forwards?We anticipate more opportunities to assist in formulating anddocumenting a reasonable DCF methodology, as well as assist-ing the examination of bilateral APAs, as noted above.

How has this changed the way you offer tax advice?Because it is necessary to have proper defence from a tax per-spective, we will work not only with the accounting departmentof companies, but also in cooperation with other departmentsto spread understanding and explain the importance of defencefrom a tax perspective to business units and units in charge ofintellectual property.

INTERVIEW

Hiroki YamakawaDeloitte Japan

ASIA-PACIFICRegional interview

Hiroki Yamakawa, a partner with Deloitte Japan, answers questions about recent legislativechanges in Japan.



ASIA-PACIFIC

Interview

What potential other legislative changes are on the horizon that you think willhave a big impact on your region/jurisdiction? Next year there will be consideration as to whether Base Erosion Profit Shifting (BEPS)Action 12: Mandatory Disclosure Rules will be implemented in Japan. Further, if the discus-sions on BEPS Action 1: Digital Economy can be wrapped up by the end of next year, weanticipate that the tax authority would move quickly to implement into legislation.

What are the potential outcomes that might occur if those changes areimplemented?In relation to the discussion around BEPS Action 12, we would anticipate further discussionon corresponding general anti-avoidance rule (GAAR) provisions. However, we would notanticipate any immediate legislative changes that would have significant impacts from aninternational tax perspective, and if GAAR provisions are implemented the impacts wouldmainly be on aggressive tax planning. Regarding BEPS Action 1, if as a result of the discus-sions on marketing intangibles the scope of what is considered to be a marketing intangibleis broadly defined (i.e. is wide in scope) this could lead to changes in the transfer pricingmethodology.

Do you think that change will have a positive effect on both your practice and thewider regional/jurisdictional market?Based on the movement towards marketing intangibles and a new type of nexus, there willbe wide ranging impacts on how income is attributed. While it depends on the scope of whatis captured under these new ideas, they represent a significant change conceptually and there-fore will certainly impact our practice.

How are issues surrounding the taxation of the digital economy affecting yourjurisdiction?Outbound businesses are affected as they consider whether to reflect the marketing intangi-ble concept into their B2C business models, and if so, how it will be reflected. Concerning anew type of nexus, how much of an issue and how serious this becomes will depend on howIndia and other countries move forward with the scope of what would be captured. Forinbound companies, it is anticipated that platform companies, beginning with GAFA(Google, Apple, Facebook, Amazon), will be impacted as they are faced with challenges fromthe tax authority.

What is the tax authorities’ approach to tax auditing?From July 2018, transfer pricing cases with the Japanese tax authority have dramaticallyincreased in number and intensity. Particularly with a focus on inbound businesses, the taxauthority is thoroughly reviewing country-by-country and local file documentation, andchoosing audits of companies based on these reviews. As regarding taxpayers with a relativelyminor presence in Japan, which were not the subject of TP audits in the past, the tax author-ity is reviewing their local files in anticipation of a potential TP audit.



ASIA-PACIFIC

How has tax advice adapted to the changing tax audit approach, and how do youexpect it to change further?As taxation measures are strengthening around the world, not just in Japan, it is increasinglynecessary for Japanese companies to monitor the situation of overseas audits, in addition tothose in Japan. In response to the needs of companies dealing with audits in Japan we areexpanding our tax controversy team and actively contributing by using our audit trackingsoftware to collect information and understand the situation and trends of recent audits. Forinbound companies, we are using the ever-strengthening Deloitte network to cooperate withthe Deloitte firm in the parent company jurisdiction to provide support from both sides.Further, in an effort to boost the audit defense capability of our clients, we are increasinglyproviding advice on how to enhance related party contracts, as well as advising on TP policiesand mechanisms to confirm that actual pricing figures fall within a specified target range.

For disputes that require litigation (pre-litigation, and court proceedings), howare matters evolving in your jurisdiction/region? Are pre-court settlementsbecoming easier, and why?During tax audits, the Japanese tax authority encourages voluntary amendments by the tax-payer and there is a tendency for matters to be settled in the audit so litigation does not gen-erally occur. As a result of taxpayers here tending not to challenge the authority, there arevery few tax disputes in Japan, and this trend has not changed significantly in recent years.We plan to look at potential changes going forward as the scrutiny from tax audits increases.On the other hand, at the National Tax Tribunal a tax practitioner has been added as a

member of the council, which both increases their level of proficiency and the possibility fora more rational outcome. For aggressive cases there may be a tendency to move to the courtwithout reaching a conclusion favorable for taxpayers at the tribunal level.Regarding pre-court settlements, there is no official settlement procedure, though cases

tend to be settled in fact during the audit process.


Interview



ASIA-PACIFIC

Fiona CraigDeloitte Australia

Grosvenor Place 225 George Street,Sydney, NSW 2000, AustraliaTel: +61 2 9322 [email protected]

James FabijancicDeloitte Australia

Deloitte Legal Pty Ltd, 550 BourkeStreet, Melbourne, VIC 3000, AustraliaTel: +61 3 9671 [email protected]

Jonathon LeekDeloitte Australia

Brookfield Place Tower 2 123 StGeorges Terrace, Perth, WA 6000,AustraliaTel: +61 8 9365 [email protected]

Jacques van RhynDeloitte Australia

Level 25 Riverside Centre 123 EagleStreet, Brisbane, QLD 4000, AustraliaTel: +61 7 3308 [email protected]

Bill BaiDeloitte China

45/F Metropolitan Tower 183 NanjingRoad Heping District Tianjin 300051,PRCTel: +86 22 [email protected]

Bradley EdwardsDeloitte Australia

Level 25 & 26 Riverside Centre 123Eagle Street, Brisbane, QLD 4000,AustraliaTel: +61 2 9322 [email protected]

Greg JanesDeloitte Australia

Deloitte Touche Tohmatsu 550 BourkeStreet, Melbourne, VIC 3000, AustraliaTel: +61 3 9671 [email protected]

Christopher ThomasDeloitte Australia

Grosvenor Place 225 George Street,Sydney, NSW 2000, AustraliaTel: +61 2 8260 [email protected]

Kimsroy ChhivDeloitte CambodiaVattanac Capital Tower, P.O. Box 1150,Floor 8, Unit 8, #66 Preah MonivongBlvd, Sangkat Wat Phnom, PhnomPenh, CambodiaTel: +855 23 963 [email protected]/kh/

Lian-Tang HeDeloitte China

12/F, China Life Financial Center No.23, Zhenzhi Road Chaoyang District,Beijing 100026, PRCTel: +86 10 [email protected]



ASIA-PACIFIC

Mike JiangDeloitte China

30/F Bund Center 222 Yan An RoadEast, Shanghai, 200002, ChinaTel: +86 21 [email protected]

Sam LiDeloitte China

35/F One Pacific Place 88 Queensway,Hong Kong, ChinaTel: +852 [email protected]

Frank TangDeloitte China

43/F World Financial Center, 188Minzu Road, Yuzhong District,Chongqing 400010, PRCTel: +86 23 [email protected]

Andrew ZhuDeloitte China

12/F China Life Financial Center No.23 Zhenzhi Road Chaoyang District ,Beijing 100026, PRCTel: +86 10 [email protected]

Neeru AhujaDeloitte India

7th Floor, Building 10, Tower B DLFCyber City Complex, DLF City Phase IIGurgaon - 122 002, Haryana, IndiaTel: +91 11 679 [email protected]

Eunice KuoDeloitte China

9/F Bund Center 222 Yan An RoadEast, Shanghai, 200002, ChinaTel: +86 21 [email protected]

Victor LiDeloitte China

13/F China Resources Building 5001Shennan Road East, Shenzhen,518010, ChinaTel: +86 755 [email protected]

Julie ZhangDeloitte China

12/F, China Life Financial Center, No.23, Zhenzhi Road, Chaoyang District,Beijing, Beijing 100026, PRCTel: +86 10 [email protected]

Philip WongDeloitte China

35/F One Pacific Place 88 Queensway,Hong Kong, ChinaTel: +852 [email protected]

C A GuptaDeloitte India

Indiabulls Finance Centre, Tower 3,28th Floor, Senapati Bapat Marg,Elphinstone Road(W), Mumbai,Maharashtra 400013, IndiaTel: +91 22 6185 [email protected]



ASIA-PACIFIC

Manisha GuptaDeloitte India

Indiabulls Finance Centre,Tower 3,28th Floor, Senapati Bapat Marg,Elphinstone Road(W), Mumbai,Maharashtra-400013, IndiaTel: +91 22 6185 [email protected]

KarishmaPhatarphekarDeloitte IndiaIndiabulls Finance Centre, Tower 3, 28thFloor, Senapati Bapat Marg, ElphinstoneRoad(W), Mumbai, Maharashtra 400013,IndiaTel: +91 22 6815 [email protected]

K R SekarDeloitte India

Prestige Trade Tower, Level 19, 46,Palace Road, High Grounds, Bengaluru- 560001, Karnataka, IndiaTel: +91 80 6188 [email protected]

Yan HardyanaDeloitte Indonesia

The Plaza Office Tower, 32nd Floor Jl.M.H. Thamrin Kav 28-30, Jakarta, DKIJakarta 10350, IndonesiaTel: +62 21 5081 [email protected]/id

Heru SupriyantoDeloitte Indonesia


SubramanianKrishnamaniDeloitte India

19th Floor, 46 - Prestige Trade TowerPalace Road, High Grounds,Bengaluru, Karnataka 560001, IndiaTel: [email protected]

Rohan PhatarphekarDeloitte India

Indiabulls Finance Centre, Tower 3,28th Floor, Senapati Bapat Marg,Elphinstone Road(W), Mumbai,Maharashtra-400013, IndiaTel: +91 22 6185 [email protected]

Rajesh SrinivasanDeloitte India

52, Venkatanarayana Road, ASV NRamana Tower, T Nagar, Chennai-600017, Tamil Nadu, IndiaTel: +91 44 6688 [email protected]

Cindy SukimanDeloitte Indonesia


Turmanto TurmantoDeloitte Indonesia

The Plaza Office Tower, 32nd Floor Jl.M.H. Thamrin Kav 28-30, Jakarta, DKIJakarta 10350, IndonesiaTel: +62 21 5081 [email protected]/id/en.html



ASIA-PACIFIC

Yang Ho KimDeloitte Japan

Local office address:MarunouchiNijubashi Building 3-2-3 MarunouchiChiyoda-ku, Tokyo, 1008362, JapanTel: +81 3 6213 [email protected]/jp/en/tax

Jun SawadaDeloitte Japan

Marunouchi Nijubashi Building 3-2-3Marunouchi Chiyoda-ku, Tokyo,1008362, JapanTel: +81 3 6213 [email protected]

Senthuran ElalingamDeloitte Malaysia

Level 16, Menara LGB, 1 Jalan WanKadir, Taman Tun Dr. Ismail, KualaLumpur, 60000, MalaysiaTel: +60 3 7610 [email protected]/my

Chandran RamasamyDeloitte Malaysia


Patrick McCalmanDeloitte New Zealand

Level 12, 20 Customhouse Quay,Wellington, 6011, New ZealandTel: +64 [email protected]

Yutaka KitamuraDeloitte Japan

Local office address:MarunouchiNijubashi Building 3-2-3 MarunouchiChiyoda-ku, Tokyo, 1008362, JapanTel: +81 3 6213 [email protected]/jp/en/tax

Hiroki YamakawaDeloitte Japan

Marunouchi Nijubashi Building 3-2-3Marunouchi Chiyoda-ku, Tokyo,1008362, JapanTel: +81 3 6213 [email protected]/jp/en/tax

Theresa GohDeloitte Malaysia

Level 16, Menara LGB, 1 Jalan WanKadir, Taman Tun Dr. Ismail, KualaLumpur, 60000, MalaysiaTel: [email protected]/my

Tan Eng YewDeloitte Malaysia


Campbell RoseDeloitte New Zealand

Level 18 Deloitte Centre 80 QueenStreet, Auckland, 1010, New ZealandTel: +64 [email protected]



ASIA-PACIFIC

Walter, Jr. AbelaDeloitte Philippines

19th Floor Net Lima Plaza 5th Avenuecorner 26th Street Bonifacio GlobalCity, Taguig, 1634, PhilippinesTel: +63 2 581 [email protected]/ph

Fredieric LandichoDeloitte Philippines

19th Floor Net Lima Plaza 5th AvenueCorner 26th Street Bonifacio GlobalCity, Taguig - 1634, PhilippinesTel: +63 2 581 [email protected]/ph

Daniel HoDeloitte Singapore

6 Shenton Way #33-00 OUEDowntown 2 Singapore, 068809Tel: +65 6216 [email protected]/sg

Low Hwee ChuaDeloitte Singapore

6 Shenton Way #33-00 OUEDowntown 2, Singapore, 068809Tel: +65 6216 [email protected]/sg

See Jee ChangDeloitte Singapore

6 Shenton Way #33-00 OUEDowntown 2, Singapore, 068809,SingaporeTel: +65 6216 [email protected]/sg/en.html

Carlo NavarroDeloitte Philippines

19th Floor Net Lima Plaza 5th Avenuecorner 26th Street Bonifacio GlobalCity, Taguig, 1634, PhilippinesTel: +63 2 581 [email protected]/ph/en.html

Richard LapresDeloitte Philippines

19th Floor Net Lima Plaza 5th AvenueCorner 26th Street Bonifacio GlobalCity, Taguig - 1634, PhilippinesTel: +63 2 581 [email protected]/ph

Lee Tiong HengDeloitte Singapore


Shantini RamachandraDeloitte Singapore


Michael VeltenDeloitte Singapore

6 Shenton Way #33-00 OUEDowntown 2, Singapore, 068809,SingaporeTel: +65 6531 [email protected]/sg



ASIA-PACIFIC

Jee Won KwonDeloitte Korea

9F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g Seoul, Seoul 07326,South KoreaTel: [email protected]

Seong Kwon SongDeloitte Korea

9F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g, Seoul 07326, SouthKoreaTel: [email protected]

Thomas ChenDeloitte Taiwan

20F, Taipei Nan Shan Plaza, No. 100,Songren Rd., Xinyi Dist., Taipei 11073,TaiwanTel: +886 2 27259988; [email protected]

Susan LeeDeloitte Taiwan

20F, Taipei Nan Shan Plaza, No. 100,Songren Rd., Xinyi Dist., Taipei 11073,TaiwanTel: +886 2 27259988 ; [email protected]

Nam Hyuk ParkDeloitte Korea

4F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g, Seoul, Seoul 07326,South KoreaTel: [email protected]

Robert ChenDeloitte Taiwan


Kevin LaiDeloitte Taiwan

3F, China Steel Building, No. 88Chenggong 2nd Road, Kaohsiung80661, TaiwanTel: +886 7 5301888 ; [email protected]

Robin LinDeloitte Taiwan


Kyu-Bum ChoDeloitte Korea

4F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g, Seoul, Seoul 07326,South KoreaTel: [email protected]

Sunyoung KimDeloitte Korea

12F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g Seoul, Seoul 07326,South KoreaTel: [email protected]



ASIA-PACIFIC

Ye-Hsin LinDeloitte Taiwan

20F, Taipei Nan Shan Plaza, No. 100,Songren Rd., Xinyi Dist., Taipei 11073,TaiwanTel: +886 2 27259988; [email protected]

KorneekaKoonachoakDeloitte Thailand

AIA Sathorn Tower, 23rd – 27th Floor,11/1 South Sathorn Road, Yannawa,Sathorn, Bangkok 10120, ThailandTel: +662 034 [email protected]/th

Minh BuiDeloitte Vietnam

15th Floor, Vinaconex Tower, 34 LangHa Street, Dong Da District, Hanoi,VietnamTel: +84 24 [email protected]/vn

Hoang PhanDeloitte Vietnam

18 Floor, Times Square Building 57-69FDong Khoi Street, District 1, Ho ChiMinh City, VietnamTel: +84 28 3521 [email protected]/vn

Glendy YuanDeloitte Taiwan


WannaSuteerapornchaiDeloitte Thailand

AIA Sathorn Tower, 23rd – 27th Floor,11/1 South Sathorn Road, Yannawa,Sathorn, Bangkok 10120, ThailandTel: +66 2034 [email protected]/th

Tuan BuiDeloitte Vietnam

15th Floor, Vinaconex Tower, 34 LangHa Street, Dong Da District, Hanoi,VietnamTel: +84 24 [email protected]/vn



ASIA-PACIFIC

BiographyPaul is one of Australia’s leading tax controversy and disputeresolution advisors. He has over 20 years tax experience andspent over half his career as a senior ATO executive, includingAssistant Commissioner and ATO JITSIC delegate focused onmultinational audits conducted by various revenue authoritieswhile based in Washington DC. Paul brings an unparalleledunderstanding of the ATO and its approach to audits. He usesthis knowledge to resolve tax disputes on the best possible termsfor his clients.

Recent matter highlightsPaul was the lead advisor to a global energy company involved ina cross border financing dispute. He led the collation of evidence,appeared at the GAAR Panel and led the negotiations. Thepotential adjustment was $1.5b and 50% penalties. Paul achievednegotiated settlement and no penalties were imposed. In anothermatter, Paul played a lead role in audit defence and settlementnegotiations for an ASX listed company. The potential adjustmentwas $500m and was later resolved on favourable terms with nopenalties.

Practice areasAudit defence, Dispute resolution, Pre-litigation, MAPs, Controversy management

Association membershipsThe Tax Institute (Australia) Chartered Accountants (Australia & New Zealand)

Academic qualificationsMasters of Taxation Law

AUSTRALIA

Paul McCartin

Partner, Tax Controversy &Dispute Resolution

PricewaterhouseCoopers

Melbourne+61 [email protected]/tax-controversy.html



ASIA-PACIFIC

Bar admissions: Admitted as a Solicitor and Barrister in theSupreme Court of New South Wales Entered in the High Courtof Australia Register of Practitioners

BiographyMore than thirty years of experience in Australian taxation law.Specialising in resolution of disputes with Federal and StateRevenue authorities.Management of audits and negotiations on behalf of taxpayers,conduct of tax litigation in the Administrative Appeals Tribunal,State and Federal Courts.

Recent matter highlights• Commissioner of Taxation v Financial Synergy Holdings PtyLtd [2016] HCATrans 232 (7 October 2016

• John Holland Group Pty Ltd v FCT [2015] FCAFC 82 • Adams Bidco Pty Ltd v Chief Commissioner of StateRevenue [2018] NSWSC 735

Practice areasAudit defence, Pre-litigation, Litigation, Controversy management, International tax advisory

Sector specialisationsAutomotive, Consumer goods and services, Financial services, Food and beverage, Gaming,Industrials, Media, Mining, Pharma and life sciences, Tech and telecoms

Association membershipsChartered Tax Adviser, Australia

Academic qualificationsLL.B, QUTLL.M (Hons), SydneyGrad Dip Legal Practice Law, College of Law NSW

Australia

Paul McNab

Tax Controversy Partner

PricewaterhouuseCoopersAustralia

Sydney+61 [email protected]/tax-controversy.html



ASIA-PACIFIC

BiographyEddy is a Tax Lawyer and Partner in the Tax ControversyPractice in Australia. He leads major complex audit defence formultinational and large private businesses. Areas of focus includeanti avoidance, transfer pricing, WHT, financing and IP cases.

Recent matter highlights• Eddy has assisted clients under audit in a variety of industrysectors including Financial Services, infrastructure, FMCG,Technology and Real Estate.

• He has also successfully resolved debt pricing, anti avoidance,transfer pricing cases involving material amounts of tax andpenalties at stake.

• Eddy has also published papers on evidence in tax disputes,anti avoidance, and taxation of intellectual property matters.

Practice areasAudit defence, Dispute resolution, Pre-litigation, MAPs/ADRs,Controversy management

Association membershipsMember of the Law Society of NSWMember of the State Council of the NSW Tax Institute of AustraliaBoard Member of the National Council of the Tax Institute of Australia

Academic qualificationsBachelor of Business, Bachelor of Law – University of Technology SydneyMasters of Taxation, University of Sydney

Australia

Eddy Moussa

Partner

PricewaterhouseCoopersAustralia

+61 [email protected]



ASIA-PACIFIC

BiographySimon Rooke is a legal partner in PwC’s Melbourne tax contro-versy practice. Simon specialises in working with clients toresolve complex and sometimes intense disputes with theAustralian Taxation Office (ATO). Simon has over 20 years oftaxation experience, including 12 years in international tax andM&A tax, which have led to several significant ATO investiga-tions, up to and including litigation.

Recent matter highlightsSimon has extensive experience in assisting clients manage ATOdisputes, including ATO risk reviews, ATO audits, settlementnegotiations, alternative dispute resolution and litigation.Simon’s approach is to take a respectful and educative approachto ATO investigations, while rigorously protecting a client’srights (both at law and under ATO practice and policy).Simon’s experience has also ranged from navigating through theincreasingly aggressive ATO approach to information gathering,to seeking private binding rulings on contentious tax matters, to assisting companies with‘ATO readiness’ during initial public offerings, to litigation against the ATO when otheravenues of dispute resolution are exhausted.

Practice areasRestructuring, Transactions, M&A, Financial services, Corporate taxes, Audit defence, Disputeresolution, Litigation, Controversy management, Tax consulting, International tax advisory

Sector specialisationsAutomotive, Consumer goods and services, Financial services, Pharma and life sciences

Association membershipsLaw Council of Australia, Law Institute of AustraliaChartered Accountants Australia and New ZealandTax Institute

Academic qualificationsBachelor of Laws (LLB); Bachelor of Commerce (B.Com), University of Tasmania, 1994Practical Legal Training, College of Law, 2008

Australia

Simon Rooke

Partner

PricewaterhouseCoopersAustralia

+61 (3) 8603 [email protected]



ASIA-PACIFIC

Judy Sullivan is a legal partner – tax controversy – and thenational leader for tax litigation and alternative disputeresolution (ADR) at PwC.Judy holds a BEc/LLB from the Australian National

University and LLM from Sydney University. She is a memberof the advisory panel to the Board of Taxation and a member ofthe Australian Taxation Office (ATO) dispute resolution work-ing group. She is also a chartered tax adviser (The TaxationInstitute) and on the High Court’s roll of legal practitioners.Judy is a leading tax lawyer and litigator in Australia. She

joined PwC in 2013, and was formerly the tax partner leadingthe Sydney tax disputes practice at top tier law firm King &Wood Mallesons.For over 25 years, Judy has guided multinationals, major

corporates and high-net-worth individual clients through taxreviews, audits, negotiations and litigation across all areas offederal and state taxes. She has run or worked on seminalAustralian tax cases in the Administrative Appeals Tribunal,Federal Court and High Court, as well as the NSW SupremeCourt. She instructs and works with the leaders of Australia’stax bar.With the ATO’s shift to ‘real time’ engagement with taxpayers, Judy focuses on opportu-

nities to work closely with the ATO and taxpayers to bring them together to achieve earlyengagement and resolution of disputes through ADR processes including settlement discus-sions, mediation and early neutral evaluation.As cross-border transactions and corporate structures are under intense ATO scrutiny,

(with significant additional ATO resources now applied to ‘taskforces’), multinationals andmajor corporates must prepare to defend potential disputes in relation to their structures,transactions and pricing Judy has extensive expertise across these topics and other important areas.Judy also has a keen interest in pro bono matters, and has won the New South Wales Law

Society Award for her pro bono work representing artists and establishing their practices asbusinesses for taxation purposes. She also leads PwC’s charities and not-for-profits practice inAustralia.

