tax controversy leaders - international tax revie · tax controversy leaders the comprehensive...

Tax ControversyLeadersThe comprehensive guide to the world’s leadingtax controversy advisers

www.internationaltaxreview.com/taxdisputes

SIXTHEDITION

1 | www.internationaltaxreview.com TAX CONTROVERSY LEADERS

8 Bouverie Street, London EC4Y 8AX, UKTel: +44 20 7779 8308Fax: +44 20 7779 8500

Managing editor Caroline [email protected]

Editor Anjana [email protected]

Deputy editor Joe [email protected]

Reporter Amelia [email protected]

Deputy editor, TP Week.com Joelle [email protected]

Production editor Nitesh [email protected]

Publisher Oliver [email protected]

Associate publisher Andrew [email protected]

Business manager Brittney [email protected]

Senior marketing executive Sophie [email protected]

Marketing executive Anna [email protected]

Subscriptions manager Nick [email protected]

CEO, Legal Media Group Matthias Paul

SUBSCRIPTIONS AND CUSTOMER SERVICESCustomer services:+44 20 7779 8610UK subscription hotline:+44 20 7779 8999US subscription hotline:+1 800 437 9997

© Euromoney Trading Limited, 2016. The copyright of alleditorial matter appearing in this Review is reserved by thepublisher.

No matter contained herein may be reproduced, duplicatedor copied by any means without the prior consent of theholder of the copyright, requests for which should beaddressed to the publisher. Although Euromoney TradingLimited has made every effort to ensure the accuracy of thispublication, neither it nor any contributor can accept anylegal responsibility whatsoever for consequences that mayarise from errors or omissions, or any opinions or advicegiven. This publication is not a substitute for professionaladvice on specific transactions.

Directors John Botts (Chairman), Andrew Rashbass (CEO),Colin Jones, The Viscount Rothermere, Sir Patrick Sergeant,Paul Zwillenberg, David Pritchard, Andrew Ballingal,Tristan Hillgarth

International Tax Review is published 10 times a year byEuromoney Trading Limited.

This publication is not included in the CLA license.

Copying without permission of the publisher is prohibitedISSN 0958-7594

Contents

2 Introduction and methodology

402 Index of firms

3 GlobaloverviewTroubled waters– globaltransparencyand controversyin uncertaintimes

8 Argentina

9 Australia

27 Austria

32 Belgium

43 Brazil

54 Bulgaria

55 Canada

82 Chile

84 China

104 Colombia

106 Croatia

106 Cyprus

107 Denmark

107 Ecuador

108 Finland

112 France

126 Germany

143 Greece

144 GulfCooperationCouncil

145 Hong Kong

151 Hungary

155 India

166 Indonesia

173 Ireland

174 Italy

184 Japan

191 Luxembourg

193 Malaysia

198 Mexico

211 Netherlands

219 New Zealand

222 Norway

225 Peru

226 Philippines

229 Poland

232 Portugal

234 Puerto Rico

235 Romania

239 Russia

251 Singapore

259 South Africa

263 South Korea

270 Spain

280 Sweden

292 Switzerland

301 Taiwan

306 Thailand

307 Turkey

313 Ukraine

316 UK

332 USThe top US taxcontroversies in2016

391 Venezuela

395 Vietnam

TAX CONTROVERSY LEADERS www.internationaltaxreview.com | 1


IntroductionTax litigation experts are increasingly in demand astax authorities around the world expand theirresources to audit the tax affairs of big firms andchallenge any irregularities.Global trends this year have centred on how

governments worldwide are implementing theOECD’s recommendations in the base erosion andprofit shifting (BEPS) project, leading to a numberof disputes arising as taxpayers and authoritiesadjust to new standards and mechanisms.In Europe, the European Commission’s state aid

investigations are unravelling agreements held bet -ween multinationals and governments. The Euro -pean Commission’s decision that requires Ireland toobtain $14.5 billion in back taxes from Apple over“illegal” state aid is just one example of a rulingagainst a US multinational enterprise in recent years.Apple and Ireland are appealing the Commission’sruling, as are Luxembourg and the Netherlands forthe Commission’s state aid deci sions that wentagainst Fiat and Starbucks, res pect ively, in October2015. Moreover, the Danish gov ernment will inves-tigate hundreds of taxpayers with potential unde-clared offshore assets after announc ing that it will purchase data leaked in the Panama Papersscandal. Reliable expert advice regarding such tax audits, investigations, disputes and litigationhas never before been more valuable for businesses and governments alike.In the US, the Internal Revenue Service continues to pursue transfer pricing issues and is

aggressively litigating transfer pricing cases.With all of this in mind, it is clear that taxpayers need access to lawyers and advisers with

experience in all stages of tax controversy. The remit of tax controversy advisers now extendsfar beyond the courtroom with many taxpayers seeking advice on tax dispute prevention tech-niques. In addition, many tax controversy advisers provide services on tax audit managementpractices, global strategic planning of tax audits and disputes, tax risk management, analysisand disclosure, mutual agreement procedures, advance pricing agreements and alternative taxdispute resolution.We hope that this sixth edition of the Tax Controversy Leaders guide will provide you with

the confidence to obtain reliable and trustworthy advice in each of the areas highlightedabove, in each of the 53 jurisdictions covered.

Anjana Haines, Editor, International Tax Review

Methodology

Tax Controversy Leaders is a guideto the leading tax dispute resolutionlawyers and advisers in the world. Inaddition to highlighting tax profes-sionals, the guide also includes liti-gators and barristers who may notpractise tax on a day-to-day basis.Inclusion in this guide is based

on a minimum number of nomina-tions received. Besides the requirednumber of nominations, entrantsmust also possess evidence of out-standing success in the past year andconsistently positive feedback frompeers and clients. Firms and individ-uals cannot pay to be recommendedin the Tax Controversy Leadersguide.



Enhanced tax transparency, tax efficiency, and improved tax dis-pute resolution mechanisms are driving themes in today’s globaltax landscape, given the promulgation of new disclosurerequirements and automatic exchange of information at thecentre of agendas of both governmental and non-governmentalorganisations. The OECD’s country-by-country reporting(CbCR) template, recommended in Action 13 of its base ero-sion and profit shifting (BEPS) project, is significantly impact-ing how multinational enterprises (MNEs) look at the tax func-tion within their organisation, and is generating concerns overthe public disclosure of reported data. There is also uncertaintyover how the data will be interpreted by tax authorities from arisk assessment perspective, and the potential for an increase inaudits and disputes worldwide. At the same time, the European Commission’s state aid

investigations into certain rulings received primarily by US-based MNEs, and the Commission’s recent decision to requireApple to retroactively pay $14.5 billion in unpaid taxes, are alsocausing chaos in the global tax environment – creating evenmore uncertainty for MNEs that obtained tax rulings originallythought to be in compliance with international standards.Moreover, these state aid investigations have been questioned asundermining the OECD’s efforts to reduce tax avoidancethrough its BEPS initiatives, including CbCR, and thereby lead-ing to a new era of global tax transparency and increased con-troversy.

Tax transparency – dawn of a new era Transparency is one of the fundamental pillars of the OECD’s

Global

David SwensonPwC

Troubled waters – globaltransparency and controversyin uncertain timesDavid Swenson, global leader of PwC’s tax controversy and dispute resolution network, looks athow the OECD’s BEPS project is changing the tax controversy and disputes landscape and thepotential pitfalls that may emerge as certain jurisdictions do not commit to the multilateralinitiatives.



Global

BEPS initiatives, partly accomplished through the OECD’s BEPS Action 13 on the TransferPricing Documentation and CbCR. Action 13 recommends a three-tiered approach that includes a master file, a local file, and

a CbCR template for multinationals to report income, taxes paid, and economic activity ona country-by-country basis that will collectively move disclosure and transparency for taxadministrations to new, unprecedented levels. Standing alone, the disclosure of the global allocation of income, taxes paid, and econom-

ic activity via the CbCR initiative is intended to serve as a ‘risk assessment tool for tax author-ities’. Tax authorities will, however, view the master file and local file in parallel with theCbCR to rationalise the CbCR results as a beginning point in deciding whether to initiate atransfer pricing audit. The consequential effect is that the three filings will enable tax administrations to use the

reported information to perform data analytics, identify transfer pricing risks, deployresources to more effectively assess such risks, and commence audits with more informationon hand. Unfortunately, the data may be susceptible to misunderstanding and misinterpretation by

tax administrations and other stakeholders. The end result will likely be a more volatile auditand dispute environment.Numerous countries have promulgated domestic legislation implementing the CbCR

measure, which will be automatically exchanged between jurisdictions through the multilat-eral Convention on Mutual Administrative Assistance in Tax Matters, bilateral tax treaties ortax information exchange agreements (TIEAs), or other government-to-government mech-anisms, such as the Multilateral Competent Authority Agreement (MCAA) on the exchangeof country-by-country reports.In addition, the European Commission has announced proposals that would require the

public reporting of CbCR, which is now back in the spotlight following the Commission’srecent decision to require Ireland to retroactively recoup $14.5 billion in taxes from Apple.According to the Commission, public reporting of employees, activities, turnover, and taxespaid will provide greater transparency into the tax arrangements and agreements betweenMNEs and governments in Europe.