Australia

Judy Sullivan

Legal partner – tax controversyand national leader for taxlitigation and alternative disputeresolution

PwC

Barangaroo, Sydney+61 2 8266 [email protected]/taxcontroversy



ASIA-PACIFIC

Biography Angela is Australian & ASPAC lead partner for tax dispute res-olution and controversy, representing large corporate taxpayersacross the tax dispute continuum (transaction stage, reviews,audits, objections and litigation), drawing on extensive experi-ence running significant litigation for the Commissioner ofTaxation, to efficiently resolve disputes.

Association memberships• Chartered Tax Adviser – The Tax Institute of Australia• Member – Law Institute of Victoria• Law Council of Australia – Member of Victorian TaxCommittee

• University of Melbourne – Member of Tax Advisory Board(Melbourne Law School)

Academic qualifications• Bachelor of Laws & Bachelor of Arts• Monash University (1994)

Recent matter highlights Angela currently acts for taxpayers in several significant audit/litigation matters including aAUD$1 billion ATO audit of an infrastructure stapled structure (specific and general anti-avoidance provisions, deductibility of expenses between related parties and investors (domes-tic /offshore)), mineral royalty litigation for the mining industry, reviews for transport andtechnology clients, large ATO audits of automotive and commodities clients (TP / anti-avoidance).

Practice areas • Audit defence• Dispute resolution• Pre-litigation• MAPs/ADRs• Litigation

Sector specialisations Automotive, Banking, Consumer goods and services, Energy, Gaming, Industrials, Mining,Natural resources, Oil and gas, Pharma and life sciences, Tech and telecoms, Transport,Utilities

Australia

Angela Wood

Australian and ASPAC Leader –Tax Dispute Resolution &Controversy

KPMG Law

Melbourne+61 400 988 [email protected]/au/en/home/services/tax/advisory/dispute-resolution-controversy.html



Australia

Howard AdamsErnst & Young Australia

Rick AsquiniKPMG Australia

Michael BerstenNew Chambers

Sarah BlakelockSlaughter and May

David Bloom QCNew Chambers

Michael CloughKing & Wood Mallesons

Fiona CraigDeloitte Australia See page 109

Gregory Davies QCChancery Chambers

John de Wijn QCOwen Dixon Chambers West

Aldrin De ZilvaGreenwoods & Herbert Smith Freehills

David DrummondKPMG Australia

Sarah DunnKPMG Australia

Bradley EdwardsDeloitte Australia See page 109

James FabijancicDeloitte Australia See page 109

Tony FrostGreenwoods & Herbert Smith Freehills

Stewart GrieveJohnson Winter & Slattery

Cameron HansonHerbert Smith Freehills

Dixon HearderBaker McKenzie

Andrew HirstGreenwoods & Herbert Smith Freehills

ASIA-PACIFIC



Australia

Ross HockingKPMG Australia

Lyndon JamesPricewaterhouseCoopers Australia

Greg JanesDeloitte Australia See page 109

Ashley KingPricewaterhouseCoopers Australia

Chris KinsellaMinterEllison

Angelina LaganaKPMG Australia

Jonathon LeekDeloitte Australia See page 109

Nicholas MavrakisClayton Utz

Paul McCartinPricewaterhouseCoopers Australia See page 116

Geoff McClellanHerbert Smith Freehills

Carmen McElwainMinterEllison

Paul McNabPricewaterhouseCoopers Australia See page 117

Craig MilnerCorrs Chambers Westgarth

Alan MitchellHerbert Smith Freehills

Eddy MoussaPricewaterhouseCoopers Australia See page 118

Peter MurrayHall & Wilcox

Adrian O’ShannessyGreenwoods & Herbert Smith Freehills

Ben OpieKPMG Australia

Trevor PascallCrowe Horwath Australia

ASIA-PACIFIC



Australia

Alex PatrickKPMG Australia

Hugh PaynterHerbert Smith Freehills

Chris PeadonNew Chambers

Michael PerezKing & Wood Mallesons

Mark PooleKPMG Australia

Mark Richmond SCEleven Wentworth Chambers

Simon RookePricewaterhouseCoopers Australia See page 119

John SalvarisKPMG Australia

Judy SullivanPricewaterhouseCoopers Australia See page 120

Brendan Sullivan SCTenth Floor Chambers

Tom Thawley SCNew Chambers

Christopher ThomasDeloitte Australia See page 109

Jerome TseKing & Wood Mallesons

Jacques Van RhynDeloitte Australia See page 109

Chris VittasBDO Australia

John WalkerBaker McKenzie

Paul WenkHerbert Smith Freehills

Angela WoodKPMG Australia See page 121

CAMBODIA

Kimsroy ChhivDeloitte See page 109

ASIA-PACIFIC



ASIA-PACIFIC

Xiaoying Chen is the north regional leader of tax controversyservices (TCS) at the Beijing office of PwC China. She is a cer-tified tax agent of the PRC. She has been providing tax contro-versy services related to complicated tax disputes since joiningPwC China in 2001. She leads a TCS team comprising manyexperienced former tax officials and senior tax managers.Before joining PwC China, Xiaoying worked in the State

Administration of Taxation (SAT) for 16 years since 1985.During this period, she participated in the research, draftingand amendments of a series of important tax legislation propos-als, and accumulated tremendous experience in tax collectionmanagement. She is an expert in the legislative thinking,detailed regulations and historical development of China’s taxlaws and regulations and is familiar with tax administration, taxaudit’s methodology and procedures.Since joining PwC China, Xiaoying has actively continued

her research and advisory role on tax laws and regulations withthe Ministry of Finance (MoF) and the SAT. She providesimportant advice to the MoF and the SAT on some vital tax regulations on M&A, and proac-tively drives the issuance of some regulations relating to international taxation.Xiaoying is one of the few top level tax experts, even in PwC China, with the experience

of both the SAT and top-level international accounting firms. She accumulated extensiveexperience in M&A tax disputes and the related implementation. She assisted a client in get-ting the first special tax treatment in a M&A deal in China, and assisted various foreign insti-tutions/funds in negotiating various tax related matters with all levels of tax authorities forexit deals from China. Xiaoying also assisted the first REITs issued in China to negotiate itstax treatments with all levels of tax authorities, and set an excellent example for all laterREITs’ tax-related structures issued in China. In addition, Xiaoying acted as a tax adviser forBeijing-Zhangjiakou, applying for the 2022 Winter Olympic Games. She assisted the relatedtaxpayers to solve tax issues related to the transformation from business tax to value-addedtax (B2V), and related disputes upon China implementing the B2V reform nationwide. Sheis the tax adviser of many state-owned enterprises and domestic private enterprises. Shehelped a lot of famous domestic private enterprises in getting listed in overseas capital mar-kets, offshore M&A, and privatisation delisting.

CHINA

Xiaoying Chen

North region leader

PwC China

Beijing+86 10 6533 [email protected]/taxcontroversy



ASIA-PACIFIC

Spencer Chong is a tax partner of PwC China and is the taxmarkets leader of PwC Hong Kong and China. Spencer is alsothe founder and leader of the transfer pricing services practicefor greater China. Under Spencer’s leadership, PwC China/Hong Kong was awarded the ‘China Transfer Pricing Firm ofthe Year’ award in 2006 and ‘Hong Kong Transfer Pricing Firmof the Year’ in 2009 by International Tax Review. Before join-ing the firm, Spencer worked at the Hong Kong InlandRevenue Department. He has more than 25 years of experiencein tax and transfer pricing consulting.Spencer has been involved in numerous tax and transfer pric-

ing projects. He is experienced in assisting investors in formu-lating structuring defence and negotiation strategies andfronting such negotiations in difficult tax audit defence cases.He provides value-added advice in global/regional structuringstudies aimed at achieving companies’ business and profit align-ment goals.Spencer is a regular speaker on Chinese tax and transfer pric-

ing issues and trends for professional conferences and contributes frequently to professionalpublications on the subject.Spencer manages the firm’s ‘high potential cities’ initiative, as well as managing the legal

practice. On top of his involvement in securing the first five advance pricing agreements(APAs) negotiated in China, Spencer assisted a prominent South Korean multinational groupin securing the first bilateral APA between South Korea and China, assisted a Danish multi-national group in securing the first bilateral APA between China and Europe, and was alsoinvolved in the first bilateral APA between China and Singapore.

China

Spencer Chong

National tax partner

PwC China

Shanghai+86 (21) 2323 [email protected]/taxcontroversy



ASIA-PACIFIC

William Fan is a partner with the PwC Shanghai Tax ControversyServices team. Currently, he works primarily on providing taxcontroversy services related to complicated tax disputes. Before joining PwC China, William worked in the Shanghai

Tax Bureau for more than 10 years and gained rich experiencesin the area of tax audit. During that time, William had taken aleading role in solving several sensitive and important tax auditcases in sectors such as financial services, logistics services, retail,real estate, etc. He was a member of internal audit group of theState Administration of Taxation (SAT) and a member of talentpool major in audit. In addition, he is a specialist in digital taxaudit and shares his experience and viewpoints within the taxauthorities’ network via national and internal major publications.He currently provides tax services for both multinational and

domestic clients in relation to corporate relocation, financialsubsidy application, efficient holding structure planning, dealstructuring, tax audit, etc. As an ex-official from the tax bureau, William has maintained

and developed sustainable relationships with various authorities in Shanghai and nearby areas.With his previous experience with the Shanghai tax authorities, he is equipped with the capac-ity to build up a solid base in dealing with the various kinds of tax audits and disputes facingtaxpayers.William has a Masters Degree in Finance from Fudan University. He is also a member of

the Chinese Institute of Certified Tax Agent and CFA institute Shanghai Branch.

China

William Fan

Central region tax partner

PwC China

+86 21 2323 [email protected]/taxcontroversy



ASIA-PACIFIC

Frank Gao is a tax partner specialising in tax controversy service(TCS) based in PwC, Shanghai Office. With 20 years’ experi-ence in the China State Administration of Taxation (SAT) andaccumulated practices of numerous tax dispute projects, he isdedicated in assisting multinational and domestic companies toachieve expected outcomes. Before joining PwC in 2017, Frank was a director in the

SAT, and took a leading role in tax policy making and adminis-tration in a variety of international taxation areas, includinganti-tax avoidance and evasion (CRS related), IIT (foreign)administration, nonresident taxation, treaty application, etc. Hewas involved in handling a number of influential tax avoidancecases and provided policy instructions to in-charge tax authori-ties. For his rich experience and capability, Frank was delegatedto be the first SAT representative to the JISIC London office in2008, and led SAT’s G20 BEPS project since 2013 with a focuson digital economy.As a PwC TCS member, Frank’s expertise in international

tax area and in-depth understanding of China tax policies addstremendous value to the PwC team for providing effective problem-solving strategies and itsimplementation for clients. Meanwhile, he actively continued his unique role in the researchand advisory of tax laws and regulations and provided fairly constructive reference to SAT andother government departments on themes such as BEPS, non-resident taxation and M&A taxrules. Frank has provided extensive controversy service in a wide range of areas, including M&A

STT application, applying treaty benefits or preferential income tax policies, defence againstIIT auditing or GAAR dispute cases, and solving complicated tax compliance controversy.His unique strength in technical capability and national wide communication network largelypromoted the successful resolution of many tough dispute issues, and gained high recogni-tion and appreciation from clients.Frank received his Master’s degree in economics from Yatsen University, Master of

Taxation from Golden Gate University, and his PhD in Economics from Renmin Universityof China (RUC), and is now an Adjunct Master’s Supervisor in RUC.

China

Frank Gao

Central region tax controversypartner

PwC China

Shanghai +86 21 [email protected]/taxcontroversy



ASIA-PACIFIC

Liang Gong is a tax controversy partner for PwC China, in theShanghai office, and leads the tax controversy practice in thecentral region for PwC China. He has more than 15 years’ expe-rience in providing China tax and business advisory services formultinational enterprises and domestic companies.Before joining PwC China, Liang had seven years of experi-

ence working in the Qingdao State Tax Bureau and gainedfirst-hand experience in VAT refund, tax audit and tax admin-istration issues. During that time, Liang was often called up bythe State Administration of Taxation (SAT) to join the task-force of many nationwide tax audits. Further, Liang shared hisexperience and viewpoints via articles in several national andprovincial journals. Liang has been dedicated to providingChina tax and business advisory services for his clients, and heis experienced in tax controversy services. His major industrialfocuses include manufacturing, FMCG and real estate, amongothers. Over the years, Liang has achieved various successfuloutcomes for his clients on tax controversy cases in a widerange of corporate restructuring, VAT, export refund, treatybenefits, tax audit defence and tax appeal cases.Liang’s capacity covers China tax and structure planning, tax negotiation, China indirect

tax, tax audit/investigation support, as well as others.Liang has an MBA from the University of Oxford, as well as a master’s degree in econom-

ics from Renmin University. He obtained his bachelor’s degree in economics with a major intaxation from Xiamen University. He also holds a CTA qualification.

China

Liang Gong

Central region tax controversypartner

PwC China

Shanghai+86 21 2323 [email protected]/taxcontroversy



ASIA-PACIFIC

Cathy Kai Jiang is a tax and China business advisory servicepartner and a China tax expert specialising in M&A due dili-gence review, deal negotiation support, tax restructuring, andpost-deal integration. She is also PwC’s partner-in-charge of thesouthern China domestic market initiative (DMI).Cathy lends her talents to both multinational and domestic

enterprises across many industries. She is on the frontline of thepractice as leader of the southern China DMI, as she has beenextensively involved in large numbers of A-share, overseas initialpublic offering projects, as well as China domestic outboundinvestment plans for China-based enterprises.As a member of the Institute of Certified Public Accountants

of China (CICPA), the Institute of Certified Public TaxationAccountants of China (CICTA), the Tax Institute of HongKong (HKTI), and the Association of Women Accountants,Cathy supports the practice by sharing her professional wisdomwith other practitioners. She is an editor committee member ofthe China Tax Intelligence (CCH). She also contributes to a wide range of professional insti-tution journals and newspapers. This was recognised by the China M&A Service Awards2014 that she was honoured with.Cathy has a close working relationship with Chinese policy makers and officials that comes

from her deep understanding of Chinese tax regulation and culture. She spends time in lead-ing or advising many local and regional tax authority initiatives on behalf of PwC, such asengaging the Chinese State Administration of Taxation (SAT) to implement China outboundtax administration and One Belt One Road strategies. In general, Cathy acts as the keystoneconnector between tax society and authorities.

China

Cathy Kai Jiang

South region partner

PwC

+852 2289 [email protected]/taxcontroversy



ASIA-PACIFIC

Long Ma is a tax partner within the tax controversy service prac-tice based in PwC China, Beijing office.Long has 15 years of experience in providing Chinese tax

and business advisory service to multinationals and Chineseenterprises. His extensive experience from a variety of assign-ments has covered a broad spectrum of industries and clienttypes. He started his professional tax career in 2000 and workedin the New York office of PwC US on a secondment during2006-2008 and was admitted as a partner to the Beijing officeof PwC China in July 2014.Long has close working relationships with key departments of

the Chinese State Administration of Taxation (SAT). His famil-iarity with SAT officials and in-charge officers at various provin-cial and municipal tax offices is effectively functioning as a com-munication channel between tax bureau and taxpayers. He hasassisted in resolving tough tax controversy issues and representedclients in tax negotiations in different locations in China. Hisleverage of the connections and resources he has within theChinese tax system is highly valued and appreciated by clients.In recent years, Long has extensively provided tax service in various fields, including appli-

cation for tax treaty benefits, mutual agreement procedures (MAP) involving both SAT andlocal level tax authorities, and defence against the application of the general anti-avoidancerule (GAAR) on cross-border transactions. He has engaged in various cases on tax auditdefence, and his proven track record of success in defence has been well recognised by hisclients. The experiences gained in these pursuits have proved a valuable resource for the taxcontroversy services team.Long graduated from the law school of Peking University with double bachelor’s degrees

in law and economics. He is a China certified tax agent.

China

Long Ma

North region tax partner

PwC China




ASIA-PACIFIC

Matthew Mui is national leader of national tax policy servicesand tax controversy services for PwC China.Matthew has nearly 30 years’ experience in providing China

tax and business advisory services to multinationals, Chinesedomestic and Hong Kong enterprises covering a wide range ofindustries. He started his professional tax career in Hong Kongand in July 2000 he was admitted as partner to the Beijing officeof PwC China.In his capacity as national tax policy services partner,

Matthew supports the practice nationally in respect of capturingthe latest tax and business regulatory developments, exploringtax efficiency opportunities for clients and sharing professionalexperience with the practice members.He has very close working relationships with all of the key

departments of the Chinese State Administration of Taxation(SAT). He is often invited to provide advice on the formationof state tax policies.Because of his familiarity with the key tax policymakers and

the processes behind Chinese tax policy making, Matthew has the advantage of appreciatingthe motivations behind tax policies and the approach of implementing the tax policies, and isin a strong position to communicate taxpayer views to the SAT. Thus, Matthew’s unique cal-ibre has proved to be very helpful in preventing, managing, and resolving tax controversiesbetween taxpayers and tax authorities in China.Matthew is fluent in Putonghua, English and Cantonese. He is a fellow member of the

Association of Chartered Certified Accountants and the Hong Kong Institute of CertifiedPublic Accountants. He is often recognised as a top adviser for China tax controversies,including in International Tax Review’s Tax Controversy Leaders guide.

China

Matthew Mui

National leader

PwC China

Beijing+86 (10) 6533 [email protected]/taxcontroversy



ASIA-PACIFIC

Andy Sun is a tax partner with the Central China practice ofPwC. He has more than 13 years of specialist tax experience inChina, providing tax controversy services and tax advice tomultinational and domestic companies. His focus provinces areShanghai, Jiangsu, Zhejiang, Anhui and Jiangxi.During his professional years, Andy has developed extensive

experience in providing tax and business consultation to manymultinational companies and domestic companies in China,including macro tax planning and tax function analysis for largescale groups, tax compliance and health check, investment plan-ning, merger and acquisition support, foreign exchange man-agement, operation model planning, etc. As the core teammember of the PwC Central Tax Controversy Service Team, heparticipated in and led various nationwide tax controversy nego-tiation projects facing different levels of tax authorities. Suchservices include:• Implementation support for group restructuring and busi-ness model optimisation (e.g. de-listing of red-chip companies in Shanghai, tax-free back-door listing in Jiangsu and the reorganisation of a group holding structure in Jiangsu), taxcontroversy services such as indirect transfer (exit support for a top-five real estate industryplayer), an application for tax-free special reorganisation treatments, etc.

• Tax planning and support for IPO projects, such as historical tax liability clearance, IPOstructure planning, obtain tax clearance certificates, etc.

• Settlement of tax controversies for specific tax issues, such as tax issues related to realproperty transfer, land value appreciation tax planning and negotiation, VAT specialinvoices issue, etc.

• Application for treaty benefit• Tax audit defence, tax administrative review and appeals, etc.Although he has no tax bureau background, he has established his personal network with-

in the PRC tax bureau from SAT to local district levels, from vice bureau directors to in-charge tax officials, including the international tax department, income tax department,turnover tax department, tax administration department, etc. His relationship covers almostall the Central China provinces and also includes North / South provinces such as Hainan,Guangdong, Guangxi, Yunnan, Gansu, Ningxia, Beijing, Tianjin, Liaoning, etc. Andy hasgathered extensive experience in serving a wide spectrum of clients in various industries,including real estate, construction, automobile, FMCG, internet, foreign contractor, chemi-cal, advertisement, industrial products, etc. Andy received his master degree from Shanghai Jiaotong University in China. He is also

a member of the Chinese Institute of Certified Tax Agent.

China

Andy Sun


PwC China

+86 21 2323 [email protected]/taxcontroversy



ASIA-PACIFIC

Hai Yan joined PwC China in January 2013. He is now a taxpartner specialised in tax controversy service in Beijing Office. Prior to joining PwC, Hai has been a tax official in China for

seven years. He has extensive experience in various areas, includ-ing tax treaty negotiation, large business administration, taxadministrative appeals and legal procedures, etc. He had work-ing experiences with state and local level tax authorities, includ-ing the Guangzhou State Tax Bureau, and International TaxDepartment of State Taxation Administration.In addition, Hai is recognised for his tax technical skills. He

has published several articles in international tax journals and isoften invited to speak at academic and business seminars, as wellas workshops organised by different tax authorities. He workswith tax authorities on various legislation and research projectsand actively shares practical issues and industry experiences withthe authorities.As a key member of PwC China’s tax controversy service

team, Hai has rich experience in dealing with different kinds oftax disputes, such as tax audit defense, anti-tax avoidance investigation, tax preferential treat-ment for reorganisation, and tax exemption or reduced rate application. He assists clientsdevelop appropriate dispute resolution strategy in order to lead the process towards the bestpossible outcome. He can always help clients build effective communication channels withtax authorities, which is vital for solving tax controversial cases.Hai received his LLM and LLB at Zhejiang University. He holds a China Legal

Professional Qualification Certificate.

China

Hai Yan

Tax partner

PwC China




ASIA-PACIFIC

Henry Zhu is a tax partner of PwC China, Suzhou office. Hehas been providing tax controversy services related to compli-cated tax disputes since he joined PwC. He is a member of theCertified Tax Agent and Chinese Institute of Certified PublicAccountants (CICPA).Henry has more than 20 years of experience in providing

China tax and international tax services to many well-knownMNEs and DMIs to resolve tax issues.Before joining PwC China, Henry worked in the Suzhou

Municipal State Administration of Taxation (SAT) for 16 years,focusing on transfer pricing auditing and large-scale enterprisesinspections. During this period, Henry was a core member ofthe transfer pricing team of Suzhou and Jiangsu SAT. He tookthe leading role in respect of jointly inspecting the nationaltransfer pricing of several industries. He also was a member ofthe SAT law-making team on special tax adjustments for draft-ing tax laws, regulations and policies.Because of his past practices, Henry transformed into an

expert on resolving the increasingly complicated tax disputes faced by multinational compa-nies in China supported by his legislative thinking, tax collection management and familiarityof tax audit’s methodology and procedures.Henry has been extensively involved in tax controversy issues such as transfer pricing,

equity valuation, indirect-share transferring, business restructuring, intra-group services, ben-eficial owner identification within a wide range of sectors including logistics, new energy andmanufacturing of consumer electronics, automotive, machinery and equipment, home appli-ances, real estate, etc.Henry used to provide professional trainings and technical workshops for various tax

authorities, and has established extensive and solid relationships with them.