EU state aid cases – increased uncertainty in MAP casesSeparately, the Commission’s Apple decision may increase uncertainty for MNEs that haveobtained tax rulings and advance pricing agreements that were previously thought to complywith international norms. BEPS Action 13 requires a listing of such rulings and agreements within the master file

(and in fact, a copy as part of the local file) as a means to provide enhanced transparency. But,the European Commission’s state aid investigations go one step further in questioning thevalidity of transfer pricing principles agreed upon between MNEs and governments. TheCommission’s interpretation of the state aid doctrine and retroactive recoveries could under-mine mutual cooperation and multilateral progress in addressing international tax avoidancethrough the OECD’s BEPS project, and, in turn, could create a divide in the architecture ofthe new international structure that is meant to be predictable, fair, and efficient.The mutual agreement procedures (MAP) process under bilateral income tax treaties is



one of the primary mechanisms through which cross-border tax disputes are resolved.Unfortunately, due to disagreement over the application of certain international norms, theEuropean Commission’s approach in state aid matters may lead to audits and controversiesthat are difficult or impossible to resolve through the MAP process. If this concern materi-alises in practice it will lead to more uncertainty and potentially to an increase in double tax-ation in bilateral cases around the world.The bottom line is that these increased tax reporting requirements and the sharing of sen-

sitive data and information, along with state aid investigations that call into question thevalidity of long-standing international standards, on a collective basis may inevitably result ina new era of tax controversy leading to an increase in the number and size of audits and dis-putes and a far greater risk of multiple taxation of the same items of income.

Managing risk in the new era of global tax controversyPre-emptive measures, such as performing ‘strategic risk assessments’ as part of the processof compiling the information to be reported through BEPS Action 13, will become a keycomponent of a broader, coordinated approach to preventing and managing audits and dis-putes worldwide and will become a necessary and essential part of risk prevention strategies.This will necessitate a holistic approach to enhancing the compilation, sharing, and documen-tation of data that necessarily includes technological solutions. Re-allocation of resources toa centralised hub for audit and controversy functions will also become critical in developingand maintaining consistent defensive strategies on a global basis, as well as in monitoring theresolution of audits and assessing the potential impact that disputes may have on overallresults. In certain circumstances, pre-audit strategies (such as early communications and negotia-

tions with tax authorities) can provide certainty for taxpayers and correspondingly reduce therisk of future audits and disputes. These alternative resolution options do not, however,address the fundamental concern that increased reporting requirements and exchange ofinformation will create widespread transparency into the business activities of MNEs for taxauthorities worldwide – with governments each performing their own independent riskassessments, initiating audits, and assessing income and tax adjustments. As a result, the riskof double (or even multiple) taxation will be compounded and exponential pressure will con-tinue to be placed on the MAP process. Moreover, the European Commission’s state aidinvestigations will add an additional layer of complexity into the resolution of treaty-relateddisputes through MAP. EU member states may find it difficult to comply with their obliga-tions under bilateral tax treaties to provide relief for double taxation through MAP withrespect to a state aid decision, given that the interested treaty partners would not be part ofthe European Commission’s decision, and accordingly, may lack the fundamental frameworkthrough which a treaty-related dispute can be resolved.

Making dispute resolution mechanisms more effectiveThe OECD’s BEPS Action 14 on ‘Making Dispute Resolution Mechanisms More Effective’is aimed, in part, at minimising the risks of uncertainty and double taxation by ensuring con-sistent and appropriate implementation of the MAP process under bilateral tax treaties. Thefinal report provides that countries will commit to developing ‘minimum standards’ in the

Global



Global

context of treaty-related disputes and will ensure effective and efficient implementation of thestandards through the establishment of a peer-based monitoring process. The minimum stan-dards are complemented by a number of best practices designed to meet three guiding prin-ciples, namely:• Ensuring that treaty obligations relating to MAP are fully implemented in good faith andthat MAP cases are resolved in a timely manner;

• Ensuring implementation of administrative processes that promote the prevention andtimely resolution of treaty-related disputes; and

• Ensuring that taxpayers have access to MAP when eligible. Moreover, the OECD has indicated that 20 countries have committed to providing

mandatory binding arbitration in their bilateral tax treaties as a means to guarantee thattreaty-related disputes are resolved within specified timeframes. This has been considered aremarkable move forward as collectively these 20 countries were involved in more than 90%of outstanding MAP cases at the end of 2015. Nevertheless, concerns remain that a numberof important G20 countries have not yet committed to mandatory binding arbitration andthe increase in the global MAP case inventory in future years may be largely attributable tothose countries. The final report clearly reflects a deep understanding of the difficult problems faced by,

and some potentially created by, tax administrations as BEPS initiatives are implemented –problems that can only be addressed on a multilateral basis with full accountability and trans-parency. To this end, additional work on the formation and implementation of a peer moni-toring mechanism is deemed critical and necessary to ensure that the minimum standardswere in fact satisfied. The MAP Forum within the OECD’s Forum on Tax Administration, along with the

OECD’s Working Party No. 1 on Tax Conventions and Related Questions, have been giventhe directive to develop and implement a peer review mechanism. Over the course of 2016,progress has been made in developing this mechanism with the aim to implement the peerreview process towards the end of 2016, and with the first reviews being delivered in 2017to the OECD Committee on Fiscal Affairs. The core documents for the peer monitoringprocess will include ‘terms of reference’ and the ‘assessment methodology’ that will includea roadmap upon which committed countries will be assessed along with ensuring that assess-ments across all countries will be consistently applied. Thus, tax administrations also will beheld to a new level and different types of ‘transparency’ in handling cross-border disputes andMAP cases.

ConclusionTransparency is at the forefront of today’s global tax environment as one of the driving forcesto prevent tax avoidance by MNEs. The reality is that increased tax reporting requirements and the sharing of information will

inevitably result in an increased number of audits and disputes that will further stress theMAP processes and will increase the risk of double taxation. Separately, the European Commission’s state aid investigations show no signs of slowing

down and will add a layer of complexity to increased tax disputes. Hence, the OECD’s work on BEPS Action 14 is an integral component of the overall



BEPS initiatives – the success of which will depend on responsible tax administration througha commitment to the minimum standards and cooperation in the peer monitoring mecha-nism. In this dynamic global environment, MNEs are encouraged to adopt a proactive strategic

approach to considering the structure of the tax function in the tax controversy space, witha view to enhancing the ability to prevent, manage, and resolve tax audits and disputes world-wide.

Global



Argentina

Mariano BalloneTeijeiro & Ballone Abogados

Martín BarreiroBaker & McKenzie

Maria Ines BrandtMarval, O’Farrell and Mairal

Enrique Guillermo Bulit GoñiBulit Goñi & Tarsitano

Jorge DamarcoBruchou, Fernandez Madero & Lombardi

Horacio Garcia PrietoMarval, O’Farrell and Mairal

Eduardo Gil RocaPwC

Rafael González ArzacMitrani Caballero Ojam & Ruiz Moreno

Gloria GurbistaTeijeiro & Ballone Abogados

Liban A KusaBruchou, Fernández Madero & Lombardi

Alvaro Luna RequenaLuna Requena & Fernandez Borzese Abogados

Santiago MontezantiEstudio Beccar Varela

Susana Camila NavarrineAsorey & Navarrine

Luis Marcelo NúñezPérez Alati, Grondona, Benites, Arntsen & Martínez de Hoz

Juan Manuel Soria AcuñaRosso Alba, Francia & Asociados

Alberto TarsitanoBulit Goñi & Tarsitano

Guillermo TeijeiroTeijeiro & Ballone Abogados

Miguel TesónEstudio O’Farrell



Michael Bersten has been a senior partner within the PwCAustralia tax controversy and dispute resolution (TCDR) prac-tice since founding the practice in 2004. The practice now com-prises 30 professionals and eight partners.Michael is a member of the TCDR global leadership team

and leads the PwC TCDR practice in the Asia Pacific region. Healso leads PwC’s global general anti-avoidance rules team and ischairman of the PwC Australia tax policy panel. Michael is amember of the firm’s global tax policy core group and is activein the BEPS debate.As a Big 4 firm partner since 2001, Michael has acted in

many of the major tax controversies in Australia, predominantlyin the publicly listed and global business sectors. His workranges from legal services in relation to reviews, audits, disputesand litigation to strategic advice on tax risk management andlegal advice on major transactions, especially on Part IVA.Michael has extensive experience assisting clients in the

assessment and management of their tax controversies (audits,disputes and litigation) and tax risk in Australia. He consultsglobally, particularly in Asia.As the former Australian Taxation Office (ATO) deputy chief tax counsel and deputy

Australian government solicitor, Michael has a strong understanding of ATO policy and prac-tice, and experience at assisting clients achieve the best possible outcomes in negotiationswith the ATO.

Australia

Michael Bersten

PwC

201 Sussex StreetSydney NSW 2000Australia

Tel: +61 2 8266 6858Email:[email protected]:www.pwc.com/taxcontroversy



Fiona Craig, Deloitte Australia, has 20 years of experience withDeloitte UK and Deloitte Australia, including 15 years special-ising in transfer pricing. Fiona’s primary focus is in the globallydynamic area of transfer pricing controversy, providing strategicand practical advice to taxpayers engaging with revenue author-ities on both audit defence and advance pricing agreement mat-ters.Her impressive track record in achieving successful transfer

pricing outcomes includes experience in implementing and pric-ing tax efficient structures for large listed and privately ownedmultinational organisations and obtaining subsequent fiscalagreements.Fiona advises clients in a variety of sectors with particular

focus on the energy and resources, technology and pharmaceu-tical sectors.

Australia

Fiona Craig

Deloitte Australia

Grosvenor Place225 George StreetSydney NSW 2000Australia

Tel: +61 2 9322 7770Mobile: +61 410 045 300Email: [email protected]: www.deloitte.com



James Fabijancic, Deloitte Australia, is the national leader of theAustralian legal practice specialising in the areas of tax contro-versy and litigation services. James has over 15 years of experi-ence assisting clients in complex dispute matters against theAustralian revenue authorities. He has acted for a number ofhigh profile multinationals, major corporates and high wealthgroups in relation to rulings, reviews, audits, settlements andhas instructed in numerous Federal Court and Tribunal matters,working with Australia’s leading tax barristers. He has been involved in a range of diverse matters relating

to international tax, transfer pricing, R&D tax concession enti-tlements, withholding tax, corporate tax issues and the applica-tion of the general anti-avoidance rule (GAAR), includingappearance at the GAAR Panel. James works with his clientsthrough the full range of the dispute life cycle from transactionimplementation with “audit readiness” support, defence strate-gy and planning and Part IVC and declaratory relief applica-tions. James holds a BCom/LLB from the University of Mel -

bourne, is a member of the Tax Institute and Law Institute ofAustralia and was part of the working group in relation to therecent Australian foreign investment reforms.

Australia

James Fabijancic

Deloitte Australia

Level 14, 550 Bourke StreetMelbourne Victoria 3000Australia

Tel: +61 3 9671 7370 Mobile: +61 404 049 545Fax: +61 3 9691 8442Email:[email protected]: www.deloitte.com



Greg Janes, Deloitte Australia, is a senior corporate tax partnerwith more than 35 years of experience in income tax. Greg hasachieved national prominence as an adviser in relation to com-plex tax controversy matters. He is recognised by the London-based International Tax Review as one of Australia’s leadingpractitioners in tax controversy matters. He has specialised intax controversy for more than 10 years at Deloitte where he hassuccessfully acted for a range of high profile clients in respect ofAustralian Taxation Office (ATO) audit activity and formal tax-ation disputes.Before joining Deloitte, Greg held numerous key leadership

roles within the ATO, including: assistant commissioner, largebusiness and international segment, a role which he held forseven years; senior tax counsel, group head – appeals and reviewprogramme; and leader of the ATO’s complex audit programmein Victoria.

Australia

Greg Janes

Deloitte Australia

550 Bourke Melbourne 3000Australia

Tel: +61 (03) 9671 7508Mobile +61 0414 942 589Fax : +61 (03) 9691 8175Email: [email protected]: www.deloitte.com



Mark Kenny, Deloitte Australia, has 31 years’ experience in pro-viding taxation services, specialising in international tax andtransfer pricing. His experience includes implementing and pric-ing tax efficient structures for large listed and privately ownedmultinational enterprises.Mark has managed both transfer pricing reviews and audits

(including a joint audit involving two tax jurisdictions), as wellas the negotiation of advance pricing agreements. Mark advises clients in a variety of sectors with a particular

focus on manufacturing, engineering, technology, pharmaceuti-cals, and retail including luxury goods.

Australia

Mark Kenny

Deloitte Australia

Grosvenor Place225 George StreetSydney NSW 2000Australia

Tel: +61 2 9322 7578Mobile: +61 419 205 001Email: [email protected] Website: www.deloitte.com



Ashley King is a tax controversy partner with PwC and has 30years’ tax experience, including 20 years with the AustralianTaxation Office (ATO). Ashley has achieved national promi-nence and is regularly called upon by the media and the tax pro-fession for his views on tax controversy matters in Australia.Ashley was one of the youngest tax officers to have been pro-moted to the position of assistant commissioner in the ATO in2001, and was senior assistant commissioner (large business andinternational division) when he left the ATO to join PwC in2007.Ashley specialises in advising clients in different industries on

the strategic management of ATO reviews, audits and disputes,including negotiating settlements and advising on tax auditdefence. Ashley has a deep knowledge of ATO policies and deci-sions impacting tax controversy including settlements, rulings,audits, access visits, information and assessment powers and thegeneral anti-avoidance rule (GAAR), and has deep relationshipsacross the ATO. Ashley brings unique insight to tax issues andhas acted as witness and expert witness in numerous tax matters,for both the ATO and clients.By combining his extensive ATO experience and insight,

Ashley has been instrumental in negotiating numerous large tax audit settlements in thebanking, investment, mining, oil and gas industries, including disputes in relation to cross-border finance, investment structures, transfer pricing and anti-avoidance provisions. He hasalso successfully assisted many clients in obtaining positive ATO rulings.Ashley graduated from the University of New South Wales with a master’s degree in tax

law and from the University of Canberra with bachelor degrees in commerce and accounting.Ashley is a registered tax agent and chartered tax adviser, and represents the Australia andNew Zealand Chartered Accountants on the ATO’s dispute resolution committee. Ashley isalso a member of the Australian Tax Institute’s legal and dispute resolution committee.

Australia

Ashley King

PwC

Freshwater Place2 Southbank BoulevardSouthbank VIC 3006Australia

Tel: +61 3 8603 0363Mobile: +61 4 0199 4371Email: [email protected]:www.pwc.com/taxcontroversy



Jonathon Leek, Deloitte Australia, is a solicitor and barristerwith more than 20 years of experience as a tax specialist.Jonathon is experienced in advising Australian and multina-

tional enterprises in relation to direct and indirect taxes on thefull range of corporate, commercial, and financial transactionsand projects.He has extensive knowledge and experience of obtaining tax

rulings, managing tax audits and risk reviews, objecting againstassessments, appealing to courts and tribunals, and negotiatingsettlements, including by mediation.Jonathon is also experienced in acting for clients operating in

a broad range of industries including energy, resources, realestate, infrastructure, financial services, media, communica-tions, and technology.

Australia

Jonathon Leek

Deloitte Australia

Tower 2, Brookfield Place123 St Georges TcePerth WA 6000Australia

Tel: +61 8 9365 7960Email: [email protected]: www.deloitte.com



Paul McCartin is a partner in PwC Australia’s tax controversyand dispute resolution team. Paul has over 18 years of tax experience and joined PwC after

12 years working at senior levels of the Australian TaxationOffice (ATO). Paul specialises in pre-litigation dispute resolu-tion and has achieved outstanding results for clients. While atthe ATO, Paul performed a variety of senior compliance andtechnical roles including working as an assistant commissionerin the public groups and international and the aggressive taxplanning business lines. Paul is a former ATO Competent Auth -ority and was also the ATO’s delegate on the Joint InternationalTax Shelter Information Centre (JITSIC) based in WashingtonDC from 2009-2010. In an environment of increasing revenue authority collabo-

ration, Paul’s ATO and international tax administration experi-ence is recognised and highly sought after by clients to assistthem to resolve a range of complex international disputes.Paul uses his ATO technical and compliance experience, cou-

pled with his understanding of the ATO and international taxadministration ‘mindset’, to specialise in assisting clients tostrategically and effectively manage risk reviews, audits andobjections.Paul has particular expertise in managing disputes with the ATO having resolved a num-

ber of significant and complex matters for listed public companies, private groups and high-net wealth individuals.