China

Henry Zhu


PwC

Suzhou+86 (512) 6273 [email protected]/taxcontroversy



China

Bill BaiDeloitte See page 109

Henry ChanEY

Xiaoying ChenPwC See page 125

Spencer ChongPwC See page 126

Jon EichelbergerBaker McKenzie

Liang GongPwC See page 129

Lian-Tang HeDeloitte See page 109

Mike JiangDeloitte See page 110

Cathy Kai JiangPwC See page 130

Daisy KangPwC

Brendan KellyBaker McKenzie

Yimin KouPwC

Eunice KuoDeloitte See page 110

Nancy LaiBaker McKenzie

Lilly LiKPMG

Sam LiDeloitte See page 110

Victor LiDeloitte See page 110

Donald LinPwC

David LingKPMG

ASIA-PACIFIC



China

Jinghua LiuBaker McKenzie

Lewis LuKPMG

Long MaPwC See page 131

Matthew MuiPwC See page 132

Curtis NgKPMG

Peter NiZhong Lun Law Firm

Andy SunPwC See page 133

Frank TangDeloitte See page 110

Jane WangPwC

Jason WenBaker McKenzie

Janet XuPwC

Julie ZhangDeloitte See page 110

Andrew ZhuDeloitte See page 110

Henry ZhuPwC See page 135

ASIA-PACIFIC



ASIA-PACIFIC

Karen is the tax partner of PwC Hong Kong. She has more than15 years of experience in tax consulting, assisting clients inresolving Tax Controversy cases with the Hong Kong InlandRevenue Department.Karen provides tax controversy services and business advice

to local, regional, and multinational clients. She specialises inthe industries of apparel and electronic manufacturing, pharma-ceutical, general trading, sourcing, financial services, and assetmanagement.Over the years, she has assisted companies and individuals in

dealing with prolonged tax disputes, in particular, field auditand investigation cases. Karen has also conducted tax advisoryassignments such as group restructuring, inter-company feearrangement, and post-implementation health checks using thetax audit methodology. Karen is a regular speaker at seminars and events organised

by various chambers and professional bodies. Karen is a fellow member of the Association of Chartered

Certified Accountants (ACCA), a member of the Hong Kong Institute of Certified PublicAccountants (HKICPA), and the Taxation Institute of Hong Kong. She is also a CertifiedTax Adviser in Hong Kong. She graduated from the University of Hong Kong.

HONG KONG

Karen Au

Tax Partner – PwC Hong Kong

Hong Kong

+852 2289 [email protected]/taxcontroversy



ASIA-PACIFIC

Angela Ho is the associate director of the tax controversy serv-ices group of PwC Hong Kong. She serves a wide range ofclients including multinational enterprises and Hong Kongenterprises mainly in the retail and consumer products, manu-facturing and apparel industries. Angela has gained more than25 years’ solid experience in providing advisory services to herclients involving tax dispute resolution with the Hong KongInland Revenue Department (IRD). Before joining PwC HongKong, she served at the IRD for six years, four of which werewith the profits tax and tax investigation unit. She is very knowl-edgeable about the IRD’s practices and procedures, which facil-itates her negotiation and tax resolution with the IRD.Angela also has extensive experience in tax advisory, includ-

ing business restructuring, offshore profits claim, health checksand post audit risk management.Angela is a frequent speaker at seminars organised by various

professional bodies in Hong Kong.Angela is a member of the Hong Kong Institute of Certified

Public Accountants, the Association of Chartered Certified Accountants, the CharteredProfessional Accountants of British Columbia and the Hong Kong Institute of CharteredSecretaries. She is a graduate of the Hong Kong Polytechnic University.

Hong Kong

Angela Ho

Associate director

PwC Hong Kong

Hong Kong+852 2289 [email protected]/taxcontroversy



ASIA-PACIFIC

Philip Hung is a director of the tax controversy group in PwCHong Kong. He has more than 34 years of experience in HongKong taxation, of which six years he worked in the Hong KongInland Revenue Department (IRD) including in the field auditand investigation unit. After leaving the IRD, Philip concentrat-ed in developing the PwC tax controversy services. He assistedin the setting up of the specialised tax investigation and fieldaudit division within the firm. The firm has become one of theleading tax controversy advisers in Hong Kong. Throughoutthese years, Philip has assisted numerous clients to resolve theirtax controversy cases, clients including multinational compa-nies, large Hong Kong listed companies, and also small andmedium sized enterprises from different industries.Being an ex-IRD officer and the past president of the

Taxation Institute of Hong Kong, Philip is able to establisheffective communications with the IRD. Furthermore, byfocusing in the specialised tax controversy area, Philip hasgained vast experiences in resolving a lot of tax disputes with theIRD, not only on tax audit and investigation cases, but tax appeal cases as well. Philip adopteda proactive approach in handling tax disputes. He believes that to take a practical approachby bringing the case to the IRD, rather than waiting for the IRD to come once the auditcommences, is a best way to defend an IRD dispute. Issues resolved by him include cross-border disputes, capital and revenue queries, etc. He also collaborated with other industryexperts in PwC to resolve complex cases such as transfer pricing audits and tax audits on thefund management industries.He is recognised as the guru of the tax controversy industries in Hong Kong. Philip has

contributed numerous articles to newspapers and magazines. He also gives regular talks toprofessional, trade and business associations on the topic. He is the sensei and shifu to a lotof Hong Kong tax professionals in the tax controversy area who have attended his annualfour-day seminar on tax audit resolution held by the Taxation Institute of Hong Kong.

Hong Kong

Philip Hung

Director

PwC Hong Kong




ASIA-PACIFIC

Amy Su is a tax partner in the PwC Hong Kong office, spe-cialised in Chinese tax controversy services, with more than 18years’ experience in Chinese tax.Prior to joining PwC Hong Kong, she was working in the

tax investigation department and tax policy department ofFujian State Tax Bureau, China. With such a background, shegained a thorough knowledge of the Chinese tax system andbuilt good connections for communicating with the tax author-ities at various levels.During her professional career, she has gained valuable expe-

rience in negotiating with the tax authorities on positions andconcessions for clients, as well as assisting them in their taxaudits by the PRC tax authorities. She has successfully assistedclients in tax appeals, tax audit defence, tax ruling applications(such as treaty benefit claims, tax preferential treatment, corpo-rate restructuring, etc.), pre-IPO tax clearance, VAT refunds,VAT and other tax treatment negotiations, etc.Amy has served various clients including sizeable multina-

tional companies, state-owned enterprises and privately owned enterprises. She also hasdiverse industry experience, including real estate, manufacturing, retail and consumer, health-care, services, etc.Amy received her Bachelor of Law degree with Honors from Xiamen University, China,

and a Master’s Degree in Accounting from RMIT University, Australia. She obtained thequalifications of CPA Australia and is a Certified Chinese Lawyer.

Hong Kong

Amy SM SU

Tax partner

PwC Hong Kong




ASIA-PACIFIC

Fergus Wong is the Tax Director of PwC Hong Kong NationalTax Policy Services (NTPS). Keeping a close relationship with the Hong Kong Special

Administrative Region (HKSAR) Government, in particular theInland Revenue Department (IRD), Fergus is able to provideinputs for the tax policy and practice of the HKSAR. On top ofhis tax policy role, Fergus has also been involved in assistingclients in handling complicated tax dispute cases with the IRD,including cross-border transactions.Professionally, Fergus is a fellow member of the Chartered

Association of Certified Accountants (ACCA), the Hong KongInstitute of Certified Public Accountants and the CPA Australia.He is also a Certified Tax Agent (HK). In 2016, he wasappointed as a member of the academic committee of ChinaInternational Taxation Research Institute. He has been a mem-ber of the Global Tax Forum of ACCA since 2013 and was thechairman of ACCA HK branch for the year 2014/15. He is asa member of ACCA International Council since he was electedin 2013. He stepped down from being a member of the Board of Review of HKSARGovernment (a tax tribunal) in 2017 after serving the Board for nine years.He has many years of experience in Hong Kong tax and international tax gained through

working in the HKIRD and as a faculty member of accounting departments of Hong Kongand Australian tertiary institutions. Before joining PwC Hong Kong, he was with anotherprofessional firm providing training and in-house technical support. He is a regular contrib-utor to professional journals and has been involved in setting and reviewing taxation exami-nation papers.

Hong Kong

Fergus Wong

Tax Director, Hong Kong

PwC Hong Kong




ASIA-PACIFIC

Kenneth Wong is a tax partner of PwC Hong Kong and is theleader of the Hong Kong tax controversy services (HK TCS)practice. He has more than 20 years of experience in tax con-sulting and is specialised in helping clients resolve complex taxcontroversy issues with the Hong Kong Inland RevenueDepartment (IRD).Kenneth has significant HK TCS experience and has success-

fully helped many multinational and listed companies settle taxdisputes and board of review cases with IRD units, includingappeals, field audit and investigation, tax treaty, etc., on varioustechnical issues like offshore claims, transfer pricing, tax anti-avoidance, and complex cross-border tax issues involving taxtreaties between the IRD and overseas tax authorities. His clients include multinational corporations, HK listed

companies and Chinese enterprises, mainly in the consumer andindustrial products, retailing and technology industries.Kenneth is a regular speaker in public tax events. He also

made regular contributions to the government through hisexternal duties. He helps the Association of Chartered Certified Accountants Hong Kong(ACCA HK) make budget submissions to the government and give recommendations toimprove the HK tax systems every year. He attended the finance committee meeting in theLegislative Council to comment on certain draft tax bills. Kenneth is also a tax expert on international tax and M&A. In 2006, he was seconded to

PwC Belgium to establish the China/HK desk there at that time.Kenneth graduated from the Chinese University of Hong Kong. He is the Vice-Chariman

of The Association of Chartered Certified Accountants, past president of Institute ofAccountants Exchange, honorary committee member of the China Certified Tax AgentsAssociation, Hong Kong Certified Tax Adviser, member of The Hong Kong Institute ofCertified Public Accountants and Taxation Institute of HK.

Hong Kong

Kenneth Wong

Tax partner

PwC Hong Kong




Hong Kong

Daniel ChanDLA Piper

Joe ChanEY

Pierre ChanBaker McKenzie

Angela HoPwC See page 139

Philip HungPwC See page 140

Kaiser KwanPwC

Ayesha Macpherson LauKPMG

Amy LingBaker McKenzie

Michael OlesnickyBaker McKenzie

Steven SiekerBaker McKenzie

David SmithPwC

Amy SuPwC See page 141

Richard WeismanBaker McKenzie

Fergus WongPwC See page 142

Kenneth WongPwC See page 143

Philip WongDeloitte See page 110

ASIA-PACIFIC



ASIA-PACIFIC

BiographySujit is an advocate specialising in tax matters and is based inNew Delhi, India. He qualified as a lawyer from the NationalLaw School of India University, Bangalore (in 1995) and hasmore than 24 years of experience in tax law. Sujit started hiscareer with Arthur Andersen in 1995, and thereafter joinedErnst & Young in their indirect tax practice. In 2004, he wenton to set up a boutique tax consulting firm by the name BMRAdvisors and was one of its founding indirect tax partners. In2013, Sujit left BMR Legal to set up Advaita Legal, a boutiquetax litigation firm, and was its national head for over five years.At Advaita Legal, Sujit was the key litigator and arguing counselfor the firm and continued his court appearance and successfullyargued significant tax controversy matters before all HighCourts, the Supreme Court of India as also Tax Tribunals. At the end of January 2019, Sujit set up his own independ-

ent chamber practice by the name of Chambers of Sujit Ghoshand has been operating as an independent arguing counsel.

Recent matter highlights• Represented several renewable companies before various High Courts, challenging thelevy of safeguard duty on the import of solar modules.

• Representing a major oil and gas public sector undertaking on the levy of service tax onmining leases.

• Representing several companiues on varied issues under GST before High Courts in Inidaon the validity of specifc provisions under such law.

Practice areasTax litigation, tax – legal opinion, regulatory, commercial contracts and litigation support.

Sector specialisationsPower (conventional and renewable); oil and gas – upstream, mid- and downstream; trans-port; infrastructure; real estate; construction; manufacturing; service sector; defence.

Association membershipsAdmitted as an Advocate to the Bar Council of Delhi, AIFTP, American Bar Association,Supreme Court Bar Association, Delhi High Court Bar Association.

Academic qualificationsBA LLB (Hons) – 1995 – National Law School, Bangalore, India

INDIA

Sujit Ghosh

Advocate, Supreme Court of India& High Courts

Chambers of Sujit Ghosh

New Delhi+91 11 4085 2489+91 9811019857 (mobile)[email protected]



ASIA-PACIFIC

Languages: Hindi, English, Punjabi, Urdu

BiographyKumar has specialised in tax advisory and litigation services formore than two decades. He presently operates from his venturenamed Krishnomics Legal. He has represented clients beforemany courts including Supreme Court and advised clients onCorporate Tax, Transfer Pricing, Mergers, ForeignContribution, etc. He has authored a book named Prosecutionunder Income Tax and an acclaimed book on Tax Prosecution,now in its second edition, published by Bloomsbury.

Recent matter highlights• Successfully represented reputed food chain before the DelhiHigh Court against the imposition of VAT on a franchisee fee.

• Successfully represented a globally recognised inspection andtesting organisation before the Income Tax AppellateTribunal-Delhi Bench where the issue was whether the inspection and testing services pro-vided outside India to its Indian customers constitutes make available under Article 13 ofIndia-UK DTAA.

Practice areasAPAs, M&A, Litigation, Tax consulting, Transfer pricing

Sector specialisations Accounting, Consumer goods and services, Industrials

Association membershipsDelhi High Court Bar Association, Income Tax Appellant Tribunal Bar Association,American Bar Association, Indian Lawyers Association

Academic qualificationsB.Com (Hons.), FCA, LL.B

India

Gagan Kumar

Founder

Krishnomics Legal

New Delhi +91 [email protected]



ASIA-PACIFIC

Languages: EnglishBar admissions: Bar Council of Maharashtra and Goa, LawSociety of UK

BiographyRohan Shah is a practising counsel in the Supreme Court ofIndia and various High Courts. Mr Shah established, and wasthe Managing Partner of, Economic Laws Practice from 2001 toSeptember 2016. Mr Shah has over 300 important reported taxjudgments to his credit. Mr Shah was given the “Tax Lawyer ofthe Year” award in 2019 by Legal Era awards.

Practice areasCorporate taxes, Litigation, Tax consulting, GST, Customs

Sector specialisationsAutomotive, Finance & Banking, Oil and gas, FMCG, Pharma

Academic qualificationsLLB, Government Law College of Bombay University (now the University of Mumbai), 1987

India

Rohan Shah

Sole practitionerChambers of Rohan Shah

Mumbai+91 0 22 2287 [email protected]



India

Neeru AhujaDeloitte See page 110

Sunil BadalaBSR & Co

Arvind BahetiKhaitan & Co

Mukesh ButaniBMR Legal

Arun ChhabraSole practitioner

Soli DasturSole practitioner

Arvind DatarSole practitioner

Nishith DesaiNishith Desai & Associates

S GaneshSole practitioner

Sujit GhoshChambers of Sujit Ghosh See page 145

Tarun GulatiPDS Legal

CA Rachit GuptaDeloitte See page 110

Manisha GuptaDeloitte See page 111

Akil HiraniMajmudar & Partners

Vijay IyerEY

Pratik JainPwC

Rohit JainEconomic Laws Practice

Porus KakaSole practitioner

Waman KaleBSR & Co

Dinesh KanabarDhruva Advisors

ASIA-PACIFIC



India

Sudhir KapadiaEY

Kanchun KaushalPwC

Gagan KumarKrishnomics Legal See page 146

V LakshmikumaranLakshmikumaran & Sridharan

Sunil LalaSML Tax Chamber

Amit MaheshwariAshok Maheshwary & Associates

Jehangir MistrySole practitioner

Rahul MitraDhruva Advisors

Hardik ModhEconomic Laws Practice

Jitendra MotwaniEconomic Laws Practice

Vikram NankaniSole practitioner

BL NarasimhanLakshmikumaran & Sridharan

L Badri NarayananLakshmikumaran & Sridharan

Rajendra NayakEY

Percy PardiwalaSole practitioner

Karishma PhatarphekarDeloitte See page 111

Rohan PhatarphekarDeloitte See page 111

Ravishankar RaghavanMajmudar & Partners

Abhishek RastogiKhaitan & Co

ASIA-PACIFIC



India

Harish SalveSole practitioner

Sanjay SanghviKhaitan & Co

Pranav SaytaEY

KR SekarDeloitte See page 111

Nishant ShahEconomic Laws Practice

Rohan ShahChambers of Rohan Shah See page 147

Gopalakrishnan ShivadassShivadass Law Chambers

Hasnain ShroffBSR & Co

Hardev SinghBSR & Co

Himanshu SinhaTrilegal

Rajesh SrinivasanDeloitte See page 111

Krishnamani SubramanianDeloitte See page 111

Naresh ThackerEconomic Laws Practice

Sanjay ToliaPwC

Kunj VaidyaPwC

S VasudevanLakshmikumaran & Sridharan

Ajay VohraVaish Associates Advocates

Rajan VoraEY

Alok YadavSole practitioner

ASIA-PACIFIC



ASIA-PACIFIC

Languages: English

BiographyRatna Febrina is a tax partner of SF Consulting (a Member Firmof Crowe). She is a Certified Tax Attorney, Tax Consultant andobtained a Brevet C – the highest working license qualification.Ratna has more than 25 years of experience as a tax consultant,including 10 years with Arthur Andersen and Ernst and YoungIndonesia. Prior to joining Arthur Andersen as a tax consultant,she was an external auditor in Deloitte. Throughout her tax consultancy career, Ratna has served

major multinational and large national companies in variousindustries. With this experience, she has grown accustomed todealing with different types of clients and providing effective,practical solutions. Her specialty is in matters related to disputeresolutions, such as tax audit, objection, appeal to the TaxCourt and reconsideration requests to the Supreme Court.

Practice areasRestructuring, M&A, Corporate taxes, Dispute resolution, Pre-litigation, Litigation, Taxconsulting, International tax advisory, VAT, Customs, Transfer pricing

Sector specialisationsBanking, consumer goods and services, energy, financial services, food and beverage, govern-ment and public policy, healthcare, industrials, insurance, investment management, media,mining, natural resources, oil and gas, pharma and life sciences, real estate, tech and telecoms,transport, utilities

Association membershipsIndonesian Tax Consultant AssociationIndonesia Chartered Accountant Association

CertificationsTax Consultant License (Brevet C)Tax AttorneyCustoms and Excise AttorneyAdvocates (PERADI – Indonesian Advocates Association)

INDONESIA

Ratna Febrina

Partner

SF Consulting

Jakarta+62 21 [email protected]



ASIA-PACIFIC

Languages: English

BiographySri has had more than 30 years of experience of taxconsulting/tax law with Arthur Andersen, Ernst and YoungIndonesia and SF Consulting. As the coordinator of theFinancial Services group in Arthur Andersen, Sri has beeninvolved in the restructuring and M&A of major banks andcompanies where she dealt almost exclusively with MNCs. Her experience has led to her expertise in areas such as tax liti-gation, transfer pricing, tax planning and tax restructuring. Sri is experienced in serving a large variety of clients, both

national and multinational. Thus, she is aware that each clienthas different needs and is able to adapt her services to best suitthe client.

Practice areasRestructuring, M&A, corporate taxes, dispute resolution, pre-litigation, litigation, tax consulting, international tax advisory, VAT, customs, transfer pricing

Sector specialisationsBanking, consumer goods and services, energy, financial services, food and beverage, govern-ment and public policy, healthcare, industrials, insurance, investment management, media,mining, natural resources, oil and gas, pharma and life sciences, real estate, tech and telecoms,transport, utilities

Association membershipsChairman of the Taxation Committee – Indonesian Chamber of Commerce (KADIN)Supervisory Board of Indonesian Tax Consultant Association (IKPI)Audit Committee of PT Alam Sutra TbkBoard of Jakarta Menteng Rotary Club IndonesiaBoard Member of Entrepreneur Organization (EO) Indonesia

Academic qualificationsBachelor of Law, University of UNTAG (2007); Brevet C, Registered Tax Consultant(1997); Bachelor Business Administration University of Wisconsin – Madison, USA (1987);Chartered Financial Consultant (ChFC) – Singapore College Of Insurance (2003)

Certifications Tax Consultant License (Brevet C); Tax Attorney; PERADI (Indonesian AdvocatesAssociation)

Indonesia

Sri Wahyuni Sujono

Managing Partner

SF Consulting

Jakarta+62 21 [email protected]



Indonesia

Ahdianto GNV Consulting

Ratna FebrinaSF Consulting See page 151

Yan HardyanaDeloitte See page 111

Ponti PartogiHadiputranto Hadinoto & Partners

Ay Tjhing PhanPwC

Abraham PierreKPMG

Eko PrajantoKPMG

Cindy SukimanDeloitte See page 111

Otto SumaryotoPwC

Bambang SuprijantoEY

Heru SupriyantoDeloitte See page 111

Dodi SuryadarmaEY

Turino SuyatmanPwC

Turmanto TurmantoDeloitte See page 111

Ali WidodoPwC

Wimbanu WidyatmokoHadiputranto Hadinoto & Partners

Sri Wahyuni Sujono SF Consulting See page 152

ASIA-PACIFIC



ASIA-PACIFIC

Languages: Japanese, English

BiographyMichito Kitamura is a partner of PwC Legal Japan. He joinedPwC in 2016. Before that, he started his career as a C.P.A atArthur Andersen and then he was working for the largest lawfirm in Japan for 15 years. He graduated from International TaxProgram of New York University.

Recent matter highlights• Michito Kitamura has successfully defended his clients inthe tax audits (e.g. defended M&A tax matters with poten-tial huge impact for a famous Japanese pharmaceuticalcompany in 2018).

• He represented tax disputes and litigations including thecase regarding entity cclassification of foreign entities, taxtreatment of debt-equity-swap, deferral treatment on hedgetransaction and application of CFC (anti-tax haven) rule.

Practice areasAudit defence, Dispute resolution, Litigation, Controversy management, Tax consulting

Sector specialisationsInvestment management, Pharma and life sciences, Tech and telecoms

Association membershipsTokyo Bar AssociationMember of JICPA

Academic qualificationsLL.M. in International Taxation, New York University School of Law, 2007LL.M. with Distinction and Dean’s List, Georgetown University Law Center, 2006B.C., Keio University, 1994

JAPAN

Michito Kitamura

Partner

PwC Japan Group

+81 (0)3 5251 [email protected]



ASIA-PACIFIC

Daisuke Miyajima is a partner and leader of the international taxservices (transfer pricing) group of PwC Tax Japan. During hismore than 25 years at the firm, he spent several years workingin the transfer pricing group in Washington DC and New York.In the transfer pricing area, Daisuke has provided advicetowards numerous Japanese and foreign clients on their inter-company transactions with related parties and its effect onJapanese and foreign transfer pricing rules. He has also assistedin preparing studies for presentation to the appropriate taxauthorities and has successfully defended several well-knownJapanese and foreign companies in transfer pricing audits. He isalso an expert in the area of competent authority negotiationsand advance pricing agreements.While his experience includes clients in virtually every indus-

try, he particularly specialises in the high-tech, automotive,entertainment, and luxury goods industries. Daisuke has alsowritten extensively on the above areas in various publicationsand is a frequent speaker at seminars held by PwC and outside organisations. He has beenchosen as one of the world’s leading transfer pricing consultants in various publications. Healso writes and is fluent in both Japanese and English.Daisuke is also an associated member of the American Institute of Certified Public

Accountants.

Japan

Daisuke Miyajima

PwC Japan Group

Tokyo+81 3 5251 [email protected]/taxcontroversy



Japan

Brajeshwar BanerjeeKPMG Japan

Atsushi FujiedaNagashima Ohno & Tsunematsu

Yushi HegawaNagashima Ohno & Tsunematsu

Akihiro HironakaNishimura & Asahi

Michito KitamuraPwC Japan Group See page 154

Yutaka KitamuraDeloitte See page 112

Yuichi KomakineKPMG Japan

Takayuki KozuKPMG Japan

Shigeki MinamiNagashima Ohno & Tsunematsu

Daisuke MiyajimaPwC Japan Group See page 155

Toshio MiyatakeAdachi Henderson Miyatake & Fujita

Hisashi MiyatsukaAtsumi & Sakai

Eiichiro NakataniAnderson Mori & Tomotsune

Kuniaki NomuraNomura & Partners

Yo OtaNishimura & Asahi

Takashi SaidaNagashima Ohno & Tsunematsu

Jun SawadaDeloitte Tohmatsu Tax See page 112

Koichi SekiyaErnst & Young Tax Co

Kazuhiro TakeiNishimura & Asahi

ASIA-PACIFIC



Japan

Ryann ThomasPwC Japan Group

Shigekazu TorikaiTorikai Law Office

Edwin WhatleyBaker McKenzie

Hiroki YamakawaDeloitte Tohmatsu Tax See page 112

Hideyuki YamamotoBaker McKenzie

Yang Ho KimDeloitte Tohmatsu Tax See page 112

ASIA-PACIFIC



ASIA-PACIFIC

Languages: English, Malay, Mandarin, Cantonese

BiographyTai has more than 18 years of experience in the tax and account-ing practice. He specialises in assisting local and multinationalcompanies in tax and revenue advisory, corporate tax planning,transfer pricing, tax audits, tax investigations, tax appeals andalternative dispute resolution.

Recent matter highlights• Tai has extensive experience dealing with the Inland RevenueBoard of Malaysia (IRBM) on tax audits and tax investiga-tions and has assisted high-profile clients in achievingfavourable and confidential settlements of tax disputes.

• He also advises clients on tax audit risk assessments andreviews, tax refunds as well as provides assistance with appli-cations for tax incentives. He provides a depth of knowledgeand experience aimed at providing holistic and comprehen-sive services to his clients.

Practice areasCorporate taxes, audit defence, dispute resolution, pre-litigation, controversy management,tax audit and investigations support, tax audit risk assessment and reviews, tax consulting

Sector specialisationsAutomotive, aviation, construction and materials, consumer goods and services, energy, foodand beverage, government and public policy, healthcare, industrials, media, oil and gas, phar-ma and life sciences, real estate, tech and telecoms, utilities

Association membershipsFellow member of the Association of Chartered Certified Accountants (FCCA)Member of the Malaysian Institute of Accountants (MIA)Member of the Chartered Tax Institute of Malaysia (CTIM)

Academic qualificationsHonours in Management (Accounting), University of Technology Malaysia, 2001Approved Tax Agent licensed by the IRBM

MALAYSIA

Weng Hoe Tai

Executive Director

PwC – Malaysia

Kuala Lumpur+60 (3) 2173 [email protected]/my/en/services/tax.html



Malaysia

Nicholas CristKPMG

William Stanley Walker DavidsonAzman Davidson & Co

Senthuran ElalingamDeloitte See page 112

Theresa GohDeloitte See page 112

Goh Ka ImShearn Delamore & Co

Vijey KrishnanRaja Darryl & Loh

S Saravana KumarLee Hishammuddin Allen & Gledhill

Azhar LeePlatinum Tax Consultants

Lim Kah FanEY

Ng Sue LynnKPMG

Anand RajShearn Delamore & Co

Chandran RamasamyDeloitte See page 112

Jagdev SinghPwC

Soh Lian SengKPMG

Datuk Francis LK TanAzman Davidson & Co

Tan Eng YewDeloitte See page 112

Weng Hoe TaiPwC See page 158

Adeline WongWong & Partners

Simon YeohEY

ASIA-PACIFIC



Malaysia

Irene YongShearn Delamore & Co

NEW ZEALAND

Brendan BrownRussell McVeagh

Geoffrey ClewsSole practitioner

Geoff HarleyHarleys Chambers

Kirsty KeatingEY

Mike LennardStout Street Chambers

Patrick McCalmanDeloitte See page 112

Lindsay McKaySole practitioner

David McLaySole practitioner

Aaron QuintalEY

Campbell RoseDeloitte See page 112

Fred WardRussell McVeagh

ASIA-PACIFIC



ASIA-PACIFIC

Ronald Bernas is a partner in Quisumbing Torres’s Tax PracticeGroup. He has 20 years of experience advising clients on varioustax issues, including general tax planning, tax controversies, taxlitigation and customs issues and procedures.Ronald’s practice focuses on general tax planning, protests of

assessments, claims for refund and tax credits and the taxationof commercial transactions, M&A and business reorganisations.His practice also covers trade and customs matters. He has rep-resented and assisted clients in the power/energy/renewableenergy, oil and gas, food and beverage, healthcare, and manu-facturing industries on various tax issues, including internal rev-enue deficiency tax assessments and various claims for refundsbefore the Bureau of Internal Revenue, the Court of TaxAppeals and the Supreme Court.

Representative matters• Represented a global management consulting firm in itsclaim for refund of excess and unutilised creditable withhold-ing taxes from taxable years 2007 to 2012.

• Helped a global technology-based service company to navigate on tax issues related totheir operation in the Philippines. Represented the client before the Bureau of InternalRevenue to discuss the impact of a Revenue Memorandum Circular, specifically addressedto Transportation Network Corporations.

• Advised a multinational chemicals company on the Philippine tax implications ofPhilippine entities, tax incentives for employees and other issues in relation to its globalreorganisation, in preparation for a spin-off of certain of its business lines into a separatepublic company group.

PHILIPPINES

Ronald Bernas

Partner

Quisumbing Torres

Manila+63 2 819 [email protected]



ASIA-PACIFIC

Dennis Dimagiba heads Quisumbing Torres’s Tax PracticeGroup. He advises multinational companies with Philippineoperations on general tax planning, customs compliance andvaluation issues, and represents clients in tax and customs con-troversies. He also advises private banks on wealth managementand tax and legal issues pertaining to high net worth individuals.He has 34 years of experience in his field, and has been recog-nised as a leading individual in the area of tax by The Legal 500Asia Pacific, International Tax Review and Chambers AsiaPacific. Under his leadership, Quisumbing Torres received theawards for National Tax Firm of the Year for two consecutiveyears (2018-2019) and Tax Disputes Firm of the Year 2010from the International Tax Review. Dennis is a certified public accountant. He has spoken on

Philippine tax updates and wealth management issues in variousconferences and presentations locally and abroad. He is a mem-ber of the Tax Management Association of the Philippines,where he also served as its president in 2012. He advises on var-ious aspects of general tax planning, distribution and supply chain tax planning, tax and cus-toms audits and compliance, customs and tax controversies, multinational tax planning forM&A, including pre-spin-off and post-acquisition restructuring and corporate restructuringexercises, claims for refunds and tax credits, taxation of commercial and financial transactions,among others. His practice also covers WTO and trade matters as well as tax structuring ofmining, infrastructure, oil and gas, power, telecommunications, transportation and privatiza-tion projects.

Representative matters• Assisted one of the largest US-based electronic commerce retail companies on the follow-ing matters: (a) Philippine tax implications and entitlement to incentives of a new entitythat will provide certain services to Philippine customers, and (b) Philippine tax implica-tions of new product offerings.

• Advised and assisted one of the largest multinational pharmaceutical companies in contest-ing a tax assessment relating to the sale of the shares of stock of a subsidiary, involving thedifficult issue of valuation of shares.

• Advised a leading music streaming service provider on the proper characterisation of pay-ments it was receiving monthly from a partner telecommunications company in thePhilippines.

Philippines

Dennis Dimagiba

Partner

Quisumbing Torres

Manila+63 2 819 [email protected]



Philippines

Walter Abela JrDeloitte See page 113

Carlos BaniquedBaniqued Layug & Bello

Terence BelloBaniqued Layug & Bello

Mario Rosario BernardoSalvador Llanillo & Bernardo

Ronald BernasQuisumbing Torres See page 161

Dennis DimagibaQuisumbing Torres See page 162

Benedicta Du-BaladadDu-Baladad and Associates

Mark GorricetaGorriceta Africa Cauton & Saavedra

Fidela Isip-ReyesSyCip Gorres Velayo & Co - EY

Fredieric LandichoDeloitte See page 113

Richard LapresDeloitte See page 113

Herminigildo MurakamiKPMG

Carlo NavarroDeloitte See page 113

Cirilo NoelSyCip Gorres Velayo & Co - EY

Mary Karen Quizon-SakkamKPMG

Vincent Paul SaavedraGorriceta Africa Cauton & Saavedra

Wilfredo VillanuevaSyCip Gorres Velayo & Co - EY

ASIA-PACIFIC



Singapore

Nicole FungPwC

Daniel HoDeloitte See page 113

Peter Le HurayPwC

Lee Tiong HengDeloitte See page 113

Leung Yew KwongKPMG

Eugene LimProvidence Law Asia

Low Hwee ChuaDeloitte See page 113

Mak Oi LengKPMG

Ong Ken LoonDrew & Napier

Ong Sim HoDrew & Napier

Dawn QuekBaker McKenzie Wong & Leow

Vikna RajahRajah & Tann

Shantini RamachandraDeloitte See page 113

See Jee ChangDeloitte See page 113

Sim Siew MoonEY

Geoffrey SohKPMG

Allen TanBaker McKenzie Wong & Leow

Peter TanSole practitioner

Tan Kay KhengWongPartnership

Michael VeltenDeloitte See page 113

ASIA-PACIFIC



ASIA-PACIFIC

Languages: English

BiographyHenry An is a Senior Partner at Samil PricewaterhouseCoopers(Samil PwC), the Korean member firm of Pricewaterhouse -Coopers, and currently serves as Inbound Leader. As InboundLeader, he has firm-wide oversight responsibility for SamilPwC’s foreign-invested client base. Henry has over 20 years ofexperience in the US and Korea and specializes in providingadvice on complex business and tax issues.

Recent matter highlights• Henry has been selected for inclusion in Legal MediaGroup’s Guide to the World’s Leading Tax Advisers andGuide to the World’s Leading Transfer Pricing Advisersevery year since 2004.

• In 2011, 2013, 2014, 2016 and 2018, he was recognized inEuromoney’s Best of the Best in the area of transfer pricing.

• He has served as an external adviser to Korea’s National Tax Service, Korea CustomsService, Ministry of Strategy and Finance, Office of the Prime Minister and President’sTransition Committee.

Practice areasRestructuring, APAs, Audit support, Dispute resolution, MAPs/ADRs, Transfer pricing,Audit Defense

Sector specialisationsConsumer goods and services, Financial services, Food and beverage, Pharma and life sci-ences, Tech and telecoms

Association membershipsChief Compliance Officer and Co-Chair of the Taxation Committee of the AmericanChamber of Commerce in Korea

Academic qualifications:Received a Bachelor of Economics degree from the Wharton School of Business at theUniversity of Pennsylvania.MBA from the Kellogg School of Management at Northwestern University.

SOUTH KOREA

Henry An

Partner

SamilPricewaterhouseCoopers




South Korea

Henry AnSamil PwC See page 165

Je Heum BaikKim & Chang

Kyu-Bum ChoDeloitte Anjin See page 114

Yun Heui ChoYulchon

Jeong Wook ChoiSamjong KPMG

Jee Won KwonDeloitte Anjin See page 114

Dong Chul KimEY

Sunyoung KimDeloitte Anjin See page 114

Min Yong KwonEY

Nam Hyuk ParkDeloitte Anjin See page 114

Michael QuigleyKim & Chang

Seong Kwon SongDeloitte Anjin See page 114

SRI LANKA

Suresh PereraKPMG

TAIWAN

Robert ChenDeloitte See page 114

Thomas ChenDeloitte See page 114

Sophie ChouEY

Albert GauKPMG

ASIA-PACIFIC



Taiwan

Kevin LaiDeloitte See page 114

Dennis LeeBaker McKenzie

Susan LeeDeloitte See page 114

Robin LinDeloitte See page 114

Lin Ye-HsinDeloitte See page 115

Josephine PengLee & Li

Michael WongBaker McKenzie

THAILAND

Chinawat AssavapokeeKudun & Partners

Ruth ChaowanagawiEY

Korneeka KoonachoakDeloitte See page 115

Wynn PakdeejitBaker McKenzie

Sriwan PuapondhTilleke & Gibbins

Panya SittisakonsinBaker McKenzie

Wanna SuteerapornchaiDeloitte See page 115

Aek TantisattamoBaker McKenzie

Kitipong UrapeepatanapongBaker McKenzie

Suvarn ValaisathienDr Suvarn Law Offices

Suksawat WatewaiBaker McKenzie

ASIA-PACIFIC



ASIA-PACIFIC

Huong Vu is a Partner in tax and advisory services, overseeingJapanese business services and Korean business services. She isalso the General Director of EY Consulting Vietnam.She has almost 25 years’ experience in tax and regulatory con-

sulting in Vietnam, Laos and Cambodia. Huong Vu is a Memberof CPA Australia, Member of the Standing Committee ofVietnam Tax Consultants’ Association (VTCA), Deputy Directorof Vietnam CFO Club and leader of the tax group of the VietnamBusiness Forum (VBF). She is also a lecturer in ACCA Tax cours-es, a frequent keynote speaker/writer on tax issues at the VietnamBusiness Forum and various seminars and publications of theVietnam Tax Consultants’ Association, Vietnam InvestmentReview, Securities Investment magazine, Vietnam EconomicTimes, Vietnam National Television VTV1, VTV3, etc.Huong Vu has a particularly in-depth understanding of the

Vietnam legal system and various tax and investment regula-tions. She leads a team of experienced and multi-disciplinaryprofessionals in servicing clients, focusing on Foreign InvestedCompanies. She is involved in:• Tax review, tax controversy, tax litigation support• Tax due diligences and international tax structuring advicesfor cross-border transactions in areas such as tax effectiveacquisition, transfer pricing planning, reorganizations, M&A, etc.

• Inbound investment including market entry, exit, business expansion, tax incentivesincluding negotiation with the Government to achieve favorable outcomes for clients

• Tax compliance and advisory on corporate income tax, VAT, foreign contractor tax,import – export taxes

• Human capital services, especially expatriate tax services for Vietnam encompassing globalmobility compliance, tax planning and cross border advisory for a broad base of foreigncompanies doing business in Vietnam.

VIETNAM

Huong Vu

Partner

EY Consulting Vietnam

Hanoi+ 84 24 3831 5100 (tel)+ 84 903 432 791 (cell)[email protected]/vn



ASIA-PACIFIC

Languages: English, Thai, Lao

Biography Jack is a partner and the head of the regional tax practice at DFDL.The tax practice at DFDL advises clients on a full range of tax mat-ters across South East Asian countries, including Vietnam,Thailand, Myanmar, Cambodia, Laos, Indonesia and Singapore.Jack specialises in advising on corporate tax planning, tax

controversy, M&A, transfer pricing and supply chain manage-ment, and inbound / outbound investment planning. Jack is listed as a leading tax adviser by a number of leading

directories, including the Legal 500. Jack holds a Master’sDegree in Tax Law from Oxford University and is a Fellow ofthe Association of Chartered Accountants.

Practice areas • M&A• Corporate taxes• Tax consulting• International tax advisory• Restructuring

Sector specialisations • Industrials• Tech and telecoms• Government and public policy• Consumer goods and services• Energy

Association memberships• Fellow of Association of Chartered Certified Accountants• Oxford University Alumni

Academic qualifications• Master’s in Tax Law, Oxford University – 2018• Association of Chartered Accountants – 2005

Vietnam

Jack Sheehan

Partner and head of regional taxpractice

DFDL

Ho Chi Minh City+84 28 [email protected]



Vietnam

Minh BuiDeloitte See page 115

Tuan BuiDeloitte See page 115

Frederick BurkeBaker McKenzie

Richard IrwinPwC

Tram Le BaoPwC

Christopher MarjoramPwC

Thanh Vinh NguyenBaker McKenzie

Nguyen Huong GiangPwC

Nguyen Huu PhuocPhuoc & Partners

Phan Vũ HoàngDeloitte See page 115

Jack SheehanDFDL See page 169

Huong VuEY See page 168

ASIA-PACIFIC


Europe, Middle East & Africa




EMEACurrent trends suggest that multinational organisations will continue to spend moretime and resources managing tax controversies in both their local and foreign markets.Tax authorities are sharing information about companies and focusing increasingly notjust on the technical merit of a tax position but also on implementation.

Deloitte’s tax controversy teams include former tax authority officials, alternativedispute resolution specialists, and in many countries, tax litigation specialists who canassist multinational businesses at all phases of the tax controversy cycle.

For the EMEA region, a strong network has been created, with people knowingeach other and able to design a specific team to address various types of issues andhelp clients in the various steps of the various controversy procedures (end of auditnegotiations with tax authorities, internal appeal process, legal procedures).

A pan-European network is ready to assist Multinational Enterprises—includingtax specialists, former senior tax administrations officials, experienced lawyers—tohelp clients navigate in the various procedures and provide strategic guidance inaddition to detailed legal advice.

The Deloitte member firms in the EMEA region are innovative because a dedicat-ed network has been created and is able to assist clients in a very reactive manner, ina wide range of areas, including immediate assistance in tax raids and their followingsteps.

Our key service offerings include: • Pre-controversy audit readiness• Examinations• Litigation, appeals, and settlement• Proactive resolution services• Transfer pricing• Tax controversy software tools and support

Recent wins: • Assistance of a major group in its sector of activity in a large-scale tax raid and sub-

sequent steps, including court actions• Helping a group which is a pioneer in the information technology industry area to

manage a complicated approach of tax administrations, including tax audits closing,tax raid and Advance Pricing Agreement (APAs)

• VAT dispute that is still ongoing regarding the zero rating of the services of a clientin the hospitality industry. The dispute focusses mainly on if there is an existence ofan agency relationship or not.




• Significant transfer pricing dispute with South African Revenue Service (SARS)involving a major South African distributor of electronic goods. Currently at anadvanced stage of alternative dispute resolution (ADR) proceedings.

• Very technical court procedure connected to a detailed approach of the national taxlaw and the European principles, concluded by a court decision in favour of thegroup.

Awards and recognition: 2019 ITR European Tax Awards:

Regional Awards: European Tax Firm of the YearEuropean Tax Compliance & Reporting Firm of the YearEuropean Tax Technology Firm of the Year European Court of Justice Firm of the Year – Indirect Tax

Leader Award:European Transfer Pricing Practice Leader of the Year – Shaun Austin

National Tax Firms of the Year: Deloitte in Central and Eastern Europe, Deloitte Denmark, Deloitte Finland, DeloitteLuxembourg, Deloitte Malta, Deloitte Poland, Deloitte Switzerland

National Transfer Pricing Firms of the Year: Deloitte Austria, Deloitte Baltics, Deloitte Hungary, Deloitte Ireland, DeloitteSwitzerland

2019 ITR World Tax Guide: Deloitte was ranked Tier 1 in 28 jurisdictions in EMEA.

2019 ITR World Transfer Pricing Guide: Deloitte was ranked Tier 1 in 29 jurisdic-tions in EMEA.

2018 ITR Leader Guides: Indirect Tax: Deloitte had 162 leaders included from EMEA, more than any other firm.Women in Tax: Deloitte had 102 leaders included from EMEA, more than any otherfirm.Tax Controversy: Deloitte had 70 leaders included from EMEA.

2018 Euromoney Tax Advisers Guide: Deloitte had 178 leaders included fromEMEA, more than any other firm.

2017 Euromoney Transfer Pricing Advisers Guide: Deloitte had 54 leaders includ-ed from EMEA.




Phone: +33 1 40 88 86 75, +33 7 85 11 83 64Email: [email protected]: @DeloitteWebsite: Deloitte.com/tax

This document has been prepared solely for the purpose of publishing in the 2019 Tax Controversy Leaders guideand may not be used for any other purpose. This document and its contents may not be reproduced, redistributedor passed on, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written con-sent.Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of memberfirms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms arelegally separate and independent entities. DTTL does not provide services to clients. Please seewww.deloitte.com/about to learn more.Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates thatprovide legal services outside of the US. For legal, regulatory and other reasons, some member firms, including theUS member firm, do not provide legal services.Certain services may not be available to attest clients under the rules and regulations of public accounting.Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax andrelated services. Our network of member firms in more than 150 countries and territories serves four out of fiveFortune Global 500® companies. Learn how Deloitte’s approximately 286,000 people make an impact that mattersat www.deloitte.comThis communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its mem-ber firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, render-ing professional advice or services. Before making any decision or taking any action that may affect your financesor your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall beresponsible for any loss whatsoever sustained by any person who relies on this communication.© 2019. For information, contact Deloitte Touche Tohmatsu Limited.




What is the most significant change to your region/jurisdiction’s tax controversy/disputes legislation in thepast 12 months?Implementation of Base Erosion Profit Shifting (BEPS) initia-tive, no. 14 (alternative dispute resolution) and no. 15 (multi-lateral instrument). German legislation on the EU dispute reso-lution directive remains pending.

Increased scrutiny of regulators on corporate compliancewith organisational and supervisory duties in connection withthe tax function. German legislation on new corporate sanctionsregime remains is pending.

What has been the most significant impact of thatchange?Tax litigation and tax criminal defense advice for corporateclients is changing; Tax litigation advice is becoming more inter-national. Tax criminal defense advice focuses on the design andimplementation of measures to effectively prevent the violationof organisational and supervisory duties in connection with thetax function.