Australia

Paul McCartin

PwC

Freshwater Place2 Southbank BoulevardSouthbank Vic 3006Australia

Tel: +61 3 8603 5609+61 412 861 551

Email: [email protected]:www.pwc.com/taxcontroversy



Paul McNab is a solicitor and senior tax partner at PwC Aus -tralia and is a member of the tax controversy and dispute reso-lution (TCDR) practice. He has more than 30 years of taxationexperience, including eight years in the Australian Tax ationOffice (ATO) compliance branch, where his work included anumber of high-profile investigations and the management ofthe resulting litigation and prosecutions. Over the last 20 yearsin private practice he has had extensive experience in assistingclients understand the tax risks they face and manage their inter-actions with the ATO. His work has included reviews of signif-icant transactions, assistance with the assessment and disclosureof tax risk to statutory auditors, management of audits by theATO and the negotiation of settlements and preparation for andconduct of litigation.Paul holds an LLB from the Queensland University of

Technology and an LLM, with honours, from Sydney Univer sity. He is a chartered tax adviser and is entered on the roll ofthe High Court of Australia. He has conducted cases in theAdministrative Appeals Tribunal, the Federal Court of Australiaand the High Court.He has a strong background in working with companies whose value is significantly driven

by intangible assets. He has worked on a number of disputes involving the interaction ofAustralia’s transfer pricing rules and the general anti-avoidance rule (GAAR). Over the lastyear, he has worked with many global groups (especially US multinationals) on their respons-es to the Australian government’s BEPS initiatives. He has published extensively on (andmanaged in practice) tax issues in relation to intangible asset-based business models and themanagement of related transfer pricing disputes.

Australia

Paul McNab

PwC

201 Sussex StSydneyAustralia

Tel: +61 (02) 8266 5640Email: [email protected]:www.pwc.com/taxcontroversy



Eddy Moussa is a practising tax lawyer with over 17 years ofexperience in providing legal advice on taxation matters such asfinancing, international and domestic restructuring and mergerand acquisition transactions.Eddy is a partner in the PwC tax controversy team. He pro-

vides legal advice to mainly multinational clients on taxationmatters (including anti-avoidance), and supports clients inresolving disputes with the Australian Taxation Office. Thiswork involves assisting clients under audit or investigation.Eddy also leads alternative dispute resolution processes, briefscounsel and provides anti-avoidance opinions.He has also advised a number of multinational enterprises on

international tax issues including cash repatriation, investmentstructuring, withholding tax and treaty issues.Eddy also has an interest in the taxation of intellectual prop-

erty in Australia and has written papers on the topic.He is on the NSW state council of the Tax Institute of

Australia and the NSW professional development committee ofthe Tax Institute of Australia and has published papers on taxa-tion anti-avoidance.Eddy has bachelor degrees in business and law, and a mas-

ter’s degree in tax. He is a qualified solicitor of the Supreme Court of NSW, practitioner ofthe Federal and High Court of Australia, a registered tax agent in Australia, and a CTA ofthe Tax Institute of Australia.

Australia

Eddy Moussa

PwC

Darling Park201 Sussex StreetSydney NSW 2000Australia

Tel: +612 8266 9156Mobile: +614 1311 1161Email: [email protected]:www.pwc.com/taxcontroversy



Peter Murray is a pre-eminent tax adviser with more than 30years’ experience. He is recognised as a leading Australian taxlawyer in Doyles’ Guide to the Australian Legal Profession.Peter leads the Hall & Wilcox tax controversy and dispute

resolution practice, which now comprises 12 professionals andfive partners. Formerly, Peter was a senior partner of KPMG anda founding partner of KPMG Law. Peter is also a past presidentof The Tax Institute – Australia’s premier tax industry body.Peter is active in tax policy development and participates in taxpolicy consultation with the Treasury and the Australia TaxationOffice (ATO).Peter is an external member of the ATO’s general anti-avoid-

ance rule (GAAR) panel, which advises the ATO on the appli-cation of the GAAR to issues arising out of tax audits, investi-gations and private ruling requests from taxpayers. He is also a fellow of the Institute of Chartered Accountants,

a chartered tax adviser and on the roll of the High Court ofAustralia. Peter has extensive experience acting for public and privately

owned corporate groups (both listed and internationally owned,and high-net wealth families) in the management of riskreviews, audits, disputes and litigation. Peter also advises on major transactions, including inrelation to the potential application of Part IVA. His specific areas of specialisation include assisting clients in the assessment and manage-

ment of their tax disputes and providing advice on corporate group reorganisations, mergersand acquisitions, including domestic, inbound and outbound investment, thin capitalisationand debt/equity, capital/revenue characterisation, tax consolidation and repatriation of prof-its.Peter’s clients include a range of multinational, public and private entities, professional

services firms and high-net worth family groups across a broad range of industries.

Australia

Peter Murray

Hall & Wilcox

Level 11, Rialto South Tower525 Collins StreetMelbourne, VIC 3000Australia

Tel: +61 3 9603 3683Email: [email protected]:www.hallandwilcox.com.au



Simon Rooke is a legal partner in PwC’s Melbourne tax contro-versy practice.Simon specialises in working with clients to resolve complex

and sometimes intense disputes with the Australian TaxationOffice (ATO).Simon has 20 years of taxation experience, including 12

years in international tax and M&A tax, which have led to sev-eral significant ATO investigations, up to and including litiga-tion. Simon has been recognised in 2009 and 2011 as one ofAustralia’s leading tax advisers in International Tax Review’sguide to the world’s leading tax firms.Simon has extensive experience in assisting clients manage

ATO disputes, including ATO risk reviews, ATO audits, settle-ment negotiations, 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

the increasingly aggressive ATO approach to information gath-ering, to seeking private binding rulings on contentious taxmatters, to assisting companies with ‘ATO readiness’ during ini-tial public offerings, to litigation against the ATO when other avenues of dispute resolutionare exhausted.Simon holds bachelor degrees in commerce and law. He is a chartered accountant in

Australia and New Zealand, a chartered tax adviser, holds a graduate diploma in appliedfinance and a graduate diploma in legal practice. Simon is also a member of the Law Instituteof Victoria and a member of the Law Council of Australia’s business law section.

Australia

Simon Rooke

PwC

2 Southbank BoulevardSouthbankMelbourne 3006Australia

Tel: +61 3 8603 4133+61 4 2200 4038

Email: [email protected]:www.pwc.com/taxcontroversy



Judy Sullivan is a legal partner – tax controversy – and the nation-al leader for tax litigation and alternative dispute resolution(ADR) at PwC.Judy holds a BEc/LLB from the Australian National Univer -

sity and LLM from Sydney University. She is a member of theadvisory panel to the Board of Taxation and a member of theAustralian Taxation Office (ATO) dispute resolution workinggroup. She is also a chartered tax adviser (The Taxation Inst -itute) 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 25 years, Judy has guided multinationals, major corpo-

rates and high-net wealth individual clients through tax reviews,audits, negotiations and litigation across all areas of federal andstate taxes. She has run or worked on seminal Australian taxcases in the Administrative Appeals Tribunal, Federal Court andHigh Court, as well as the NSW Supreme Court. She instructsand works with the leaders of Australia’s tax 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 approaches.Judy has extensive expertise across these topics and other important areas such as

resources and private equity.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.

Australia

Judy Sullivan

PwC

201 Sussex StreetSydney NSW 2000 Australia

Tel: +61 2 8266 0197Email: [email protected]:www.pwc.com/taxcontroversy



Jacques van Rhyn, Deloitte Australia, is an international tax andtransfer pricing partner and leader of the national transfer pric-ing practice. He is a qualified attorney and has been practisingfor more than 20 years, several of which were spent leadingnational and regional transfer pricing teams in the Big 4 firms.Before relocating to Australia in 2009, Jacques was the

Africa regional transfer pricing leader for another Big 4 firm. Hehas gained extensive experience serving clients across Africa,Australia and Asia Pacific in various industries including energyand resources, mining and oil field services, automotive andpharma ceuticals. Jacques has managed several multi-jurisdic-tional international tax and transfer pricing projects for multina-tional groups, ranging from global business reorganisations,global documentation, intellectual property (IP) tax planningand dispute resolution. He provides service across multiple countries leveraging his

strong global networks, knowledge of the OECD guidelines,double tax treaties and in-country transfer pricing rules, andawareness of revenue authorities’ enforcement of these rules invarious jurisdictions including South Africa, Australia, China, UK and other African coun-tries. Jacques has led a number of significant transfer pricing cases and audits, and negotiatedfavourable advance pricing agreements in several jurisdictions. Jacques has been listed in Euromoney’s guide to the world’s leading transfer pricing advis-

ers in both South Africa and Australia. He is a regular presenter at various international taxand transfer pricing conferences and forums, and is a contributor to various tax and industrypublications.