How do you anticipate that change impacting your workand the market moving forwards?The changes (new legislation) are fundamental for corporateclients as well as advisers. Corporate clients will have to takedecisions that are more complex, whether to settle tax disputesand to avoid double taxation in national tax court litigation orinternational dispute resolution. Corporate clients will facemore complex sanction risks, if organisational and supervisoryduties in connection with the tax function. Service solutionsrecognising this increase in complexity have been developed and

INTERVIEW

Christian-AlexanderNeulingDeloitte

EMEARegional interview

Christian-Alexander Neuling, a partner with the Deloitte controversy group, answers questionsabout recent legislative changes in Germany.




Interview

are being offered to the market. They bring different service lines together and have a strongfocus in technology. Go-to-market activities in this respect will be increased even more whenthe aforementioned legislations will come into force.

How has this changed the way you offer tax advice?Deloitte’s tax and legal controversy services will become more cross-functional and interna-tional.

What potential other legislative changes are on the horizon that you think willhave a big impact on your region/jurisdiction?Please refer to the answer to question one.

What are the potential outcomes that might occur if those changes areimplemented?Please refer to the answer to question two.

Do you think that change will have a positive effect on both your practice and thewider regional/jurisdictional market?Yes (new service offering opportunities).

How are issues surrounding the taxation of the digital economy affecting yourjurisdiction?The current discussion on digital economy taxation suggests that there is a need for a consis-tent global taxation regime, combined with a global tax dispute settlement mechanism inorder to avoid double taxation.

What is the tax authorities’ approach to tax auditing?Overall they are becoming more aggressive and focused on the clients’ processes and con-trols, as well as more traditional technical tax issues.

How has tax advice adapted to the changing tax audit approach, and how do youexpect it to change further?Tax and legal advice has become more integrated, technology orientated and complex (e.g.applying negotiation concepts).

For disputes that require litigation (pre-litigation, and court proceedings), howare matters evolving in your jurisdiction/region? Are pre-court settlementsbecoming easier, and why?Corporate clients need for tax and legal advice regarding their (inter-)national tax litigationand mutual agreement procedure options, especially in transfer pricing cases and in thenational tax audit phase, which have increased. Pre-court settlements have become morecomplex due to the initiatives on European and global level, triggered by BEPS (Please referto the answer to question one).





Interview




Bernhard GroehsDeloitte Austria

Renngasse 1/Freyung, Wien, A-1010,AustriaTel: [email protected]

Robert RzeszutDeloitte Austria


Luc De BroeLaga

Gateway Building Luchthaven BrusselNationaal 1 J, Zaventem, 1930,BelgiumTel: + 32 2 800 70 [email protected]

Danny StasLaga

Gateway building - Luchthaven BrusselNationaal 1 J, 1930 Zaventem,BelgiumTel: + 32 2 800 70 [email protected]

John HenshallDeloitte Denmark

Weidekampsgade 6 Postboks 1600,København C, 0900, DenmarkTel: +45 30 93 49 [email protected]

Alexander LangDeloitte Austria


Alexander BaertLaga

Gateway Building LuchthavenNationaal 1 J, Zaventem, 1930,BelgiumTel: + 32 2 800 71 [email protected]

Johan SpeeckeLaga

President Kennedypark 8a, Kortrijk,8500, BelgiumTel: + 32 56 59 43 [email protected]

Annick VisschersLaga

Gateway Building LuchthavenNationaal 1 J, Zaventem, 1930,BelgiumTel: + 32 2 800 70 [email protected]

Lari HintsanenDeloitte Finland

Porkkalankatu 24 P.O. Box 122,Helsinki, 00181, FinlandTel: [email protected]




Hanna ViiloDeloitte Finland

Porkkalankatu 24 P.O. Box 122,Helsinki, 00181, FinlandTel: [email protected]

Eric LespritTaj, Société d’Avocats

Tour Majunga - 6, place de laPyramide, Paris La Défense, 92 908,FranceTel: +33 [email protected]

Pascal SeguinTaj, Société d’Avocats


Dr. Ulrich GrünwaldDeloitte Germany

Kurfürstendamm 23, Neues KranzlerEck, 10719 Berlin, GermanyTel: +49 (0)30 [email protected]

Dr. MichaelMassbaumDeloitte Germany

Kurfuerstendamm 23 Neues KranzlerEck, Berlin, 10719, GermanyTel: [email protected]

Michel GuichardTaj, Société d’Avocats


GianmarcoMonsellatoTaj, Société d’Avocats


Stefan GrubeDeloitte Germany

Schwannstr. 6, Duesseldorf, 40476,GermanyTel: [email protected]

Claudia LautenDeloitte Germany

Schwannstr. 6, Duesseldorf, 40476,Germany Tel: +49 211 [email protected]

Dr. C. AlexanderNeulingDeloitte Germany

Kurfuerstendamm 23 Neues KranzlerEck, Berlin, 10719, GermanyTel: [email protected]




Heiko RamckeDeloitte Germany

Aegidientorplatz 2A, Hannover, 30159,GermanyTel: [email protected]

Harald StangDeloitte Germany

Aegidientorplatz 2A, Hannover, 30159,GermanyTel: [email protected]

Mihály HarcosDeloitte Hungary

Dozsa Gyorgy ut 84/C, Budapest,1068, HungaryTel: +36 (1) 428 [email protected]

Matteo CostiglioloDeloitte Italy

Piazza della Vittoria, 15/34, Genova,GE 16121, ItalyTel: [email protected]

Stefano FedeleDeloitte Italy

Via Tortona, 25, Milano, MI 20144,ItalyTel: [email protected]

Alexander SchemmelDeloitte Germany

Rosenheimer Platz 6, Muenchen,81669, GermanyTel: [email protected]

Eftichia PiligouDeloitte Greece

3A Fragoklissias & Granikou StrMaroussi, Athens, 151 25, GreeceTel: +30 [email protected]

Zsuzsanna HuszlDeloitte Hungary

Dozsa Gyorgy ut 84/C, Budapest,1068, HungaryTel: +36 (1) 428 [email protected]

Eugenio della ValleDeloitte Italy

Via XX Settembre, 1, Roma, RM00187, ItalyTel: [email protected]

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Iva GeorgijewDeloitte Poland

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Languages: German, EnglishBar admissions: Certified Public Accountant and Tax Adviser

BiographyHerbert joined the firm in 1985 and has more than 30 years ofprofessional experience in advising domestic and multinationalenterprises in national and international legal and tax matters.

Recent matter highlightsHerbert has been involved in numerous transfer pricing projectscovering tax planning, transfer of functions (value chain trans-formation) and transfer pricing documentation aspects. Heserves a large number of subsidiaries of international corpora-tions in Austria as well as Austria-based multinational clients.He has intense tax audit experience, mostly on TP matters, andassisted clients in obtaining advance rulings, as well as negotiat-ing advance pricing agreements.

Practice areasBusiness model optimisation, Economic modelling, Policy design, IP management, Cross-border project management, APAs, Value chains, Audit defence, Audit support, Dispute res-olution, MAPs/ADRs, Controversy management, Transfer pricing

Association membershipsMember of the tax experts board of the Austrian Chamber of Accountants and several work-ing groups thereof.Member of the Austrian branch of the International Fiscal Association

Academic qualificationsMBA, Vienna University of EconomicsDoctorate, University of Vienna

AUSTRIA

Herbert Greinecker

Partner and Head of the Austriantransfer pricing team

PwC Austria

Vienna+43 1 50188 [email protected]/taxcontroversy



Austria

Franz AlthuberDLA Piper Weiss-Tessbach

Matthias BaritschDLA Piper Weiss-Tessbach

Herbert GreineckerPwC See page 185

Bernhard GroehsDeloitte Audit See page 178

Gabriele HacklHackl & Co

Johannes KautzDLA Piper Weiss-Tessbach

Michael KotschniggKotschnigg

Alexander LangDeloitte Audit See page 178

Roman LeitnerLeitnerLeitner

Gerhard OrtliebHackl & Co

Roman PernerSchoenherr

Barbara PolsterKPMG Austria

Orlin RadinskyBrauneis Klauser Prändl

Robert RzeszutDeloitte Audit See page 178

Gerald Schachnerbpv Hügel

Niklas SchmidtWolf Theiss

Claus StaringerFreshfields Bruckhaus Deringer

Andreas StefanerErnst & Young

Benjamin TwardoszWolf Theiss

Kornelia Wittmannbpv Hügel





Languages: Dutch, English, FrenchBar admissions: Member of the Brussels Bar

BiographyVéronique’s practice focuses on dispute resolution and litigationrelated to all types of taxes. With more than 24 years’ experi-ence, Véronique advises both Belgian and international clientson procedural matters and in handling both administrative andCourt proceedings (such as complex transfer pricing disputes).She is a guest lecturer at Ghent University.

Recent matters highlights• Assisted clients in the context of domestic as well as multilat-

eral tax audits.• Negotiated settlements with the administrative authorities,

provided assistance in dawn raids, e-auditing (together withforensics).

• Handled administrative disputes and litigation cases in all courts of Belgium (from thelowest to the Constitutional Court and the Supreme Court) and assisted clients in devel-oping a litigation strategy.

• Carried out risk analyses and helped clients with voluntary disclosures.

Practice areasAudit support, Dispute Resolution, Pre-litigation, Litigation, Controversy management

Sector specialisationsAutomotive, Food and beverage, Consumer goods, Media, Real estate, Tourism, Transport

Academic qualifications• Master Degree in Accounting and Taxes, Vlerick Management School (Ghent), 1992-1993• Law degree, University of Leuven, 1987-1992

BELGIUM

Véronique De Brabanter

Senior Counsel

PwC Legal

Brussels+32 (0)2 710 78 [email protected]



Belgium

Thierry AfschriftAfschrift

Alexander BaertLaga See page 178

Nicolas BertrandLoyens & Loeff

Patrick BoonePwC

Thierry CharonLoyens & Loeff

Christian ChéruyLoyens & Loeff

Victor DauginetDauginet

Véronique De BrabanterPwC See page 187

Luc De BroeDeloitte See page 178

Guido De WitLinklaters

Thierry DenayerStibbe

Caroline DoccloLoyens & Loeff

Daniel GarabedianLiedekerke Wolters Waelbroeck Kirkpatrick

Jurgen GeversTiberghien

Axel HaeltermanFreshfields Bruckhaus Deringer

Alain HuygheBaker McKenzie

Ine LejeunePwC

Nicolas LippensLinklaters

Bernard PeetersTiberghien




Belgium

Astrid PieronMayer Brown

Philippe RenierDe Broeck Van Leaere & Partners

Natalie ReypensLoyens & Loeff

Véronique SlachmuyldersKPMG Central Services

Patrick SmetAllen & Overy

Johan SpeeckeDeloitte See page 178

Danny StasLaga See page 178

Reinhold TournicourtMonard Law

Dirk van StappenKPMG Central Services

Xavier Van VlemPwC

Henk VanhulleLinklaters

Isabel VerlindenPwC

Henk VerstraeteStibbe

Annick VisschersLaga See page 178

BULGARIA

Diavena KalchevaBWSP Ilieva Voutcheva & Co

Teodosia KirilovaKirilova Law Office

Tamara KovachevaBWSP Ilieva Voutcheva & Co

Boyana MilchevaDimitrov Petrov & Co




Bulgaria

Milen RaikovEY

Valentin SavovSavov & Partners

Todor TodorovKambourov & Partners Attorneys at Law

Viara TodorovaDjingov Gouginski Kyutchukov & Velichkov

CROATIA

Maja MaksimovićKPMG

CYPRUS

Chris DamianouEurofast

Zoe KokoniZathea-Zoe Quality Services

Philippos RaptopoulosEY

Angelos TheodorouEY

CZECH REPUBLIC

Eliška KomínkováBaker McKenzie

Petr TomanKPMG

DENMARK

Stine AndersenKromann Reumert

Kaspar BastianTVC Advokatfirma

Peter Rose BjareKPMG Acor Tax

Nikolaj BjørnholmBjørnholm Law




Denmark

Johnny BøgebjergKPMG Acor Tax

Lena EngdahlPwC

Lasse Esbjerg ChristensenPlesner

Hans Severin HansenPlesner

John HenshallDeloitte See page 178

Lida HulgaardHulgaard Advokater

Tom Kári KristjánssonPlesner

Søren Lehmann NielsenPlesner

Henrik LundKPMG Acor Tax

Martin NielsenKPMG Acor Tax

Jef Nymand HounsgaardPlesner

Anders Oreby HansenLundgrens

Arne Møllin OttosenKromann Reumert

Arne RiisARITax/law

Michael SerupBech-Bruun

Jakob Skaadstrup AndersenGorrissen Federspiel

Eduardo VistisenVistisen Falk Winther





Languages: Finnish, English, Swedish

BiographyEija Kuivisto has long and exhaustive experience on taxation.She is specialized in corporate taxation, but also has experiencewith other taxes. She is a well know litigator, regularly assistingclients with their domestic and international tax processes andappeals. Eija also heads PwC teams in numerous M&A projects.

Recent matter highlights• Successful completion of multilateral MAP• Assistance with bilateral APA processes• Assistance with tax audit defence and tax audit support

processes

Practice areasAPAs, Transactions, Audit defence, Dispute resolution,Litigation, Corporate taxes

Sector specialisationsHealthcare, Industrials, Investment management, Real estate

Association membershipsInternational Fiscal Association, Finnish BranchAssociation of Finnish Tax Advisors

Academic qualificationsLL.M., University of Helsinki, 1990Trained at the Bench, Helsinki District Court, 1998

FINLAND

Eija Kuivisto

Senior Manager

PricewaterhouseCoopers Oy

Helsinki+358 (0)20 787 7876www.pwc.fi



Finland

Mikko AlakareCastrén & Snellman

Henri BeckerAlder & Sound

Ossi HaapaniemiRoschier

Lari HintsanenDeloitte See page 178

Jussi JärvinenKPMG

Janne JuuselaBorenius

Einari KarhuBorenius

Eija KuivistoPwC See page 192

Antti LehtimajaKrogerus

Hannu-Tapani LeppänenAlder & Sound

Reima LinnanvirtaAlder & Sound

Jukka LyijynenEY

Jarno MäkeläKPMG

Mika OhtonenRoschier

Petteri RapoAlder & Sound

Eric SandelinKPMG

Sami TuominenBird & Bird

Suvi VänskäAlder & Sound

Heikki VesikansaHannes Snellman





Finland

Hanna ViiloDeloitte See page 179

Jouni WeckströmWaselius & Wist




Languages: French, EnglishBar admissions: 12th October 1990

BiographyRichard joined CMS Francis Lefebvre Avocats in 1988 and wasco-opted as an equity partner in 1998. He chaired the firm’s advi-sory board from 2009 to 2012. He is an expert in direct taxes, andmainly manages mainly cases in the following subject matters: cor-poration tax for listed and non-listed companies (French and inter-national); personal income tax; real estate and finance taxation, forlisted and non-listed French and international companies; and taxsystems for semi-public companies and local authorities.

Richard is also specialised in tax litigation and in tax penalclaims. In this context, he and his team have spent many yearsassisting several groups, companies and their key individuals, intax dawn raid procedures (section L 16B of the French taxcode) and in tax criminal procedures; as a tax litigation lawyer,he also regularly pleads (including in criminal tax).

Richard is well known by the French tax administration as an expert of those matters, andregularly publishes different articles on these matters in specialised publications.

He is a lecturer at the Universities of Paris I (Panthéon-Sorbonne), Sophia-Antipolis andMontpellier. He is also a member of the IACF and of the ACE.

Practice areasDirect taxes; corporation tax for listed and non-listed companies; personal income tax; realestate and finance taxation; tax litigation; tax penal claims.

Association membershipsRichard is a member of the IACF and of the ACE.

Academic qualificationsPostgraduate degree in business law from the University of Montpellier (DJCE)

FRANCE

Richard Foissac

Partner

CMS Francis LefebvreAvocats

Neuilly-sur-Seine+33 1 47 38 40 [email protected]/fr/FRA/




Languages: French, English

BiographyAntoine has an extensive experience of 20-plus years on allissues pertaining to transfer pricing: Management of an array ofprojects including: transfer pricing strategy design and structur-ing, general documentation, effective tax rate management,strategic management of intangibles; Corporation reorganisa-tion, structuring.

Practice areas• IP management• Technology services• Corporate taxes• Litigation• Tax consulting• Transfer Pricing

Sector specialisationsAccounting, Agriculture, Automotive, Aviation, Banking, Construction and materials,Consumer goods and services, Energy, Financial services, Food and beverage, Governmentand public policy, Healthcare, Industrials, Insurance, Investment management, Media,Mining, Natural resources, Oil and gas, Pharma and life sciences, Social infrastructure, Techand telecoms, Tourism, Transport, Utilities

Academic qualificationsEngineer in “economy, engineering and urban management”National School of Administration (ENA, 1991)

France

Antoine Glaize

Arsene Taxand

Paris+33 1 70 38 88 [email protected]



France

Vincent AgulhonDarrois Villey Maillot Brochier

Stéphane AustryCMS Francis Lefebvre Avocats

Gauthier BlanluetSullivan & Cromwell

Delphine BocquetPwC Société d’Avocats

Eric BonneaudFidal

Laurent BoreyMayer Brown

Bernard BoutémyJeausserand Audouard

Ariane CalloudBaker McKenzie

Manuel CastroCabinet Castro & Associé

Michel CombePwC Société d’Avocats

Sabina ComisDechert

Jean-Charles DavidAteleia

Nicolas de BoynesSullivan & Cromwell

Philippe DerouinPhilippe Derouin

Gilles EntrayguesCleary Gottlieb Steen & Hamilton

Pierre EscautPwC Société d’Avocats

Richard FoissacCMS Francis Lefebvre Avocats See page 195

Alain FrenkelFrenkel & Associés

Bruno GibertCMS Francis Lefebvre Avocats




France

Antoine GlaizeArsene Taxand See page 196

Michel GuichardTaj See page 179

Sandra HazanDentons

Jacques Henry De BourmontLPA-CGR

Benjamin HomoMayer Brown

Audrey-Laure Illouz-ChetritKPMG

Christopher LallozMayer Brown

Eric LespritTaj See page 178

Philippe LionBaker McKenzie

Laurence MazevetKPMG

Eric MeierBaker McKenzie

Charles MénardEY

Gianmarco MonsellatoTaj See page 179

Eve ObadiaWagener & Associés

Marc PelletierFrenkel & Associés

Elisabeth RivièrePwC Société d’Avocats

Guillaume RubechiValoris Avocats

Pascal SeguinTaj See page 179

Mathieu Selva-RoudonLPA-CGR




France

Régis TorletBaker McKenzie

Jérôme TurotCabinet Turot

Cyril ValentinFreshfields Bruckhaus Deringer





Languages: German, French, English

Biography Dr. Yves Hervé is a Managing Director in NERA’s GlobalTransfer Pricing Practice and is operating in NERA’s Frankfurtoffice. Dr. Hervé has been a fully dedicated TP professionalsince 1999. Prior to joining NERA, he was a Transfer PricingPartner at KPMG and the German Tax Leader of the globalValue Chain & Digital Transformation practice at PwC.

Recent matter highlights• Transfer pricing analysis in German tax litigation case in the

tobacco industry• IP valuation and damage claim computation in commercial

litigation case in the pharmaceutical company• TP advisor of global aviation manufacturer on the develop-

ment of their future digital business models• Lead TP advisor for a leading US Digital Tech Company for

their BEPS related European TP restructuring• Lead TP advisor for the Specialty Chemicals Division of a German DAX 30 Company,

conduct of a global TP restructuring, related TP documentation and Dispute Resolutionstrategy

Practice areasBusiness model optimisation, Cost-sharing arrangements, Dispute resolution, EU state aid,Transfer pricing

Sector specialisationsAutomotive, Consumer goods and services, Healthcare, Industrials, Tech and telecoms

Association membershipsIFA

Academic qualificationsM.Sc. in Economics from the University of Bonn, Germany, 1993M.A. in European Studies, College of Europe in Bruges, BelgiumPh.D. in Economics from the University of Saarbrücken, Germany

GERMANY

Dr. Yves Hervé

Managing directorNERA Economic Consulting

Frankfurt am Main+49 697 104 475 [email protected]



Germany

Ulf AndresenPwC

Christoph BeckerBaker McKenzie

Lorenz BernhardtPwC

Burkhard BinnewiesStreck Mack Schwedhelm

Dieter BirkP+P Pöllath + Partners

Eugen BogenschützAllen & Overy

Gero BurwitzMcDermott Will & Emery

Stephan BuschDentons

Uwe ClausenO&R Group

Felix DörrDr Felix Dörr & Kollegen

Axel EigelshovenPwC

Kati FiehlerPwC

Stefan GrubeDeloitte See page 179

Ulrich GrünwaldDeloitte See page 179

Wilhelm HaarmannLinklaters

Susann Van der HamPwC

Jörg HankenPwC

Michael HendricksFlick Gocke Schaumburg

Yves HervéNERA Economic Consulting See page 200




Germany

Ulf JohannemannFreshfields Bruckhaus Deringer

Andreas KempfPwC

Stephan KrampeBryan Cave Leighton Paisner

Carsten KratzerBaker Tilly

Axel KronigerDeloitte

Heinz-Klaus KroppenPwC

Thomas KüffnerKüffner Maunz Langer Zugmaier

Claudia LautenDeloitte See page 179

Martin LenzSole practitioner

Alexander LinnDeloitte

Nicole LooksBaker McKenzie

Jochen LüdickeFreshfields Bruckhaus Deringer

Alexandra MackStreck Mack Schwedhelm

Michael MassbaumDeloitte See page 179

Jochen Meyer-BurowBaker McKenzie

Christian-Alexander NeulingDeloitte See page 179

Dirk PohlMcDermott Will & Emery

Christian PortBaker McKenzie

Michael PulsFlick Gocke Schaumburg




Germany

Heiko RamckeDeloitte See page 180

Ulrich RänschBaker McKenzie

Stephan RaschPwC

Martin RenzPwC

Alexander SchemmelDeloitte See page 180

Jürgen SchimmeleEY

Ulrich SorgenfreiUlrich Sorgenfrei

Gerhard SpeckerP+P Pöllath + Partners

Rudolf StahlCarlé Korn Stahl Strahl

Harald StangDeloitte See page 180

Michael StreckStreck Mack Schwedhelm

Alexander VoegeleNERA Economic Consulting

Klaus von BrockeEY

Ludger WellensPwC





Georgios Katrinakis is a barrister at the Athens Bar Associationand he joined PwC Greece in 2014 to lead its tax litigation prac-tice and as a Partner of the PwC network member law firm M.Psylla – V. Vizas – G. Katrinakis.

Georgios has more than 19 years of experience in handlingcomplex litigation and ADR in virtually all areas of taxation,including corporate taxation, PE and TP disputes, indirect taxes(VAT, stamp duties, customs and excise duties), individual andwealth taxation, either defending clients against tax and penaltyassessments after the conduct of audits or reclaiming the refundof taxes unduly paid. Georgios also assists criminal defenselawyers in cases of criminal tax evasion.

During the first four years of his career he conducted com-mercial litigation at an Athens-based law firm, specialising inbanking and financial law. Subsequently he served as one of theleading tax litigators in a major Greek law firm for 11 yearsbefore joining PwC Greece. Georgios has represented over theyears a multitude of multinational and Greek companies, as wellas individual taxpayers before all Greek court instances (includ-ing the Greek Supreme Administrative Court) and before the Court of Justice of theEuropean Union.

Georgios is a graduate of the Law School of the Athens National and KapodistrianUniversity and holds an LLM in European & International Law (University of Durham, UK)and PG Certificates in Tax Law and Accounting (Athens University of Economics &Business). He speaks Greek (native), English and French.

GREECE

Georgios I. Katrinakis

Director, Tax LitigationPwC Greece

Athens+30 210 811 4236 (direct)+30 6940 437869 (mobile)[email protected] www.pwc.gr



Greece

Effie AdamidouKPMG

Tassos AnastassiadisPlatis - Anastassiadis & Associates Law Partnership

John DryllerakisDryllerakis & Associates

Georgios KatrinakisPwC See page 204

Spyros MaratosZepos & Yannopoulos

Spyros OikonomidisOikonomidis - Kontos Law Firm

Eftichia PiligouDeloitte See page 180

HUNGARY

Ákos BecherDLA Piper Horváth & Partners Law Firm

Balázs BékésBékésPartners

Michael GloverTaxually

Mihály HarcosDeloitte See page 180

Zsuzsanna HuszlDeloitte See page 180

Pál JalsovszkyJalsovszky Law Firm

Barbara KonczPwC

Tamás LőcseiPwC

Kovács OrsolyaNagy & Trócsányi

Botond RenczEY

Gergely RiszterHegymegi-Barakonyi és Társa Ügyvédi Iroda




Hungary

Levente TormaDLA Piper Horváth & Partners Law Firm

Zoltán VarszegiRéti Várszegi & Partners Law Firm

IRELAND

Brian DuffyWilliam Fry

Joe DuffyMatheson

Michael FarrellKPMG

Shane HoganMatheson

Greg LockhartMatheson

Martin PhelanWilliam Fry

Gavan RylePwC

David SmythEY





ISRAEL

Ofer GranotHerzog Fox & Neeman

Meir LinzenHerzog Fox & Neeman

Leor NoumanS Horowitz & Co

Daniel PasermanGornitzky & Co

Pinhas RubinGornitzky & Co

Ziv SharonZiv Sharon & Co

Yaacov SharvitHerzog Fox & Neeman

Moshe ShekelShekel & Co




Languages: Italian, English, French

BiographyCristiano Caumont Caimi joined Tremonti Romagnoli Piccardie Associati in 2002 and has been a partner since 2009. He spe-cialises in tax litigation, with a special focus on international tax-ation and transfer pricing issues thanks to his LLM inInternational Taxation and two-year work experience at theInternational Bureau of Fiscal Documentation.

Practice areasAPAs, Pre-litigation, MAPs/ADRs, Litigation, International taxadvisory, Transfer pricing

Sector specialisationsAutomotive, Banking, Energy, Industrials, Insurance, Oil andgas, Real estate, Tech and telecoms, Transport

Academic qualificationsDegree (cum laude) in Law, University of Genoa, Italy, 1997LLM in International Taxation (cum laude), University of Leiden, Holland, 2002

ITALY

Cristiano Caumont Caimi

Partner

Tremonti RomagnoliPiccardi & Associati

[email protected]




During his 18-year career Vittorio Giordano has gained a signif-icant amount of experience in trials before the Italian SupremeCourt, the Italian Constitutional Court, the Court of Justice ofthe European Union and the European Court of HumanRights, where he represented taxpayers in highly complex taxand state aid issues.

Indeed, he is one of the few Italian lawyers admitted toappear before the supreme courts when he was just 35 years old,after having passed the relevant exam with full marks. As anintegral part of his practice, Vittorio also provides assistance inthe context of tax audits, settlements procedures and adminis-trative rulings, acts as an expert in criminal tax cases and regu-larly advises clients on income taxes, indirect taxes, propertytaxes, excise duties and tax avoidance, aiming at mitigating therisk of tax disputes arising on their transactions.

Vittorio was born in 1978 and began his career in 2002 withProfessor Franco Gallo, former president of the ItalianConstitutional Court, and became partner of the homonymous law firm in 2013. After tak-ing part in the opening of the Ludovici Piccone & Partners’ Rome office in 2015, Vittorioestablished his own practice in 2017 together with his long-time colleague Andrea Merolle.

Giordano-Merolle – Studio Legale Tributario is a boutique law firm of eight professionalsdeeply specialised in taxation, with offices in Rome and Milan, which provides assistancemainly to banks, insurance companies, MNE and HNWI.

The firm recently advised and represented, inter alia, an Italian Bank for tax topics relatedto a €4 billion securitisation of receivables, an Italian bank for the tax issues related to a sub-ordinated loan amounting to €200 million, a real estate company in a €100 million deemedtax-avoidance trial before the Italian Supreme Court, a foreign bank during a tax audit aimedto challenge the existence of a permanent establishment in Italy, an extra-UE bank for the taxissues related to initiation of banking activity under the regime of authorisation in Italy, amultinational group for the regulation and tax issues related to tax-free shopping activity inItaly, and several individuals regarding various complex law and tax issues concerning assetsand inheritance planning and management.

Italy

Vittorio Giordano

Founding Partner

Giordano – MerolleStudio Legale Tributario

Roma+39 06 87 15 34 [email protected]




Languages: Italian, English

BiographyBorn in 1970, Valentino Guarini graduated in Economics andLaw and joined PwC in 1995. Since then he has worked indomestic and international tax consultancy and developed hisexpertise in dealing with tax controversies before the Courts.The PwC Tax Litigation PwC team is made of 22 professionalsbased in Milan and Rome.

Practice areasCorporate taxes, Dispute resolution, Pre-litigation, Litigation,Tax consulting

Sector specialisationsConstruction and materials, Industrials, Pharma and life sciences

Association membershipsInternational Fiscal Association

Academic qualificationsDegree in Economics, Università La Sapienza – Roma, 1993Degree in Law, Università Marconi – Roma, 2016

Italy

Valentino Guarini

Partner

PwC TLS Avvocati &Commercialisti

Milan+39 02 [email protected]




Languages: Italian – English – Dutch

BiographyPartner of PwC TLS – tax controversy and dispute resolutionleader in Italy. He is a tax lawyer with 24 years of experiencequalified to argue Supreme Court cases and has a doctorate inInternational and Comparative Tax Law (PhD cum laude,University of Groningen, Netherlands).

Recent matter highlights• Leading partner for some of the most significant permanent

establishments and transfer pricing cases for several multina-tionals in Italy

• Mutual Agreement Procedures and International Arbitrationcases

• Advance Pricing Agreements• Court’s success stories before the Italian Supreme Court and

the European Court of Justice

Practice areasPolicy design, Audit defence, Audit support, Pre-litigation, Litigation, Transfer pricing

Association membershipsInternational Fiscal AssociationInternational Bar AssociationIBFD Alumni

Academic qualificationsPhD cum laude University of GroningenNYU researcherLUISS LLM in TaxLaw Degree at university of Naples

Sector specialisationsAviation, Banking, Consumer goods and services, Financial services, Food and beverage,Government and public policy, Healthcare, Industrials, Insurance, Oil and gas, Transport

Italy

Carlo Romano

Partner

PwC TLS Avvocati &Commercialisti

Rome+39 [email protected]




Languages: Italian, EnglishBar admissions: Italian Bar Association (1990), admitted todefend cases before the Court of Cassation (2003)

BiographyFull professor of tax law at the Università Carlo Cattaneo –LIUC, Professor Giuseppe Zizzo has been registered with theMilan Bar Association since 1990, and on the Special Registerof Court of Cassation lawyers since 2003. After many yearsworking with the one of the leading Italian tax law firms, hefounded Studio Zizzo e Associati in 2007.

His main focus is providing assistance during tax audits and taxassessment procedures, as well as representing taxpayers in tax con-troversies before the Tax Courts and the Court of Cassation in awide range of areas relating to international and domestic tax law.

In 2018 he won the Court of Cassation Barrister of the YearAward at the Top Legal Awards.

He is a member of the editorial board of Rassegna Tributaria and of the scientific com-mittee of Corriere Tributario.

Since 1986 he has published two books, numerous articles in professional journals and sectormagazines, essays in collective works, encyclopaedic entries and case notes, mainly on issues deal-ing with international and domestic corporate tax, company reorganisations and tax avoidance.

Practice areas Corporate taxes, Audit defense, Pre-litigation, Dispute resolution, Litigation

Sector specialisations Banking, Energy, Industrials, Shipping, Transport

Association memberships • European Association of Tax Law Professors• Associazione Italiana dei Professori di Diritto Tributario• Associazione Nazionale Tributaristi Italiani (member CFE)

Academic qualifications • Full Professor of Tax Law, Università Carlo Cattaneo – LIUC, since 2005• Associate Professor of Tax Law, Università Carlo Cattaneo – LIUC, from 1999 to 2005• Law Degree (cum laude), University of Palermo

Italy

Giuseppe Zizzo

PartnerZizzo e Associati

Milan+39 02 43 99 84 [email protected]





BiographyGiancarlo Zoppini joined Tremonti Romagnoli Piccardi eAssociati in 1993 and has been a partner since 2000. Based inthe Milan office of the firm, he specialises in tax litigation. Healso provides assistance in advance ruling proceedings, legaldefence in fiscal cases, and he represents taxpayers in casesbefore the Italian Revenue Agency.

Practice areasCorporate taxes, Audit defence, Dispute resolution, Pre-litiga-tion, Litigation

Sector specialisationsBanking, Financial services, Industrials, Real estate, Tech andtelecoms

Association membershipsItalian Accountant Auditor (1996)

Academic qualificationsDegree (cum laude) in Law (University of Bologna) 1991

Italy

Giancarlo Zoppini

Partner

Tremonti RomagnoliPiccardi & Associati






BiographyMarco Cerrato is specialised in domestic, European and interna-tional tax controversies and in tax disputes resolutions throughsettlements, arbitration and mutual assistance procedures. With respect to the consultancy practice, his areas of expertisecover assistance in potential tax controversies and tax penalties,as well as the taxation of trusts, estate tax planning and regular-isation procedures.

In 2015 and 2016 he was a member of the Committee ofExperts on Tax and Economic Policy of the Presidency of theItalian Counsel of Ministries.

He is the author of many publications on tax matters and isa frequent speaker at congresses. Since 2002 he has been a lec-turer of tax law at the Law faculty of the University CarloCattaneo of Castellanza.

Recent matter highlights• In 2019 he represented a leading fashion group in the largest Italian tax settlement on

transfer pricing and permanent establishment issues• He represented a top US group active in the digital economy sector in a tax settlement

concerning the alleged existence of a permanent establishment in Italy

Practice areas• Dispute resolution• Pre-litigation• MAPs/ADRs• Litigation• Controversy management

Association membershipsAdmitted to the Bar in 1995 and admitted to the Supreme Court in 2008.

Academic qualificationsLLM in Tax at the London School of Economics (1997) PhD in Tax at the University of Pavia (2000)

Italy

Marco Cerrato

Partner

Maisto e Associati






BiographyGuglielmo Maisto founded Maisto e Associati in 1991. He is aProfessor of international and comparative tax law at theUniversità Cattolica di Piacenza.

He is President of the Italian Branch of the International FiscalAssociation (IFA), member of the Board of Trustees of theInternational Bureau of Fiscal Documentation (IBFD) inAmsterdam, member of the Advisory Board of the Master ofAdvanced Studies in International Taxation of the LausanneUniversity, member of the Practice Council of New YorkUniversity (NYU) Law’s International Tax Program and memberof the Board of the American Chamber of Commerce in Italy.

He represents the Italian Association of Industries(Confindustria) at the OECD Business Industry AdvisoryCommittee in Paris. He acted as a consultant to the Ministry forEuropean Community Affairs and was a member of the EU Joint Transfer Pricing Forum.He is a member of several law societies and of the editorial board of various Italian and for-eign tax legal journals. He usually participates as a speaker to several annual tax conferences.

Recent matter highlights• In 2019 he represented a leading fashion group in the largest Italian tax settlement on

transfer pricing and permanent establishment issues• He represented an automotive group in a State Aid case before the EU Court of Justice

Practice areasDispute resolution, Pre-litigation, Litigation, Controversy management

Association membershipsItalian Bar Association (1980), Italian Certified Public Auditors Association (1995),International Fiscal Association, The Law Society, American Bar Association, InternationalBar Association, Istituto de Fiscalidad Internacional, Union Internationale des Avocats

Academic qualificationsHe graduated in Law (cum laude) at the University of Genoa and trained at the ECCommission, Directorate General IV. He received a Masters from the University ofAmsterdam.

Italy

Guglielmo Maisto

Founding Partner

Maisto e Associati

Milan+39 02 [email protected] www.maisto.it




Languages: Italian, EnglishBar admissions: Italian Bar Association

BiographyPietro is partner at the Italian tax law firm L&P – LudoviciPiccone & Partners. He has more than 20 years of experience inthe areas of tax controversy and litigation services. He gainedsignificant experience in advising domestic and foreign clients incomplex tax audits, pre-litigation and judicial settlements, anddefence before tax courts and the Court of Cassation.

Recent matter highlights• He provided tax assistance to a group of institutional

investors headed by Värde Partners and Guber Bank on taxmatters related to the €734 million acquisition of an NPLportfolio deriving from a pool of 22 Cooperative CreditBanks.

• He also advised on the €337 million private placement bondissuance of Ingrid Hotels.

Practice areasM&A, Dispute resolution, Pre-litigation, Litigation, International tax advisory, VAT,Registration tax and other Indirect taxes as well as Excise duties and Consumption taxes.

Sector specialisationsAutomotive, Food and beverage, Industrials, Oil and gas, Real estate

Association membershipsIBA

Academic qualificationsDegree in Law, LUISS – Guido Carli University, Rome, 1995Full time specialization program in Tax Law and Tax Accounting, Management SchoolLUISS – Guido Carli University, Rome, 1996

Italy

Pietro Piccone Ferrarotti

Partner

L&P – Ludovici Piccone &Partners

Milan+39 [email protected]



Italy

Maria Antonietta BiscozziEY

Gianluca BoccalatteStudio Biscozzi Nobili (WTS)

Cristiano Caumont CaimiTremonti Romagnoli Piccardi & Associati See page 208

Cristina CaraccioliValente Associati GEB Partners / Crowe Valente

Alessandro CaridiPwC TLS Avvocati & Commercialisti

Aurelia Daniela CasaliDLA Piper

Marco CerratoMaisto & Associati See page 214

Paolo ComuzziQuorum

Roberto Cordeiro GuerraCordeiro Guerra & Associati

Matteo CostiglioloStudio Tributario & Societario - Deloitte See page 180

Nicola CrispinoRödl & Partner

Eugenio della ValleStudio Tributario & Societario - Deloitte See page 180

Marco Di SienaChiomenti

Gabriele EscalarSalvini Escalar & Associati

Barbara FainiBaker McKenzie

Augusto FantozziFantozzi & Associati Studio Legale Tributario

Stefano FedeleStudio Tributario & Societario - Deloitte See page 180

Carlo GalliClifford Chance

Bruno GangemiMacchi di Cellere Gangemi




Italy

Vittorio GiordanoGiordano-Merolle - Studio Legale Tributario See page 209

Valentino GuariniPwC TLS Avvocati & Commercialisti See page 210

Marco LioPwC TLS Avvocati & Commercialisti

Guglielmo MaistoMaisto & Associati See page 215

Alessandro MartinelliDLA Piper

Salvatore MattiaValente Associati GEB Partners / Crowe Valente

Christian MontinariDLA Piper

Renato PaternolloFreshfields Bruckhaus Deringer

Lorenzo PiccardiTremonti Romagnoli Piccardi & Associati

Pietro Piccone FerrarottiLudovici Piccone & Partners See page 216

Giuliana PolaccoBird & Bird

Carlo PolitoSimonelli Associati

Carlo RomanoPwC TLS Avvocati & Commercialisti See page 211

Dario SencarPwC TLS Avvocati & Commercialisti

Andrea SilvestriBonelli Erede Pappalardo Studio Legale

Alessandro TardiolaSimonelli Associati

Antonio TomassiniDLA Piper

Piergiorgio ValenteValente Associati GEB Partners / Crowe Valente

Giuseppe ZizzoZizzo e Associati See page 212




Italy

Giancarlo ZoppiniTremonti Romagnoli Piccardi & Associati See page 213

KUWAIT

Rasheed Al-QenaeKPMG

Zubair PatelKPMG

LUXEMBOURG

Laurent EngelFicel Group

Eric FortArendt & Medernach

John HamesEY

Nadège Le GouellecLoyens & Loeff

Fabienne MoquetPwC

Philippe NeefsKPMG

Jean SchaffnerAllen & Overy

Alain SteichenBonn Steichen & Partners

MALTA

Oleg ChaykaKPMG





Prof. Dr. Stef van Weeghel is PwC’s Global Tax Policy leader.He is also professor of international tax law at the University ofAmsterdam. Prior to joining PwC Stef was partner at law firmsLinklaters (2007-2009) and Stibbe (1987-2007) where hisroles included membership of the Executive Committee, headof tax practice and resident partner in the New York office.

He was chair of the Permanent Scientific Committee of theInternational Fiscal Association (IFA) and is chair of the Boardof Trustees of the International Bureau of FiscalDocumentation (IBFD).

Stef’s focus is on tax policy, strategic tax advice and tax con-troversy. He has extensive experience in cross-border transac-tions, structuring and dispute resolution. He regularly rendersadvice and second opinions to clients and to other advisers, oncorporate income tax and tax treaty matters and is also consult-ed by the Dutch government on a regular basis. He acts ascounsel and as expert witness in tax matters (for taxpayers andfor governments) before Dutch and foreign courts and in arbi-tration pursuant to bilateral investment treaties and in commercial arbitration.

In 2009/2010 he chaired the Study Group Tax System, a committee that advised theDutch government on comprehensive tax reform. In 2000 he was a member of the VanRooy-Committee that advised the Dutch government on corporate income tax reform. Priorthereto he was member of a working group at the Dutch Ministry of Finance that worked onrevision of the Dutch ruling practice.

He also worked on the review of administrative practices in taxation for the EuropeanCommission. On various occassions he appeared as expert before the Finance Committees ofthe Second and First Chamber of the Dutch Parliament and he also appeared before theTAXE-Committee and the PANA-Committee of the European Parliament.

Stef is a frequent speaker at international conferences and authored more than 100 pub-lications on international taxation.

NETHERLANDS

Stef van Weeghel

Global Tax Policy Leader

PwC

Amsterdam+31 0 88 792 [email protected]



Netherlands

Dick BarmentloFT Lawyers

Frits BarnardDeloitte See page 180

Arnaud BooijBooij Bikkers Advocaten

Guido de BontDe Bont Advocaten

Tjebbe GerverdinckLoyens & Loeff

Paul HalprinDentons Boekel

Johan HollebeekDeloitte See page 181

Roel KerckhoffsHertoghs advocaten

Ivo KuipersAtlas Tax Lawyers

Lars MøllerLumen Lawyers

Martien PelinckPelinck Nijssen Weijers Advocaten

Antonio RussoBaker McKenzie

Thies SandersLoyens & Loeff

Erik ScheerBaker McKenzie

Pascal SchrijverDeloitte See page 181

Frans SijbersWladimiroff Advocaten

Marc TemmeKPMG Meijburg & Co

Agata UcedaKPMG Meijburg & Co

Job van der PolOsborne Clarke




Netherlands

Arjo van EijsdenEY

Peter van HagenHertoghs advocaten

Stef van WeeghelPwC See page 220

Edwin VisserPwC

Roelof VosHertoghs advocaten

Eric VroemenPwC

Dennis WeberLoyens & Loeff





Languages: Norwegian, EnglishBar admissions: 2004

BiographyArild has more than 20 years of experience as a tax advisor for alarge group of companies, both stock listed and family owned.He also has extensive experience with tax compliance and con-troversy, is a frequent speaker at tax seminars and has participat-ed in several committees to evaluate newly proposed tax rules.

Practice areas• Corporate taxation• Partnership taxation• Tax compliance• Dispute resolution• M&A

Sector specialisations• Financial services• Private equity• Real estate• Hospitality• Construction• Consumer products

Association memberships• Member of the Norwegian Bar Association

Academic qualifications• Cand jur, University of Oslo, 1999

NORWAY

Arild Vestengen

Partner

EY

Oslo+47 982 06 [email protected]



Norway

Erik Hillestad AasKPMG

Svein Gunnar AndresenKPMG

Finn Backer-GrøndahlThommessen

Einar BakkoSelmer

Morten BeckPwC

Joachim BjerkeBAHR

Finn EideDeloitte See page 181

Anette FjeldDeloitte

Henning HarborgThommessen

Harald HaugeHarboe & Co

Ivar HobbelhagenHarboe & Co

Jan JansenBAHR

Hans Martin JørgensenDeloitte See page 181

Thor LeegaardKPMG

Anders LilandKPMG

Daniel Løken HøgtunSelmer

Marius PilgaardBAHR

Eyvind SandvikArntzen De Besche

Frode TalmoBAHR





Norway

Arild VestengenEY See page 223

OMAN

Ashok HariharanKPMG




BiographyMariusz Marecki is a licensed tax advisor and vice-director in thetax controversy and dispute resolution department in PwCPoland, with more than 25 years’ experience in tax and fiscal law.

Mariusz specialises in assisting PwC clients in high profile andcomplex litigations involving multinational organisations. Withinhis practice, he has been representing clients in course of numer-ous tax and administrative court proceedings, including the pro-ceedings before Supreme Administrative Court in tax cases.

He is also an author of numerous tax publications.

Association memberships• National Chamber of Tax Advisers

Academic qualifications• Law, Warsaw University, 1991

Practice areas• Tax audit defense• Tax audit support• Dispute resolution• Pre-litigation• Litigation• Fiscal liability

Sector specialisations• Energy• Financial services• Food and beverage• Pharma and life sciences• Tech and telecoms

POLAND

Mariusz Marecki

Vice-Director, tax controversy anddispute resolution department inPwC Poland

PwC Poland

Warsaw+48 [email protected]




BiographyJan Tokarski is a licensed tax adviser and a partner leading taxcontroversy and dispute resolution department for PwC Poland.

Jan Tokarski specialises in various aspects of tax-related liti-gations against Polish tax, customs and enforcement authorities,including tax audits, fiscal and tax assessment proceedings. Healso assists clients in the course of administrative court proceed-ings, including proceedings before the Supreme AdministrativeCourt in tax cases.