Australia

Jacques van Rhyn

Deloitte Australia

Woodside PlazaLevel 14, 240 St Georges TerracePerth, WA 6000Australia




Angela Wood is the national lead partner of the tax dispute res-olution and controversy team with KPMG Australia. Angela isalso the Asia Pacific leader within KPMG International’s globaltax dispute resolution and controversy services network. With 20 years’ experience representing the Australian Tax -

ation Office (ATO) and taxpayers in tax litigation and disputeresolution at KPMG, Angela assists multinationals, large privategroups and high-wealth individuals to successfully navigate toefficient and early resolution of disputes at all points along thetax controversy continuum. She gets involved in early-engage-ment with the ATO at the transaction stage, through torequests for rulings, ATO risk reviews and audits, along withobjections and litigation. Angela’s Australian and ASPAC practice focuses on effective

management of tax dispute risk across a range of industries,including energy, mining, finance, automotive, infrastructure,IT/technology and retail. She has extensive experience in dis-pute management in relation to transfer pricing, income tax,general anti-avoidance provisions and Australia’s recently enact-ed Multinational Anti-avoidance Law. To bolster taxpayer posi-tions, Angela specialises in multi-jurisdictional evidence gather-ing, designed to positively influence outcomes in alternative dispute resolution processes inreviews, audits and litigation.Prior to joining KPMG Australia, Angela was a partner in an Australian law firm, where

she represented the ATO in relation to its most significant and complex tax litigation in theFederal Court of Australia and High Court of Australia.

Australia

Angela Wood

KPMG Australia

147 Collins StreetMelbourne, Vic 3000Australia

Tel: +61 3 9288 6408Email:[email protected] Website: www.kpmg.com/au



Australia

Howard AdamsEY

Sarah BlakelockKPMG

David Bloom QCNew Chambers

Michael CloughKing & Wood Mallesons

Gregory J Davies QCVictorian Bar

John W de Wijn, QCVictorian Bar

David DrummondKPMG

Sarah DunnKPMG

Tony FrostGreenwoods & Herbert Smith Freehills

Adam GibbsKPMG

Stewart GrieveJohnson Winter & Slattery

Cameron HansonHerbert Smith Freehills

Dixon HearderBaker & McKenzie

Andrew HirstGreenwoods & Herbert Smith Freehills

Ross HockingKPMG

Lyndon JamesPwC

Chris KinsellaMinter Ellison

Angelina LaganaKPMG

Peter Le HurayPwC



Australia

Nicholas MavrakisClayton Utz

Geoff McClellanHerbert Smith Freehills

Carmen McElwainMinter Ellison

Craig MilnerCorrs Chambers Westgarth

Alan MitchellHerbert Smith Freehills

Ben OpieKPMG

Adrian O’ShannessyGreenwoods & Herbert Smith Freehills

Trevor PascallCrowe Horwath Australia

Alex PatrickKPMG

Hugh PaynterHerbert Smith Freehills

Chris PeadonNew Chambers

Michael PerezKing & Wood Mallesons

Mark PooleKPMG

Mark Richmond SCEleven Wentworth Chambers

Cameron RiderPwC

John SalvarisKPMG

Brendan Sullivan SCTenth Floor Chambers

Reynah TangJohnson Winter & Slattery

Tom Tha----wley SCNew Chambers



Australia

John WalkerBaker & McKenzie

Anthony WatsonGreenwoods & Herbert Smith Freehills

Paul WenkHerbert Smith Freehills



Herbert Greinecker is a partner and head of the Austrian trans-fer pricing team. He joined the firm in 1985 and has more than31 years of professional experience in advising domestic andmultinational enterprises in national and international legal andtax matters.Herbert has been involved in a number of transfer pricing

projects covering tax planning, transfer of functions (value chaintransformation) and transfer pricing documentation aspects. Heserves a large number of subsidiaries of international corpora-tions in Austria as well as Austrian based multinational clients.He has intense tax audit experience, mostly on transfer pricingmatters, and assisted clients in obtaining advance rulings, as wellas negotiating advance pricing agreements. Further, Herbert isa frequent speaker at conferences and seminars on transfer pric-ing related matters as well as an author in the field of transferpricing.Herbert holds an MBA from the Vienna University of Eco -

no mics and a doctorate from the University of Vienna. Herbertis a member of the Austrian Chamber of Accountants as a cer-tified public accountant and tax adviser, member of the taxexperts board of the Austrian Chamber of Accountants and several working groups thereof,and member of the Austrian branch of the International Fiscal Association.

Austria

Herbert Greinecker

PwC

Erdbergstrasse 2001030 ViennaAustria




Bernhard Groehs, Deloitte Austria, is the managing partner. Hispractice includes mergers and acquisitions, structured invest-ments and strategic consulting in public sector projects. Histeam includes more than 15 specialised litigation experts.Bernhard has specialised in tax and criminal tax law for manyyears, and has been a court-certified expert since May 2014.Bernhard has written more than 100 pieces published in all

leading Austrian legal magazines and publications. He has beena teaching assistant at the Law University of Economics,Vienna, and a member of the University of Vienna law faculty. Bernhard is a member of the Austrian Institute of Certified

Public Accountants, the International Association of Boalt HallAlumnis (IABA), the International Fiscal Association, Rotary,and the Board of CFO Club Austria.

Austria

Bernhard Groehs

Deloitte Austria

Renngasse 1/Freyung1013 ViennaAustria

Tel: +43 1 53700 5500; +43 1 53700 99 5500; +43 664 80537 5500

Email: [email protected]: www.deloitte.at



Alexander Lang, Deloitte Australia, joined in 2003 and leadsthe tax litigation and fiscal penal law team. The team supportsclients in all types of national and international disputes with taxauthorities. In fiscal penal law matters the team defends clients’tax positions in tax audits and before Austria’s Tax Court ofAppeal and the Administrative Supreme Court (VwGH). Alexander is a certified public accountant (CPA) and a certi-

fied tax consultant. He is a certified fiscal penal law expert andlectures on tax litigation and criminal tax law at the law facultyof the University of Vienna. He studied law and businessadministration at the University of Vienna and the University ofEconomics. Alexander has published various articles in all lead-ing Austrian legal magazines and publications.

Austria

Alexander Lang

Deloitte Austria


Tel: +43 1 53700 6650 Fax: +43 1 53700 99 6650 Mobile: +43 664 80537 6650 Email: [email protected] Website: www.deloitte.at



Robert Rzeszut, Deloitte Austria, is a tax adviser who specialisesin procedural tax law. He has been with the firm since 2007. Heworks in the tax litigation team assisting international corpora-tions, medium size businesses, and private clients. He alsodefends clients in fiscal criminal law procedures and preparesself-disclosures to help clients become retroactively compliant. Robert gained experience by defending his clients’ tax posi-

tion in tax audits and subsequently before Austria’s Tax Courtof Appeal and the Administrative Supreme Court (VwGH).Further more, Robert managed mutual agreement proceduresinvolving several jurisdictions to avoid double taxation in closecooperation with other Deloitte member firms. Robert Rzeszut studied business and law at the Vienna Uni -

ver sity of Economics and at Wake Forest University, NorthCarol ina, US. He also holds a procedural law degree from theAus trian Chamber of Tax Advisers.

Austria

Robert Rzeszut

Deloitte Austria


Tel: +43 1 53700 6620Email: [email protected] Website: www.deloitte.at



Austria

Franz AlthuberDLA Piper

Matthias BaritschDLA Piper

Imke GerdesBaker & McKenzie

Johannes KautzDLA Piper

Michael KotschniggKotschnigg

Roman LeitnerLeitner & Leitner

Barbara PolsterKPMG

Dr Orlin RadinskyBKP (Brauneis Klauser Prandl)

Niklas SchmidtWolf Theiss

Claus StaringerFreshfields Bruckhaus Deringer

Andreas StefanerEY

Benjamin TwardoszWolf Theiss



Patrick Boone is the Belgian managing partner for tax and legalservices, and representative in the PwC global transfer pricingnetwork.Patrick joined PwC in 1994. He has obtained relevant expe-

rience in corporate structuring and restructuring from a domes-tic and international perspective. In 1999 and 2000, Patrickworked in PwC’s London transfer pricing group and gainedadditional experience with respect to transfer pricing and valuechain transformation projects in a wide range of sectors. He wasalso involved in Competent Authority and APA negotiations ona European level.Besides tax planning, Patrick also assisted clients in defence

work. Patrick is a central cluster co-leader of the PwC tax con-troversy and dispute resolution worldwide network. He is theEuropean tax lead for major Japanese, European and Americanaccounts. He is specialised in global core documentation andthe financial services industry, as well as in tax controversy anddispute resolution.He is now heavily focussing on assisting clients in addressing

BEPS-related consequences and has, for example, already beeninvolved in various country-by-country reporting projects.Patrick teaches transfer pricing in the academic world (Vlekho UAMS), is a regular speaker

at seminars and conferences and runs transfer pricing sessions during international trainingcourses within PwC.