Within his practice he participated in numerous projectsrelated to VAT issues, specialising in VAT evasion disputes,forensic projects, white collar crime, combating and preventionof tax crimes and mitigation of personal fiscal penal liability.


Academic qualifications• Master of Laws, University of Warsaw, 2004

Association memberships• National Chamber of Tax Advisers

Practice areas• Audit defense• Dispute resolution• Pre-litigation• Litigation• Controversy management• Forensic support• White-collar crime• Fiscal criminal defense

Sector specialisations• Agriculture• Automotive• Consumer goods and services• Food and beverage• Industrials

Poland

Jan Tokarski

Partner, Leader of TaxControversy and DisputeResolution Department

PwC Poland

Warsaw+48 [email protected]/en/services/tax-services.html




BiographyAndrzej Zubik is a director in the tax controversy and dispute res-olution department in PwC Poland. Andrzej has more than 15-years’ experience in all types of tax, social security and other publiclevies disputes. He is specialised in advising and representingmultinational corporations and Polish entrepreneurs before andduring audits, proceedings and litigations and is focused on find-ing and implementing efficient dispute resolution mechanisms.


Academic qualifications• Master of Laws, University of Warsaw, 2004• Diploma in English and European Law – University of

Cambridge (in cooperation with University of Warsaw), 2004

Association memberships• National Chamber of Tax Advisers• Warsaw Chamber of Legal Advisers

Recent matter highlights • Leading advisor in 10+ finished and pending tax audits with values exceeding zł100

million each• Successfully represented the pension fund in the course of the leading Supreme

Administrative Court case concerning the refund of interest resulting from the infringe-ment of EU law by Polish legislator

• Leading advisor in two pending Constitutional Tribunal cases.

Practice areas• Audit defense• Dispute resolution• Pre-litigation• Litigation• Controversy management

Sector specialisations• Automotive• Consumer goods and services• Financial services• Real estate• Tech and telecoms

Poland

Andrzej Zubik

Director, Tax Controversy andDispute Resolution Department

PwC Poland

Warsaw+48 [email protected]



Poland

Tomasz BarańczykPwC

Slawomir BorucBaker McKenzie

Tomasz ChentoszBaker McKenzie

Hanna FilipczykEnodo Advisors

Karina Furga-DąbrowskaDentons

Iwona GeorgijewDeloitte See page 181

Michał GojEY

Piotr KarwatRadzikowski Szubielska & Wspólnicy

Peter KayKPMG

Mariusz KażuchDeloitte See page 181

Robert KrasnodębskiWeil Gotshal & Manges

Katarzyna MaćkowskaMVP Tax

Piotr MaksymiukBaker McKenzie

Dariusz MalinowskiKPMG

Mariusz MareckiPwC See page 216

Jerzy MartiniMartini & Co

Artur NowakDomański Zakrzewski Palinka

Wojciech PietrasiewiczMVP Tax

Cezary PrzygodzkiDentons




Poland

Dorota SzubielskaRadzikowski Szubielska & Wspólnicy

Agnieszka TałasiewiczEY

Jan TokarskiPwC See page 227

Dariusz WasylkowskiWardyński & Partners

Piotr WysockiBaker McKenzie

Andrzej ZubikPwC See page 228





Languages: Portuguese, English and SpanishBar admissions: Member of the Portuguese Bar Association

Biography Francisco operates in the the tax controversy and dispute reso-lution law practice. He has dedicated his entire career to the taxlaw and tax controversy and dispute resolution practice, focus-ing his practice on business taxation, especially in tax litigation,providing regular legal advice to domestic and internationalclients, in respect of all taxes of national law as well as in mattersrelated to social security contributions.

His experience also includes legal advice in tax criminal law.Recently, the International Tax Review recognised him as a TaxControversy Leader. Francisco is also recognised and men-tioned, since 2017, by the international magazine Best Lawyers.

Recent matter highlights • Francisco has been representing several taxpayers in tax liti-

gation matters, regarding CIT, VAT, transfer pricing and customs duties.• Recently, Francisco represented a taxpayer in an administrative tax claim sustaining the

deductibility, for corporate income tax purposes, of the bank levy paid in 2015. Eventhough the current tax law expressly excludes the deduction of such a cost and there is atotal absence of any case law on the matter, the Portuguese Tax Authorities accepted thedeductibility of €1.8 million accounted as bank levy costs.

• Francisco was a speaker in Tax Seminars, organised by PwC Portugal and the ProfessionalBody for Economists, and in several seminars regarding the State Budget 2019.

Practice areasDispute resolution, Pre-litigation, Litigation and arbitration

Sector specialisations • Automotive• Banking• Energy• Food and beverage• Industrials

Academic qualifications• Law Degree, Law Faculty of Catholic University of Oporto (2006)• Post-graduate degree in tax planning and tax controversy, Oporto Business School

(2011).

PORTUGAL

Francisco Castro Guedes

Principal associate of CCR Legal

CCR Legal

Porto+351 221 129 [email protected]




Languages: Portuguese, English, French and Spanish.

BiographyJaime leads the tax practice of PwC Angola, Cabo Verde andPortugal.

He specializes in dispute resolution, national and internationaltax planning (individual and corporate), transfer pricing, mergersand acquisitions, corporate reorganisations, high-net-worth indi-viduals and family business, including family offices. Jaime alsoassists clients investing in Guinea-Bissau, Mozambique and SãoTomé and Príncipe. He is also a Tax Arbitrator.

Recent matter highlightsJaime has been directly involved in the recently created TaxTechnology Department, that will assist PwC’s clients in theautomation of its tax function procedures.As regards the services at the disposal of PwC Portugal clients,it is worth noting that they can be assisted locally or in the investments abroad by CCR Legal,an independent Portuguese law firm and a member of the group of legal services practices ofPwC member firms that provide legal services.

Practice areasRestructuring, Dispute resolution, Arbitration, International tax advisory, Transfer pricing

Sector specialisationsAutomotive, Construction and materials, Consumer goods and services, Oil and gas, Techand telecoms

Association memberships• Jaime is an Executive Director of the Forum para a Competitividade, since 2011.

Academic qualifications• Management Executive Studies at IMD (2010), at INSEAD (2007) and at Universidade

Nova de Lisboa (2003)• Post-graduation in Commercial Law at Universidade Católica Portuguesa, Lisboa, 1997• Post-Graduation in European Studies at Universidade Católica Portuguesa, Lisboa, 1989• Graduation in Law, Universidade Católica Portuguesa, Porto, 1986

Portugal

Jaime Carvalho Esteves

PwC

Lisbon




Portugal

Gustavo AmaralKPMG

António Américo CoelhoKPMG

Frederico AntasVieira de Almeida & Associados

Rosa AreiasPwC

Ana Isabel BatistaGarrigues

Catarina BelimBelim Legal Services

Bruno Botelho AntunesBARV Sociedade de Advogados

António Pedro BragaMorais Leitão Galvão Teles Soares da Silva & Associados

Pedro BrazGarrigues

Serena Cabrita NetoPLMJ

Susana CaetanoPwC

António Castro CaldasUría Menéndez-Proença de Carvalho

José Calejo GuerraJCG Advogados

Rui Camacho PalmaLinklaters

Diogo Tavares CastroPwC

Francisco Castro GuedesCCR Legal See page 231

Fernando Castro SilvaGarrigues

Susana ClaroPwC

Francisco de Sousa da CâmaraMorais Leitão Galvão Teles Soares da Silva & Associados




Portugal

Ricardo da Palma BorgesRicardo da Palma Borges & Associados

Nuno de Oliveira GarciaNobre Guedes Mota Soares & Associados

Patrick DewerbeCMS Rui Pena & Arnaut

Clara Madalena DithmerDeloitte

Rodrigo Rabeca DominguesPwC

Ana DuartePwC

Susana DuarteAbreu Advogados

João EspanhaEspanha & Associados

Jaime Carvalho EstevesPwC See page 232

Samuel Fernandes de AlmeidaVieira de Almeida & Associados

Rogério Fernandes FerreiraRogério Fernandes Ferreira & Associados

Isabel Santos FidalgoMorais Leitão Galvão Teles Soares da Silva & Associados

Filipa Simoes FigueiredoGarrigues

Jorge FigueiredoPwC

João Taborda da GamaGama Glória

Conceição GamitoVieira de Almeida & Associados

Francisco Geraldes SimõesGalhardo Vilão Torres

André GonçalvesTelles Advogados

Catarina GonçalvesPwC




Portugal

Maria GouveiaMorais Leitão Galvão Teles Soares da Silva & Associados

Mariana Gouveia de OliveiraMiranda & Associados

Joana Lobato HeitorVieira de Almeida & Associados

Joaquim Pedro LampreiaVieira de Almeida & Associados

Patrícia Meneses LeiriãoCapitão Rodrigues Bastos Areia & Associados

Gonçalo Leite de CamposGonçalo Leite de Campos & Associados

Antonio Lobo XavierMorais Leitão Galvão Teles Soares da Silva & Associados

Marta Machado de AlmeidaRogério Fernandes Ferreira & Associados

Luis MagalhaesKPMG

Rita MagalhãesVieira de Almeida & Associados

Leonardo Marques dos SantosGama Glória

Tiago Marreiros MoreiraVieira de Almeida & Associados

Elsa Silva MartinsPKF Portugal

Francisco Cabral MatosVieira de Almeida & Associados

José Pedroso de MeloSRS Advogados

Antonio Rocha MendesCampos Ferreira Sá Carneiro & Associados

Paulo MendonçaEY

João Maricoto MonteiroSRS Advogados

Ricardo Seabra MouraVieira de Almeida & Associados




Portugal

Ana Moutinho NascimentoSérvulo & Associados

Paulo NúncioMorais Leitão Galvão Teles Soares da Silva & Associados

Diogo Ortigão RamosCuatrecasas

Ana Rita PereiraRicardo da Palma Borges & Associados

Raquel PetiscaBelim Legal Services

Antonio Moura PortugalDLA Piper ABBC

Ricardo Reigada PereiraRRP Advogados

Ana ReisPwC

Miguel ReisPLMJ

Cláudia Reis DuarteUría Menéndez-Proença de Carvalho

João Riscado RapoulaVieira de Almeida & Associados

Tânia RodriguesDeloitte See page 181

Filipe RomãoUría Menéndez-Proença de Carvalho

Hugo Salgueirinho MaiaPwC

Adrião SilvaPwC

Joana Tavares de OliveiraAAA Advogados

Miguel Teixeira de AbreuAbreu Advogados

Ana Teresa TiagoDLA Piper ABBC

Manuel Anselmo TorresGalhardo Vilão Torres




Portugal

Maria Antónia TorresPwC

Miguel TorresTelles Advogados

Leendert VerschoorPwC

Pedro Vidal MatosCuatrecasas





Languages: Romanian, English, French

BiographyDan is active in litigation (with a special focus on tax, as theCEE leader of the PwC Tax Controversy and DisputeResolution Network) and employment matters. His practiceincludes assistance to clients in front of courts in the field of taxlaw, competition law, commercial law, labour law and civil law.

Recent matter highlights• Steaua Romana (Romanian refinery)- recovering of VAT

unlawfully denied for reimbursement plus related interestand the case C-431/12, at European Court of Justice, whichled to the modification of Romanian legislation.

• Two companies in front of the Romanian courts, convincingthe national courts to refer preliminary questions to theEuropean Court of Justice (ECJ). At this moment Danassists both clients in front of the ECJ (C-68/18 and C-291/18, recently).

Practice areasLitigation, Tax/Administrative disputes/ Commercial, Civil, Employment law

Sector specialisationsAgriculture, Automotive, Banking, Energy, Financial services, Healthcare, Media, Oil andgas, Pharma and life sciences

Association membershipsMember of the Bucharest Bar Association.Acting on behalf of D&B David si Baias and PwC in Romanian American Chamber ofCommerce and Foreign Investors Council in sustaining legislative changes in taxation,employment and commercial law.

Academic qualificationsDan graduated in law from the Bucharest University in 1997. He subsequently obtained apostgraduate diploma from The Hague Academy of International Law in The Netherlands.Dan has a PhD degree in tax contentious matters from the Law Faculty of the BucharestUniversity (2013).

ROMANIA

Dan Dascalu

Partner

PwC

Bucharest+44 0 21 225 [email protected]



Romania

Andreea ArtenieDeloitte See page 181

Dan BadinDeloitte See page 181

Emanuel BancilaEY

Vlad-Constantin BoeriuDeloitte See page 181

Dan DascaluPwC See page 238

Niculae DoneKPMG

Ciprian GavriliuDeloitte See page 182

Cezar GusuGlodeanu & Partners

Alex SlujitoruEY

George SoareGlodeanu & Partners





BiographyAlexei Nesterenko heads the EY Russia tax controversy team.He has more than 18 years of experience supporting multina-tional and local companies, providing services on Russian andinternational tax planning, structuring of cross-border anddomestic transactions and activities. He has a wide experience inmanaging international tax risks in one of the largest public oiland gas company.

Alexei was supporting clients in negotiations with taxauthorities and resolution of tax disputes and taking part inmore than 300 successful court hearings.

At the focus of work is a proactive cooperation with FederalTax Services and development of best practices of horizontalmonitoring (controversy part) and international taxation issues.

Alexey is the author of numerous materials and publicationsin the press, including publications in the journals Tax Disputesand Legal Insight, as well as being a participant in internationaland Russian legal and tax forums and conferences.

Recent matter highlights• Supported a subsidiary of the world’s leading spare car parts manufacturer in challenging

tax audit report concerning intra-group IT services costs• Advised and represented an industry-leading oil and gas service company in challenging

the results of tax audit in relation to beneficial ownership of the distributed dividends,which formed the grounds of a recent Federal Tax Services’ guidance

• Supported a leading development company in confirmation of a reduced withholding taxrate on dividends application (provided for by the Russia-Cyprus Double Tax Treaty)payable to indirect beneficial owner of income

• Supported a sector-leading manufacturer of soft drinks in challenging the position of thetax authority on the requalification of a loan into the contribution to the charter capitalof that manufacturer

• Advised and represented one of Europe’s largest bakery groups in the confirmation of thededuction of losses (capital investments formed under the reconstruction of a factory)

• Supported a leading producer of wood materials in challenging the position of the taxauthority on the application of the preferential tax rate (provided for by the Russia-CyprusDouble Tax Treaty) in respect of dividends paid

• Supported a global consumer goods company in tax monitoring regime (controversy part)regarding the legality of loss record from the acquisition and further liquidation of a legalentity

• Tax health check for the one of the worlds’ biggest beverage manufacturers

RUSSIA

Alexei Nesterenko

Partner, Russia Tax ControversyLeader

EY

Moscow+ 7 495 662 93 [email protected]



Russia

Rustem AhmetshinPepeliaev Group

Galina AkchurinaFBK Legal

Valentina AkimovaPepeliaev Group

Raisa AlexakhinaPwC

Alexey ArtyukhTaxology

Kristina BalevaDentons

Vladislav BozhenkovPwC

Boris BrukDentons

Alexander BychkovBaker McKenzie

Alexander ChmelevBaker McKenzie

Stanislav DenisenkoKPMG

Irina DmitrievaWhite & Case

Dzhangar DzhalchinovDentons

Alexander ErasovBryan Cave Leighton Paisner

Andrey ErmolaevKPMG

Andrey GrachevEversheds Sutherland

Alexander GrigorievFBK Legal

Tatiana GrigorievaFBK Legal

Marina IvlievaPepeliaev Group




Russia

Ivan KhamenushkoPepeliaev Group

Anna KnelzDentons

Oleg KonnovHerbert Smith Freehills

Natalia KordyukovaCliff Legal Service Law Firm

Dmitri KostalginTaxAdvisor

Maria KostenkoBaker McKenzie

Natalia KovalenkoPepeliaev Group

Leonid KravchinskyPepeliaev Group

Sergey LikhachevBryan Cave Leighton Paisner

Ksenia LitvinovaPepeliaev Group

Alexandra LobovaEY

Elena MikhailovskaiaDLA Piper Rus

Maria MikhaylovaPwC

Alexei NesterenkoEY See page 240

Anton NikiforovPepeliaev Group

Andrey NikonovPepeliaev Group

Mikhail OrlovKPMG

Irina Orlova-PaninaKPMG

Alexei PanichHerbert Smith Freehills




Russia

Sergey PepeliaevPepeliaev Group

Kirill PetrovShapovalov Petrov Law Firm

Ilya RybalkinRybalkin Gortsunyan & Partners

Sergey SavserisPepeliaev Group

Denis SchekinSchekin & Partners

Igor SchikowDentons

Arseny SeidovBaker McKenzie

Sergey ShapovalovShapovalov Petrov Law Firm

Andrey TereschenkoPepeliaev Group

Evgeny TimofeevBryan Cave Leighton Paisner

Gennady TimonichevDentons

Ruslan VasutinDLA Piper Rus

Sergei ZhestkovBaker McKenzie

Anna ZverevaDentons

Anton ZykovDeloitte See page 182




SAUDI ARABIA

Ebrahim BaeshenKPMG

SLOVAK REPUBLIC

Martin SabolDeloitte See page 182

Jan SkorkaDeloitte See page 182

SLOVENIA

Dénes SzabóEY





Languages: English, Afrikaans

BiographyElle-Sarah spent 14 years with SARS where she managed anEnforcement Division focusing on High Profile investigations(locally and abroad) and now leads the Tax Controversy &Dispute Resolution function for PwC South Africa where sheassists clients on a daily basis to escalate, manage and resolvecomplicated disputes with SARS.

Recent matter highlights• Assisted clients to release R220m VAT refund in less than

three months (pending seven-month SARS audit) via anurgent High Court application.

• Assisted client in circumventing R6billion add back ofdeductions by proactively engaging as SARS had not fol-lowed due administration process.

• Assisted mining client with a tax dispute in achieving settle-ment that saved them R36million.

Practice areasCorporate taxes, Audit defence, Dispute resolution, MAPs/ADRs, Litigation, Controversymanagement

Association membershipsMaster Tax Practitioner (SAIT), Law Society of South Africa & member of SARIPA

Academic qualificationsBCom (Law), 1999; LLB, 2001; LLM (Corporate Law), 2002; MCom(Tax), 2006 andMBA: 2009

SOUTH AFRICA

Elle-Sarah Rossato

Associate Director: TaxControversy & Dispute Resolution

PwC

Johannesburg+27 011 797 [email protected]



South Africa

Emil BrinckerCliffe Dekker Hofmeyr

Bernard du PlessisENSafrica

Nazrien KaderDeloitte See page 182

Nina KeyserWebber Wentzel

André MeyburghKPMG

Elle-Sarah RossatoPwC See page 245

Muhammad SaloojeeSole practitioner

Johan van der WaltFTI Consulting

Louise VoslooDeloitte See page 182





Languages: English, French and Spanish

BiographyJulio César García is a tax litigation and EU tax law partner atKPMG. He is also the partner in charge of the Corporate TaxPractice at KPMG Abogados, and has broad expertise in corpo-rate taxation.

Recent matter highlightsJulio César has represented some of the largest Spanish IBEX35 companies and most relevant associations before Europeancounts and the EU Commission. He also holds over 20 years ofextensive experience dealing with state and local tax controver-sies at the audit, economic, administrative and state court levels,including National Apellate Court, Supreme Court andConstitutional Court

Practice areasAudit support, Dispute resolution, Litigation, Arbitration, EU state aid, Corporate Incometax and the corporate tax practice

Sector specialisationsAutomotive, Energy, Financial services, Media, Oil and gas

Association membershipsMadrid Bar Association

SPAIN

Julio César Garcia Muñoz

Partner

KPMG Abogados S.L.P.

Madrid+34 [email protected]




Languages: Spanish, English, CatalanBar admissions: Barcelona Bar Association

BiographyWith more than 15 years’ experience as a lawyer, having prac-tised in some of Spain’s best legal firms, Jose Maria García-Valdecasas prides himself on his client-first approach. Thanks tohis academic background in economics (MBA from ESADEBusiness School incorporating an exchange with UCLAAnderson School of Management and studies in finance at TheLondon School of Economics and Political Science) Jose Mariais well placed to get to the bottom of his clients’ problems, bet-ter understand their business goals and offer them finely tailoredadvice. His areas of expertise include the provision of advice oncompany law, family businesses, M&A, corporate law, privateequity, corporate and individual taxation as well as internationaltaxation. He also specialises in defending taxpayers’ interests before the Spanish tax authori-ties and the courts.

He has lectured on national and international taxation at a number of higher educationinstitutions, such as the University of Barcelona, ESADE Business School, ISDE BusinessSchool and the International University of Catalonia.

Practice areasTaxation of family businesses, restructuring (e.g. reorganising processes of company groups),transactions, M&A, corporate taxes of large and multinational business groups (consolidatedtax system), dispute resolution, pre-litigation, litigation, controversy management, tax con-sulting, international tax advisory

Sector specialisationsBanking. Accounting, financial services, construction and materials, investment management,real estate, tourism, tech, media and telecoms.

Academic qualificationsHarvard University, International Executive Program, 2019; The London School ofEconomics and Political Science, Executive Education, Corporate Finance and Strategy,2016; University of California, (Anderson School of Management), MBA ExchangeProgram, 2008; ESADE Business School, Executive MBA, 2008; Centro de EstudiosFinancieros, Master of Taxation, 2004; University of Barcelona, LLB, 2002.

Spain

Jose Maria García-Valdecasas Alloza

Partner

Garcia-Valdecasas & Viola

Barcelona+34 608 070 [email protected]




Languages: Spanish, English, ItalianBar admissions: Barcelona Bar Association

BiographyStella Raventós-Calvo has a long experience in the field of inter-national taxation and taxation of corporations.

Throughout her career she has combined her professionalactivity with education at several Spanish and European institu-tions, renowned at an international level. She has written severalspecialised articles in tax magazines and publications, and is aregular lecturer in Spain and abroad.

She has been the Vice President of the Spanish Associationof Tax Advisors, and as from January 2017, she is President ofthe CFE (Confédération Fiscale Européenne) FiscalCommittee, a confederation that embraces the national associa-tions of tax advisors of the European Union.

Practice areas• Corporate taxes• Tax consulting• International tax advisory• VAT

Sector specialisations• Accounting• Automotive• Fashion industry• Shipping• Services

Association memberships• CFE Fiscal Committee• Spanish Association of Tax Advisors• International Tax Association• Spanish Association of Financial Law

Academic qualifications• Graduate in History (Universidad Autónoma de Barcelona), 1977• Graduate in Law (Universidad de Barcelona), 1985• Master’s Degree in Tax Law (Universidad de Barcelona), 1988-1991

Spain

Stella Raventós-Calvo

Partner

Danbury

[email protected]



Spain

Pedro AguarónBaker McKenzie

Felipe Alonso FernándezGTA Villamagna

María Antonia AzpeitiaBaker McKenzie

Miró AyatsCuatrecasas

María Antonia AzpeitiaBaker McKenzie

Ernesto BenitoPwC

Luis BrionesBaker McKenzie

Javier Gónzalez CarcedoPwC

Julio César Garcia MuñozKPMG See page 247

Álvaro de la Cueva González-CoteraGarrigues

Abelardo Delgado PachecoGarrigues

Jose Diaz-FaesKPMG

Santiago DíezMarimón Abogados

Bruno DominguezBaker McKenzie

Rafael FusterUría Menéndez

Angel Garcia RuizGarrigues

Javier García-Pita RipollésLinklaters

Jose Maria García-Valdecasas AllozaGarcía-Valdecasas & Viola See page 248

Eduardo GardetaGarrigues




Spain

Eduardo GraciaAshurst

Agnès GranésKPMG

José Ignacio Guerra GarciaGarrigues

Alberto HerasRamón & Cajal Abogados

Juan Manuel Herrero de EgañaDeloitte Legal See page 182

Federico LinaresEY

Maximino LinaresEY

Ramon Lopez de HaroDeloitte Legal See page 182

Jesús López TelloUría Menéndez

Miguel LoránOsborne Clarke

José Manuel de BunesDeloitte Legal See page 182

Juan MolinaDeloitte Legal See page 182

Antonio PuentesPwC

Alejandra PuigDeloitte Legal See page 183

Esteban RaventósBaker McKenzie

Stella Raventós-CalvoDanbury Legal See page 249

Carlos Reviriego GomezPwC

Luis Enrique Rodríguez OteroDeloitte Legal See page 183

Ana RoyuelaBaker McKenzie




Spain

Javier Ruíz CalzadoLatham & Watkins

Manuel SáezCasals Abogados

Raúl Salas LúciaRoca Junyent

Manuel Santa María FernándezGarrigues

Enrique Seoane SmithDeloitte Legal See page 183

Montserrat TrapéKPMG

José Vicente Iglesias GómezGarrigues

Esther Zamarriego SantiagoGarrigues

Adolfo ZunzuneguiAllen & Overy





Mac Berlin is the managing partner of Skeppsbron Skatt, a lead-ing independent firm of tax advisers in Sweden.

Mac has wide experience advising clients across a broadrange of issues and he brings long experience in Swedish andinternational corporate taxation, predominantly working withmergers and acquisitions and real estate related matters, as wellas with tax disputes and tax audits.

Mac has previously worked in a Big 4 firm. He has a master’sdegree in law.

SWEDEN

Mac Berlin

Skeppsbron Skatt – Taxand

Stockholm+46 73 640 91 [email protected]




Hans has over 30 years’ experience as a legal adviser in corpo-rate taxation with a special focus on tax disputes and resolution.Hans has a background as a judge and has been active in theAdministrative Court and the Court of Appeal.

Practice areasCorporate TaxTax Disputes and resolutionEU law

Academic qualitificationsLL.M., Lund University

AccreditationAuthorized tax adviser

MembershipsFAR

Sweden

Hans Eklund

KPMG Sweden

Göteborg +46 31 61 48 [email protected]




Magnus Larsén is a corporate tax partner at Skeppsbron Skatt.He is a lawyer and has 20 years of experience working in thefield of Swedish and international taxation.

Magnus brings long experience in corporate and internation-al tax advisory, with deep expertise in international structuredfinancial transactions and mergers and acquisitions (M&A).

He deals with companies in most sectors, specialising particu-larly in the banking, large corporate and private equity industries.

Magnus has, over the years, been appointed to lead complexmajor disputes for large companies.

Before joining Skeppsbron Skatt, Magnus headed part ofMorgan Stanley’s tax structured finance business.

Magnus is also engaged as a speaker and panel member at taxseminars and conferences, besides being a member of Taxand’ssteering group for global M&A.

Sweden

Magnus Larsén






Languages: Swedish, English

BiographyLennart has been practising for approximately 25 years as a pro-fessional tax adviser. He has extensive experience of Swedish andinternational corporate taxation. Lennart has experience also ofhelping clients with all aspects of enquiries and tax disputes,including tax audit support, tax litigation and assisting inadvance ruling procedures.

Practice areas• Financial services• Corporate taxes• Audit support• Litigation• International tax advisory

Sector specialisations• Banking• Financial services• Industrials• Insurance• Investment management

Association membershipsCertified Tax Advisor by FAR, the institute for the accountancy profession in Sweden.

Academic qualificationsLLM at the University of Uppsala in 1986.

Sweden

Lennart Staberg

Tax Partner

PwC

Stockholm+46 709 [email protected]




BiographyPär Magnus heads the transfer pricing team of PwC in Sweden.With a background in corporate finance and tax law he supportsSwedish and international clients with their international taxstrategies and assists with various dispute work (tax audits,MAPs, APA and court litigations) in the field of transfer pricing.

Practice areasIP management, Restructuring, Audit defence, Litigation,Transfer pricing

Sector specialisationsBanking, Consumer goods and services, Financial services,Industrials, Investment management

Association membershipsFAR, IFA

Academic qualificationsMaster of Laws, Uppsala University, 1994-2000Master of Business Administration and Economic, Uppsala University, 1996-2000Studies in Finance, University of Miami, 1997-1998

Sweden

Pär Magnus Wiséen

Tax Partner

PwC

Stockholm+46 [email protected]




Joakim Wittkull is a partner at Skeppsbron Skatt and the leaderof the tax controversy team of Skeppsbron Skatt. He is a lawyerand has more than 20 years of experience working in the fieldof Swedish and international taxation.

Joakim has a wide experience advising clients across abroad range of sectors. As a professional tax adviser he hasalways focused on assisting clients in tax disputes and taxaudits. He is often engaged in complex major disputes andhas represented clients successfully in some of the most sub-stantial tax cases in Sweden.

For seven consecutive years, Joakim has been recognised byInternational Tax Review as a tax controversy leader.

Joakim has worked as an associate judge in Swedish taxcourts. He has a master’s degree in law. He is often engaged asa speaker and panel member at tax seminars and conferences.

Sweden

Joakim Wittkull


Stockholm+46 73 640 91 [email protected]/en/business-areas/tax-litigation





BiographyHead of Svalner’s tax litigation practice. Fredrik has experiencefrom the Swedish civil courts and tax courts, international arbi-tration and the European Court of Justice and was previously amember of the Swedish Bar.

Recent matter highlightsFredrik has acted as counsel in several high profile cases over theyears, e.g. in cases related to the private equity industry andcases regarding interest deductions.

Practice areas• Restructuring• Transactions• Financial services• Litigation• International tax advisory

Sector specialisations• Financial services• Industrials• Investment management• Real estate• Tech and telecoms

Academic qualificationsMaster of Laws, Lund University

Sweden

Fredrik Berndt

Partner

Svalner






BiographyUlrika Grefberg, Partner at Svalner in Stockholm, has 20+ years’experience advising on VAT, tax M&A, tax rulings and litiga-tion. Ulrika advises some of Sweden’s leading corporate andgovernment clients in all aspects of indirect tax. She is also anappreciated lecturer and regularly leads training sessions on avariety of tax aspects.

Practice areas• VAT• Customs• Excise Duties• Litigation• State Aid

Sector specialisations• Energy• Healthcare• Media• Transport• Investment Management

Association memberships• VAT Group• WTS

Academic qualifications• Master of Laws, Uppsala University, 1990

Sweden

Ulrika Grefberg

Partner

Svalner





BiographyFredrik has extensive expertise in Swedish and international tax-ation. He advises on capital markets solutions, cross bordertransactions, restructurings and tax litigation across many indus-tries and for a wide variety of clients.

Practice areas• Restructuring• M&A• Corporate taxes• Tax consulting• International tax advisory

Sector specialisations• Consumer goods and services• Financial services• Gaming• Industrials• Tech and telecoms

Sweden

Fredrik Sandefeldt

Senior Tax Partner

Svalner

Stockholm+46 0 [email protected]



Sweden

Mylene BeimingPwC

Ulrika BengtssonVinge

Mac BerlinSkeppsbron Skatt See page 253

Fredrik BerndtSvalner See page 259

Hans EklundKPMG See page 254

Anders ErasmieMannheimer Swartling

Lars FranckDeloitte See page 183

Ulrika GrefbergSvalner See page 260

Niklas HagbardMannheimer Swartling

Erik HultmanEY

Magnus JohnssonPwC

Magnus LarsénSkeppsbron Skatt See page 255

Lennart LarssonSkatteanalys Advokatbyrå

Magnus LarssonDeloitte See page 183

Mika MyllynenPwC

Martin NilssonMannheimer Swartling

Peter NordquistPeter Nordquist Advokatbyrå

Fredrik SandefeldtSvalner See page 261

Lennart StabergPwC See page 256





Sweden

Pär Magnus WiséenPwC See page 257

Joakim WittkullSkeppsbron Skatt See page 258




Languages: English, French, German

BiographyJean-Blaise Eckert is considered as a leading lawyer in tax andprivate client matters in Switzerland. He is the co-head of thetax group of Lenz & Staehelin. He advises a number of multi-na-tional groups of companies as well as HNWIs.

Jean-Blaise Eckert is a frequent speaker at pro-fessional con-ferences on tax matters. He is Secretary General of theExecutive Committee of the IFA. The “exceptionally knowl-edgeable” Jean-Blaise Eckert represents multinational clients incross-border tax litigation and advises private companies oncountry-by-country reporting legislation. He also assists withimport tax issues.

Practice areasTax, private clients, succession law, commercial and contracts,investigations

Memberships and other activitiesNeuchâtel Bar; Secretary General of IFA; Board Member of Compagnie FinancièreRichemont SA, PSA International SA, Gonet & Cie SA and Banque Pâris Bertrand SA.

SWITZERLAND

Jean-Blaise Eckert

PartnerLenz & Staehelin

[email protected] www.lenzstaehelin.com



Switzerland

Denis BerdozBaker McKenzie

Peter BrülisauerDeloitte See page 183

Harun CanSwissVAT

Sarah DahindenPwC

Marcus DesaxWalder Wyss

Jean-Blaise EckertLenz & Staehelin See page 264

Pierre GilliozGillioz Dorsaz & Associés

Pierre-Marie GlauserOberson Avocats

Marco GreterAltorfer Duss & Beilstein

Andreas HelbingAltorfer Duss & Beilstein

Jackie HessDeloitte See page 183

Niklaus HonauerPwC

Benjamin KochPwC

Hans KochBaker McKenzie

Ferdinando MercuriDeloitte See page 183

Xavier ObersonOberson Avocats

Per Prod’homPython

Britta RehfischAltorfer Duss & Beilstein

Raoul StockerDeloitte See page 183

Markus WyssKPMG





Languages: EnglishBar admissions: Istanbul Bar Association

BiographyZeki Gündüz is a partner at PwC Turkey and he leads the country’stax practice. He also leads the PwC Turkey tax controversy and disputeresolution team. With his extensive experience, Zeki is considered asone of the foremost experts in the field of tax and customs litigation.

Recent matter highlightsBefore joining to PwC, Zeki worked for the Ministry of Financeas an auditor for eight years; he performed numerous tax auditsof private companies and state institutions.

Zeki has led PwC Turkey’s pharmaceutical industry and thetransfer pricing, client training and tax/customs disputes busi-ness units of PwC Turkey. He has represented a broad range ofcorporate clients on various tax and customs related dispute res-olution projects for about 27 years.

He is concentrated on the big global firms, which are pro-viding digital services such as social and professional network-ing, social media and e-commerce companies.

Practice areasCorporate taxes, Technology, Dispute resolution, Litigation, Controversy management, Tax consulting

Sector specialisationsAccounting, Government and public policy, Healthcare, Media, Pharma and life sciences,Tech and telecoms

Association membershipsZeki, a sworn financial adviser (YMM) and lawyer, is also an educator and is a regular speaker attax forums and seminars organised by PwC, the Istanbul Chamber of Sworn Financial Advisors(İYMMO), the Istanbul Chamber of Certified Public Accountants (İSMMMO), publication hous-es, professional associations and other institutions. Zeki is admitted to Istanbul Bar Association.

Alongside his professional interests, Zeki is a member of the Turkish Industrialists andBusinessmen’s Association (TÜSİAD) Tax Commission and the board of TransparencyInternational and IFA in Turkey; he is personally invited to the Tax Council Turkey. Zeki isthe author of various articles and supplements in periodicals as well as PwC publications.

Academic qualificationsZeki has graduated from the Ankara University Faculty of Law.

TURKEY

Zeki Gündüz

Partner, leader of country taxpractice and tax controversy anddispute resolution

PwC Turkey

Istanbul+90 212 326 60 [email protected]/tr




Languages: EnglishBar admissions: İstanbul Bar Association

BiographyErsin Nazalı is an expert in taxation. He has worked as a TaxSpecialist for nine years, and has extensive knowledge and experi-ence in tax matters including tax reviews, tax evaders, transfer pric-ing, companies’ tax restructuring areas. As of August 2012, Ersinworks as a tax consultant and attorney in the private sector. Ersinhas also published more than 100 articles in several tax journals and5 books (Taxation of Merger-Acquisition and Spin-off, InternationalTaxation, Permanent Establishment, Transfer Pricing, Tax-Civil-Criminal Liabilities of Company Directors) on the tax law.

Recent matter highlightsThe main difference of NAZALI is that we provide regular legalservices and services in the fields of tax law, social security and cus-toms through its partners and employees experienced in both public and private sectors. Inthis respect, our firm offers tax, social security and labor law, customs and foreign trade, generallegal services, accounting, fraud risk management and internal systems services to the clients.

Practice areasCompetition law, Business model optimisation, Restructuring, Corporate taxes, Litigation,Tax consulting, Corporate and commercial law, IP, M&A, Social security, Capital markets andfinancial law, Criminal law, Personal data protection law, Dispute resolution, Customs

Sector specialisationsConstruction and materials, Industrials, Investment management, Shipping, Tech and telecoms

Association membershipsAmerican Chamber of Commerce (AMCHAM), International Association of Restructuring,AIJA – International Association of Young Lawyers, Swedish Chamber of Commerce,International Fiscal Association, International VAT Association, International Bureau ofFiscal Documentation (IBFD), International Tax Review, British Chamber of Commerce inTurkey, The Blockchain Turkey Platform (BCTR)

Academic qualificationsAnkara University, Political Science, 2001Dicle University, Faculty of Law, LLB, 2012İstanbul University, MSc, Financial Law, 2018King’s College London, School of Law, LLC, 2012

Turkey

Ersin Nazalı

Managing Partner

NAZALI Tax&Legal

İstanbul+90 (212)[email protected]/en




Languages: EnglishBar admissions: Istanbul Bar Association

BiographyEzgi Turkmen is the leader of the team that provides disputeconsultancy on corporate and indirect tax issues. She is spe-cialised in tax law and she provides consultancy in settling thetax or customs disputes of companies from various sectors bothby administrative and judicial ways.

Recent matter highlightsEzgi is very experienced in disputes about the taxation of digitaleconomy and highly complex transfer pricing disputes in varioussectors. With her sophisticated approach in litigation processes,which applied ECHR (European court of Human rights) to thetax disputes, she made a substantial contribution to the judicialprecedent in Turkey.

She has focused on big global digital economy companiesand multinational clients. These clients operate in various sec-tors including retail, media, social media, social networking, microblogging and professionalnetworking industries. Her experiences in corporate tax disputes also includes indirect tax dis-putes and the tax amnesty process in Turkey.

Practice areasAPAs, Corporate taxes, Technology, Dispute resolution, Litigation, Controversy manage-ment, Tax consulting

Sector specialisationsConstruction and materials, Consumer goods and services, Energy, Media, Tech and tele-coms, Utilities

Association membershipsEzgi has participated in many seminars and training programmes as a lecturer and traineralong with organising seminars and in-house client training. She is also a founding memberof IFA Turkey and admitted to Istanbul Bar Association. Together with being a lawyer, sheis a certified public accountant (SMMM). She is also admitted to İstanbul Bar Association.

Academic qualificationsAnkara University, Faculty of Law

Turkey

Ezgi Turkmen

Partner, Tax & Customs DisputeResolution

PwC Turkey

Istanbul+90 212 326 64 [email protected]/tr



Turkey

Ahmet CangözDeloitte See page 183

Niyazi ComezDeloitte See page 184

Refik Yaşar DurusoyDeloitte See page 184

Erdal EkinciEsin Attorney Partnership

Duygu GültekinEsin Attorney Partnership

Zeki GündüzPwC See page 266

Abdulkadir KahramanEY

Ersin NazalıNAZALI See page 267

Orhan PalaEsin Attorney Partnership

Yuksel ToparlakPwC

Ezgi TurkmenPwC See page 268

Bilgutay YasarPwC




UKRAINE

Tetyana BerezhnaVasil Kisil & Partners

Zhanna BrazhnykPwC

Igor DavydenkoDentons

Viktoriya FomenkoIntegrites

Danylo GetmantsevJurimex

Vladimir KotenkoEY

Maksym LavrynovychLavrynovych & Partners

Kostiantyn LikarchukKinstellar

Oleh MarchenkoMarchenko Danevych

Oleksandr MarkovRedcliffe Partners

Vadim MedvedevAvellum Partners

Alexander MininWTS Tax Legal Consulting / KM Partners

Anastasiya MosunovaKPMG

Svitlana MusienkoSayenko Kharenko

Vitaliy OdzhykovskyySayenko Kharenko

Sergiy PopovKPMG

Andrey PronchenkoPwC

Yroslav RomanchukInternational Legal Center EUCON

Artem SeredaallTax




Ukraine

Victor SeredaallTax

Alexander ShemiatkinWTS Tax Legal Consulting / KM Partners

Andriy StelmashchukVasil Kisil & Partners

Mykola StetsenkoAvellum Partners

Illya SverdlovDLA Piper

Vyacheslav VlasovPwC

Hennadiy VoytsitskyiBaker McKenzie

Tatiana ZamorskaKPMG

UNITED ARAB EMIRATES

Anbreen KhanDeloitte See page 184

Robert PeakeCragus Group

Mark StevensCragus Group





Biography Kevin’s entire career has focused on resolving tax disputes, includ-ing nearly 20 years at HMRC and more than 10 years at KPMG.

He has experience of helping corporate and private clients pro-tect against, manage and resolve a wide variety of tax disputes.

Association membershipsKevin is a CEDR accredited mediator and assists clients withAlternative Dispute Resolution.

Recent matter highlights Kevin has assisted:• A global pharmaceutical group in successfully appealing a

discovery assessment issued by HMRC seeking to deny anyrelief for a £69m royalty payment.

• A corporate client that had received a discovery assessmentfrom HMRC going back 20 years based on an assertion thatthe business had deliberately submitted incorrect tax returnsby manipulation of stock valuation.

• A US headquartered group with the voluntary disclosure oftransfer pricing adjustments in several countries.

Practice areas • Tax authority enquiry management• Pre-litigation dispute resolution including ADR

UNITED KINGDOM

Kevin Elliott

Director: Tax Investigations &Dispute Resolution

KPMG LLP

London+44 (0)20 7311 [email protected]/xx/en/home/services/tax/dispute-resolution-controversy.html



United Kingdom

Graham Aaronson QCJoseph Hage Aaronson

Roopa AitkenGrant Thornton

Kate AlexanderBaker McKenzie

David AndersonPwC

James AndersonSkadden Arps Slate Meagher & Flom

Michael AndersonJoseph Hage Aaronson

Shaun AustinDeloitte See page 184

Philip BakerField Court Tax Chambers

Rupert Baldry QCPump Court Tax Chambers

Mark BevingtonADE Tax

Sandy BhogalGibson Dunn & Crutcher

Richard Boulton QCOne Essex Court

Giovanni BraccoPwC

John Brinsmead-Stockham QC11 New Square

Amanda BrownKPMG

Andy BrownBird & Bird

Helen BuchananFreshfields Bruckhaus Deringer

Stephen CammPwC

Alex ChadwickBaker McKenzie




United Kingdom

Murray ClaysonFreshfields Bruckhaus Deringer

Jason CollinsPinsent Masons

Michael Conlon QCTemple Tax Chambers

Adam CraggsReynolds Porter Chamberlain

Mark DelaneyBaker McKenzie

Paul DennisEY

Nigel DolmanBaker McKenzie

Karen EcksteinWomble Bond Dickinson

Jessica Susannah EdenBaker McKenzie

Steve EdgeSlaughter and May

Kevin ElliottKPMG See page 272

Paul FarmerJoseph Hage Aaronson

Liesl FichardtQuinn Emanuel Urquhart & Sullivan

Richard FletcherBaker McKenzie

Alison Foster QC39 Essex Chambers

Philippe FreundFieldfisher

Malcolm Gammie QCOne Essex Court

John Gardiner QC11 New Square

Heather GethingHerbert Smith Freehills




United Kingdom

Julian Ghosh QCPump Court Tax Chambers

Ian Glick QCOne Essex Court

David HarknessClifford Chance

Diane HayPwC

James HendersonPump Court Tax Chambers

Andrew HinsleyRSM

Andrew Hitchmough QCPump Court Tax Chambers

Julie HughffDeloitte

David HumeDeloitte

Chris Hutley-HurstCarey Olsen

Ian HydeOsborne Clarke

David JamiesonBaker McKenzie

Oliver JarrattDeloitte

Richard JeensSlaughter and May

Annis LampardDeloitte See page 184

Mike LaneSlaughter and May

Sarah LeeSlaughter and May

Geoff LloydEY

Sara LuderSlaughter and May




United Kingdom

Jason MarshDeloitte

David Milne QCPump Court Tax Chambers

Eddie MorrisDeloitte See page 184

Stephen MorsePwC

Dan NeidleClifford Chance

Peter NiasPump Court Tax Chambers

Patrick O’GaraBaker McKenzie

Christopher OrchardPwC

Conall PattonOne Essex Court

Jonathan Peacock QC11 New Square

Kevin Prosser QCPump Court Tax Chambers

Michael Ripley11 New Square

Dominic RobertsonSlaughter and May

Aidan Robertson QCBrick Court Chambers

David SalehClifford Chance

Giles SalmondEversheds Sutherland

Jonathan SchwarzTemple Tax Chambers

David Scorey QCEssex Court Chambers

Heather SelfBlick Rothenberg




United Kingdom

Nicola Shaw QCGray’s Inn Tax Chambers

Rupert ShiersHogan Lovells

Tony SinglaBrick Court Chambers

Alan SinyorBryan Cave Leighton Paisner

Nick SkerrettSimmons & Simmons

James StaceySlaughter and May

Kelly Stricklin-Coutinho39 Essex Chambers

Stuart WalshPinsent Masons

William WatsonSlaughter and May

Simon WhiteheadJoseph Hage Aaronson

Mark WhitehousePwC

Simon WilksPwC

James WilsonEY

Zizhen YangPump Court Tax Chambers



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