Belgium

Patrick Boone

PwC

Woluwe Garden – Woluwedal 181932 Sint-Stevens-WoluweBelgium

Tel: +32 (0)2 710 43 66Email:[email protected]:www.pwc.com/taxcontroversy



Véronique De Brabanter is a counsel at Law Square, an inde-pendent law firm with a privileged cooperation with the PwCnetwork. Her practice focuses on dispute resolution and litiga-tion related to all types of taxes.Over a period of 20 years, Véronique has built up experience

in advising both Belgian and international clients on proceduralmatters and in handling both administrative and court proceed-ings (such as complex transfer pricing disputes).As a specialist in Belgian and international tax law, she assists

clients in tax audits and negotiates settlements with the admin-istrative authorities. She assists clients in developing a litigationstrategy on the basis of national legislation, EU law and thecase law of the Court of Justice of the European Union and ofthe Human Rights Court.Véronique also carries out risk analysis (e.g. penalties, crimi-

nal prosecution, liability of managers, etc.) and helps clientswith voluntary disclosures.Véronique has expertise in litigation aftercare and assists

clients in the execution of settlements or court decisions andfiles requests for waivers of interest and penalties.She regularly lectures at seminars with respect to tax matters. Véronique is a member of the Brussels Bar. She is fluent in

Dutch, English and French.

Belgium

Véronique De Brabanter

Law Square(an independent law firm inBelgium with a privileged coop -eration with the PwC network)


Tel: +32 (0)2 710 78 17Email: veronique.de.brabanter@

lawsquare.beWebsite: www.lawsquare.be



Luc De Broe, Deloitte Belgium, joined the tax controversysolutions department in 2010. Before joining, he was partnerand senior counsel with Stibbe. Luc has been a member of the Brussels Bar since 1982. He

is also a professor of tax law at the Katholieke UniversiteitLeuven (KUL). Since 2007, he has been a member of the exec-utive committee of the International Fiscal Association (IFA). Luc is the author of numerous articles on Belgian, interna-

tional and European tax law. In 1988, he was awarded the IFA’sMitchell B Carroll Prize for his manual on cross-border leasingbetween Belgium and the US. In 2008, he published the book,‘Tax Planning and the Prevention of Tax Avoidance’.Luc graduated from the KUL and earned a master of laws

degree from the Northwestern University School of Law(Chicago, 1986). Luc also earned a degree in tax law from theEcole Supérieure des Sciences Fiscales Bruxelles (1987) and earneda doctorate from the KUL in 2007.

Belgium

Luc De Broe

Deloitte Belgium

Berkenlaan 8a1831 Brussels / DiegemBelgium

Tel: +32 2 800 70 10Fax: +32 2 800 70 01Email: [email protected]: www.laga.be



Jurgen Gevers is a director (advocaat vennoot/avocat associé) atLaw Square, an independent law firm with a privileged cooper-ation with the PwC network. Jurgen has more than 16 years ofexperience in tax dispute resolution and litigation. Before join-ing Law Square, he was a partner at Antaxius Advocaten.Jurgen assists national and multinational enterprises with

customs and excise issues, including anti-dumping and counter-vailing duties, as well as related tax aspects. In this context, headvises his clients on procedures and assists them in audits andcriminal investigations, negotiations on amicable settlements,rulings and submissions of applications for reimbursement andremission.Jurgen also handles disputes with the Customs and Excise

Administration or the VAT authorities and assists his clients inadministrative proceedings and proceedings before the civil andcriminal courts, the Belgian Constitutional Court and theSupreme Court. Jurgen has been involved in cases before theCourt of Justice of the European Union (e.g. C-499/14, C-351/11, C-367/09 and C-201/04).Jurgen assists his clients in the negotiation and drafting of

contracts between logistic services and importers/exporters,between importers and suppliers/customers, and betweenexporters and customers. He also represents them before the commercial courts in relateddisputes.He teaches customs and excise in tax and accountancy management at the Karel de Grote

University College in Antwerp and has published numerous tax-related articles.Jurgen is a member of the Brussels Bar. He is a Dutch native speaker and speaks English

and French.

Belgium

Jurgen Gevers



Tel: +32 (0)2 710 78 17Email: Veronique.de.brabanter@




Ine Lejeune is a partner and leads the tax policy, tax dispute res-olution and tax litigation practice at Law Square, an independ-ent law firm with a privileged cooperation with the PwC net-work.Her team of 15 tax lawyers provides support related to all

sorts of taxes (corporate income taxes, personal income taxes,customs, excise, anti-dumping duties, VAT and environmentaltaxes) by developing local or globally coordinated dispute reso-lution and litigation strategies, and developing a defence strate-gy for clients using national legislation, EU law and thejurisprudence of the Court of Justice of the European Union(ECJ). The team has also assisted with both regulatory and vol-untary disclosure, acted on behalf of clients during audits,(fraud) investigations and raids, assisted clients with administra-tive appeals and settlement negotiations with authorities, poli-cymakers and mediation and arbitration procedures, anddefended clients’ interests in all courts in Belgium (from thelowest to the Constitutional Court and the Supreme Court),the EU and the ECJ. The team is also highly experienced in fil-ing complaints with the European Commission (EC).Before joining Law Square as a partner, Ine held multiple

leadership positions within PwC, which she joined in 1984,including global indirect tax network leader, global indirect tax policy leader and partner incharge of PwC’s services to the EU institutions.Ine assists clients with tax disputes and procedures before national courts in Belgium, and

other European countries, as well as before the ECJ. Ine has filed complaints with the EC,resulting in infraction procedures and changes in national legislations to resolve litigations.Ine has been responsible for 36 studies delivered to DG TAXUD (EC), has provided pol-

icy services to Belgium (VAT grouping), other EU member states and non-EU countries(UAE, GCC, China and India).She is a member of the EC’s VAT expert group, and the OECD’s technical advisory group

(TAG) for consumption taxes.Ine was elected ‘Belgian Taxman’ in 2009 (an annual award recognising an outstanding

contribution to tax).She lectures at the University of Vienna (WU) in the LLM programme in international

tax law and has lectured at other universities in Europe and China.She has published several books and articles on EU, global and Belgian VAT and the case

law of the Court of Justice. She has a master’s degree in law and a postgraduate degree in taxstudies.Ine is a member of the Brussels Bar. She is fluent in Dutch, English and French.

Belgium

Ine Lejeune







Astrid Pieron has more than 35 years of tax experience, whichincludes over 30 years of focus on international taxation. Her practice includes counseling on the transactional aspects

of transfer pricing, tax optimisation of mergers and acquisitions,structuring of investment funds and general assistance to privateequity deals.Astrid heads Mayer Brown’s European transfer pricing cen-

ter and coordinates transfer pricing strategies and controversiesin Europe. She participates in the EU platform for tax goodgover nance and has previously served as a non-governmentalmember to the EU joint transfer pricing forum advising theEuro pean Commission on transfer pricing matters (2012-15).Before joining Mayer Brown, Astrid practiced in Brussels

and Lux em bourg with two of the world’s leading tax andaccounting firms Deloitte (2002-06) and Arthur Andersen(1981-02).

Belgium

Astrid Pieron

Mayer Brown

Avenue des Arts 521000 BrusselsBelgium

Tel: +32 2 551 5968Fax: +32 2 502 5421Email:[email protected]: www.mayerbrown.com



Philippe Renier is a director (advocaat vennoot/avocat associé) atLaw Square, an independent law firm with a privileged cooper-ation with the PwC network.Philippe has more than 15 years of experience in tax in differentlaw firms.Philippe has extensive experience assisting national and

multi national industrial and financial companies with complextax controversy issues. He has an excellent reputation and goodcontacts with the tax authorities. Philippe has significant experi-ence undertaking remedial action after an audit by the specialtax inspectors’ team, as well as tax settlement procedures beforetax authorities and the public prosecutor, thereby using media-tion and negotiation techniques.As a tax litigator, Philippe has significant experience on com-

plex tax litigation procedures before all Belgian and Europeancourts with specific regard to tax fraud, withholding tax claims,transfer pricing, permanent establishment issues and anti-avoid-ance rules.Philippe has experience assisting multinational industrial and

financial clients (banks) for EEC Arbitration Convention proce-dures, as well as on claims and ruling requests (involvingdomestic and EU law, application of tax treaties, anti-avoidancerules, and the non-discrimination principle).Philippe litigated/is litigating some milestone cases before the European Court of Justice,

including one on excess dividend deductions received by taxpayers (C-499/07) and anotheron tax fairness and the tax on dividends (C-68/15).He has also successfully defended cases before the Belgian Constitutional Court.Philippe is a professor at the University of Brussels where he lectures on tax procedural

law. He is linked to the University of Hasselt as a voluntary researcher in the area of tax law.He has published numerous tax-related articles in matters that concern national and inter-

national tax litigation. He regularly lectures on specialised tax seminars and is frequentlyquoted in the press.Philippe is a member of the Brussels Bar. He is a Dutch native speaker, is fluent in French

and English and proficient in Spanish.

Belgium

Philippe Renier







Johan Speecke, Deloitte Belgium, is a founding partner of thetax law service line, created in 1997. Before this, he was a part-ner at the Tour ni court & Vanistendael law office.As a senior partner of the tax team, Johan specialises in tax

litigation, advising companies and individuals during the admin-istrative process (advice on tax challenges leading to final assess-ments, negotiations with both local and central tax administra-tion, individual rulings, claims against assessments, notices,among others) as well as before the tax and criminal courts bothin Belgium (Court of First Instance, Court of Appeal, SupremeCourt) and elsewhere in Europe.Johan is a professor at the Fiscale Hogeschool Brussels and a

permanent member of the editorial staff of the Tijdschrift voorFiscaal recht. He holds a degree in law from the University ofLeuven (KUL) and a degree in economics from EHSAL.

Belgium

Johan Speecke

Deloitte Belgium

President Kennedylaan 8a/00018500 KortrijkBelgium




Danny Stas, Deloitte Belgium, is a VAT expert and managingpartner.Danny has 20 years of experience as an adviser/lawyer in VAT.

He started his career as a VAT consultant with Arthur Ander -sen, later working as a managing partner at a tax boutique. Hejoined Deloitte in January 2012. He is a tax lawyer specialisedin VAT, in particular with respect to real estate and financialtransactions, as well as eco taxes and contributions. In the real estate industry, Danny focuses on VAT consulting

for clients in the private sector (for example real estate develop-ers, REITs, hospitals, senior housing) and public sector, and thebroad corporate market at national and international levels. Inaddition to specific VAT topics (for example reduced VAT rates,VAT exemptions), he also has good knowledge of alternativefinancing of real estate and transfer duties. Danny earned a degree in law from KUL, Leuven (1994)

and a degree in tax and accounting from Vlerick, RUG (1995).He has authored several books and articles discussing VAT relat-ed matters. He is also a regular speaker at internal and externalseminars and is regularly consulted by professional federations in Belgium on legislative ini-tiatives.

Belgium

Danny Stas

Deloitte Belgium


Tel: +32 2 800 70 11Email: [email protected]: www.laga.be



Annick Visschers, Deloitte Belgium, joined the tax controversysolutions team in 2010. Before this, Annick practised at Stibbeuntil 1999. A member of the Brussels Bar since 1996, Annick specialises

in Belgian and international tax law and focuses on tax risk man-agement (preventing disputes and resolving business issues), taxlitigation (defending clients before Belgian tax courts, theSupreme Court and the European Court of Justice), tax recov-ery and criminal tax matters.Annick is a member of the editorial staff of the journal Révue

Générale du Contentieux Fiscal and CFO-magazine and of thechief editorship (doctrine) of the Tijdschrift voor Fiscaal Recht.She is also the author of numerous articles on tax risk manage-ment and the investigative powers of the tax authorities. Annick graduated from the University of Leuven in 1995

and studied tax law at the Université Libre de Bruxelles.

Belgium

Annick Visschers

Deloitte Belgium





Belgium

Thierry AfschriftAfschrift

Thierry CharonLoyens & Loeff

Victor DauginetDauginet

Caroline DoccloLoyens & Loeff

Daniel GarabedianLiedekerke

Axel HaeltermanFreshfields Bruckhaus Deringer

Alain HuygheBaker & McKenzie

Véronique SlachmuyldersKPMG

Patrick SmetAllen & Overy

Reinhold TournicourtMonard Law

Dirk Van StappenKPMG

Xavier Van VlemPwC

Henk VanhulleLinklaters

Isabel VerlindenPwC



Gileno Barreto is a partner at Loeser e Portela Advogados, thecorrespondent law firm of PwC in Brazil, and he is the leader ofPwC Brazil’s tax controversy and dispute resolution network.Gileno has more than 10 years’ experience in tax litigation

and controversy resolution in the administrative and the judicialcourts related to federal, state and city taxes at all levels, andmore than 20 years of experience acting in tax consulting activ-ities in Brazil, as well as five years in accounting audit.He gained broad experience of legislative procedures at the

National Congress including advising on the drafting of legisla-tion, the national budget, internal commissions, budget execu-tion and national accounting procedures among other tax policyissues and legislative activities.Appointed as counsellor of the Brazilian Federal Tax Admin -

istrative Council (CARF) in 2006, to its 3rd section, Gilenoserved until January 2015 as vice-president of his collegiate. During his career as a tax adviser and lawyer, he has coordi-

nated several projects related to the review of procedures adopt-ed by national and multinational enterprises in compliance withBrazilian tax laws and regulations. He is an adviser to severalBrazilian agencies and public-owned companies and banks.Gileno was the project technical coordinator of the Brazilian customs modernisation plan

(PMAB) rendered to the Brazilian Federal Revenue Services (RFB) and now acts as a Euro -pean Commission tax consultant. He also provides tax advice in structuring and restructuringprojects carried out by national and multinational enterprises and is responsible for M&Aprojects on behalf of both public and private companies including legal due diligences andconsultancy regarding land property acquisition. His client portfolio includes companies inthe construction, financials, insurance, chemical, forest and paper, energy and utilities, min-ing and oil, and education sectors.The meeting of his experience in accounting audit, tax audit, government relations, busi-

ness administration and in settlement of disputes relating to tax law, regulatory law and anti-corruption, anti-bribery and anti-money laundering laws result in a unique expertise in com-pliance and corporate governance, both in legal matters and regarding other aspects of thecorporate lifecycle, such as in business management processes.Gileno graduated from the Law School of UNICEUB in Brasilia-DF, holds an MBA from

the Fundação Getúlio Vargas – FGV and an LLM in international tax law (IBDT). He is amember of the Brazilian Bar Association, chapters of Federal District, São Paulo, Rio deJaneiro, Minas Gerais, Bahia and Sergipe.

Brazil

Gileno G Barreto

PwC

Av. Francisco Matarazzo, 1400Torre Milano, 15th FloorSão Paulo, SP 05001-903 Brazil




José de Carvalho Jr, Deloitte Brazil, is an international businesstax and corporate consulting partner with 24 years of experiencein corporate and tax.He specialises in corporate income taxes, foreign capital leg-

islation, corporate law, corporate reorganisations, and interna-tional tax planning structures, as well as direct taxes and taxcontroversy. He leads the legal practice and is also the Brazilian tax con-

troversy team leader. Jose has been involved in several interna-tional tax engagements.Jose has bachelor degrees in accounting (1982), economics

(1984) and law (1989), and is registered with the RegionalAccount ing Council (CRC), Regional Economics Council(CRE), and the Brazilian Bar Association (OAB).

Brazil

José de Carvalho Jr

Deloitte Brazil

Av. Dr. Chucri Zaidan, 1.240,Golden Tower – 4º ao 12º andaresSão Paulo - SP, 04711–130Brasil

Tel: +55 11 5186 1268Email: jcarvalhojr@

carvalhoenatale.com.brWebsite: www.deloitte.com.br



Gilberto de Castro Moreira Jr is a partner and the head of thetax department of Lautenschlager, Romeiro e Iwamizu. He isbased in São Paulo.Gilberto has been practising law in São Paulo since 1990. He

holds a JD degree from the University of São Paulo and a PhDdegree in economic and financial law from the University of SãoPaulo. Gilberto’s practice is focused on tax law (litigation, advi-sory and planning). He is an arbitrator of the EUROCHAMBERS’ Mediation

and Arbitration Chamber (CAE), a member of the tax law andtax litigation committees of the São Paulo Bar Association, ofthe Brazilian Institute of Tax Law (IBDT), of the scientificcouncil of the Tax Law Association of São Paulo (APET), of theInternational Association of Tax Judges (IATJ) and a sittingmember of the Lawyers’ Institute of São Paulo (IASP). Formercouncilor of the 3rd section of the Administrative Court of TaxAppeals (CARF), former tax law professor of the MackenziePresbyterian University and former member of the Ethics Courtof São Paulo Bar Association. He is the author of the book‘Bitributação Internacional e Elementos de Conexão’ (Inter -national Double Taxation and Connection Elements); coordi-nator and co-author of the books ‘Direito Tributário Inter -nacional’ (International Tax Law) and ‘PIS e COFINS à luz da jurisprudência do CARF’(volumes 1, 2 and 3) (PIS and COFINS taxes under the CARF precedents). In total, he hasco-authored 21 books and written several articles addressing tax matters.

Brazil

Gilberto de Castro Moreira Jr

Lautenschlager, Romeiro eIwamizu Advogados

Av. Paulista, 1.842 - 22º andar -Torre NorteSão Paulo - SP 01310-200 Brazil

Tel: +55 11 2126 4600Fax: +55 11 2126 4601Email: [email protected]: www.lrilaw.com.br



Fernando Loeser is a partner at Loeser e Portela Advogados, thecorrespondent law firm of PwC Legal in Brazil.Fernando joined PwC in 1987, when he started working

with tax consultancy and corporate law. He joined Loeser &Portela Advogados (formerly Castro, Campos & Associados –Advogados) in 1989 as a senior lawyer and became a managerin 1992 before being admitted as a partner five years later, in1997. He is a member of the São Paulo, Rio de Janeiro, Brasília,

Bahia and Minas Gerais chapters of the Brazilian Bar Associa -tion (OAB), and also member of several chambers of commercein Brazil. Fernando holds a bachelors degree in law from the Law

School of the Pontifical Catholic University of São Paulo –PUC/SP (1991).Fernando has more than 24 years’ experience in tax litigation

and 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 several

M&A, spin-offs; due diligence and structuring and restructur-ing processes, as well as in the incorporation of subsidiary companies in Brazil; drafting ofarticles of association, corporate amendments, transfer of shares agreements and sharehold-er’s agreement.Fernando has also coordinated several projects related to the review of procedures adopt-

ed by national and multinational enterprises 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 enterprises. His clients include companies in the construction,retail, mining and oil, and education sectors. He has been also responsible for several projects related to compliance with anti-bribery

and anti-money laundering laws (FCPA, Brazilian FCPA, UK Bribery Act) by Brazilian com-panies, conducting and/or overseeing investigation procedures as well as reporting proce-dures.He writes chapters and articles in various books and journals and is a native speaker in

Portuguese, as well as being fluent in English and Spanish.

Brazil

Fernando Loeser

PwC

Av. Francisco Matarazzo, 1400Torre Milano, 15th FloorSão Paulo, SP 05001-903 Brazil

Tel: +55 11 3879 2800Email:[email protected]@lpadv.com.brWebsite:www.pwc.com/taxcontroversy



Ana Luiza Martins is a partner in the tax practice in the SãoPaulo office of Tauil & Chequer Advogados. Ana Luiza has vast experience in tax consulting and litiga-

tion. Among her clients are major national and internationalenterprises from various industries, including consumer goods,hospitality and leisure, infrastructure, pharmaceuticals, technol-ogy and telecommunications.She started her career in 1997 as a member of the tax prac-

tice of Gouvêa Vieira Advogados. In 2000, she joined the taxdepartment of Veirano Advogados to spur the tax litigationpractice. In 2007, she joined Campos Mello Advogados as asenior associate focusing on tax litigation and strategic tax con-sulting, becoming a partner in January 2011. In October 2015,Ana Luiza joined Tauil & Chequer as a tax partner based in thefirm’s São Paulo office. Throughout her career, Ana Luiza has represented several

major multinational enterprises, most of which are in the US,Italy and France, as well as prominent stock exchange-listedcompanies of Brazil. She has argued cases for these clientsbefore the highest Brazilian courts, including the STF (Brazil’sSupreme Court), the STJ (Brazil’s highest court for non-consti-tutional matters) and the CARF (the highest administrative taxcourt of the Brazilian federal administration).

Brazil

Ana Luiza Martins

Tauil & Chequer Advogadosin association with MayerBrown

Av. Juscelino Kubitschek1455 – 5º, 6º e 7º andaresVila Nova Conceição – 04543-011São Paulo Brazil




Marcos Matsunaga is a tax and legal partner and leads KPMG’stax dispute resolution and controversy services in Brazil. In addition to his national role, Marcos is also the LATAM

leader within KPMG International’s global tax dispute resolu-tion and controversy services network. He has wide experiencein tax law and different industry sectors, with a focus on adviso-ry for prevention and resolution of tax disputes, from the pre-dispute phase (voluntary disclosures, private letter rulings, taxrisk assessments) through examinations and appeals. Marcos represents several national and international corpo-

rate clients before administrative and judicial tax courts inBrazil, dealing with complex controversial matters related todirect and indirect taxes, domestic and international tax issues.His clients include financial institutions, insurance companies,international pension funds, and industrial and agribusinesscompanies.Due to his international role, Marcos has coordinated and

participated in a number of cross-border projects among theLatin America region, dealing with multi-jurisdictional teams,which has given him outstanding experience in mergers andacquisitions, transfer pricing, corporate restructuring and R&Dtax incentives. Marcos joined KPMG Brazil in 1998 and has been a partner since 2008. He has a bach-

elors degree in law from Pontifícia Universidade Católica de São Paulo – PUC/SP and a spe-cialisation degree in tax law from Fundação Getúlio Vargas – GVLaw. He is member of theBrazilian Bar Association, GETAP (Grupo de Estudos Tributário Aplicados) and NEF/FGV(Núcleo de Estudos Fiscais). Marcos has been named by International Tax Review as one ofthe tax controversy leaders in Brazil since 2012 and has been recognised by AnáliseAdvocacia 500 as one of the most admired Brazilian tax lawyers in 2014 and 2015.

Brazil

Marcos Matsunaga

KPMG

Rua Arquiteto Olavo Redig deCampos, 105, 12º andarEdifício EZ Tower – Torre ACEP 04711-904 – São Paulo, SPBrazil

Direct: +55 (11) 3940 8429Email:[email protected]: www.kpmg.com.br



Ivan Tauil is the founding partner and head of the tax law prac-tice of Tauil & Chequer Advogados in association with MayerBrown and serves on Mayer Brown’s partnership board. He hasextensive experience in local and international taxation. He is also the author of several articles and is often a lecturer

at a number of legal and corporate events in Brazil and abroad.Ivan holds an LLM in constitutional law and theory of the

state from PUC-RJ. He is the chairman of the oil and gas com-mittee of the Brazilian Bar Association, Rio de Janeiro Chapter,director of the Brazilian Tax Law Academy, and a member ofthe Brazilian Finance Law Association, the Inter national FiscalAssociation and the International Bar Associa tion. In addition,Ivan is also a member of the editorial board of Revista Tribut -ária e de Finanças Públicas – Ed. Revista dos Tribun ais. In 2016, both Chambers Global and Chambers Latin

America recognised him as one of the “Leaders in their Field”for his legal work in the tax sector.

Brazil

Ivan Tauil


Rua Teixeira de Freitas, 31 – 9ºandar20021-350 CentroRio de JaneiroBrazil

Tel: +55 21 2127 4213Fax: +55 21 2127 4211Email: [email protected]: www.mayerbrown.com



Eduardo Maccari Telles is a partner in the Rio de Janeiro andSão Paulo offices of Tauil & Chequer Advogados. Eduardo isresponsible for coordinating the firm’s Brazil tax controversypractice and focuses on tax controversy, litigation and arbitra-tion, tax consulting and administrative law. He represents national and foreign companies, as well as

govern mental institutions, and he assists them in all types of dis-pute resolution for tax cases and with tax consulting. Eduardo has a lot of previous experience in energy, civil,

labour, intellectual property, environmental and insurance liti-gation. He has a master’s degree in tax law and coordinates thepost graduate programmes of tax controversy, constitutional taxand oil and gas taxation at Fundação Getúlio Vargas. He is alsoa guest professor in post graduate programmes at others univer-sities in Rio de Janeiro, like Catholic University (PUC), IBMECand Cân dido Mendes and also at the Judge’s School of Rio deJaneiro. Since 2000, Eduardo has also served as a state attorney in the

Attorney’s Office of the State of Rio de Janeiro. His other pro-fessional assignments have included work as a tax attorney withthe National Institute of Social Security (1998-00), as externalcounsel for the Brazilian Institute of Municipal Administration(2000-04) and as treasury representative on the TaxpayerCouncil of the State of Rio de Janeiro (2004).

Brazil

Eduardo Maccari Telles


Rio de Janeiro:Rua Teixeira de Freitas31 – 9º andar20021-350 CentroRio de JaneiroBrazilTel: +55 21 2127 4229Fax: +55 21 2127 4211

São Paulo:Av. Juscelino Kubitschek1455 – 5º, 6º e 7º andaresVila Nova Conceição – 04543-011São Paulo Brazil Tel: +55 11 2504 4210Fax: +55 11 2504 4211

Email: [email protected]: www.mayerbrown.com



Paulo Vital is a tax director with 20 years’ experience and strongexpertise in tax controversy and dispute resolution mattersbefore the administrative and judicial courts, comprising bothdirect and indirect taxes. Paulo is a specialist in various sectorsof industry, including commerce and technology companies,advising and defending both publicly and privately held compa-nies in highly complex cases related to tax planning. Paulo isalso experienced in providing legal advice on tax matters. Paulo graduated in 1998 from the Mackenzie University and

holds a master’s degree in tax law from the Pontifical CatholicUniversity of São Paulo.Paulo is a native speaker in Portuguese and is also fluent in

English.

Brazil

Paulo Vital

PwC

Avenida Francisco Matarazzo, 1400Torre Milano, 15th FloorSão Paulo, SP 05001-903Brazil

Tel: + 55 11 3879 2800Email: [email protected]:www.pwc.com/taxcontroversy



Brazil

Marcel Alcades TheodoroMattos Filho

Marcelo Salles AnnunziataDemarest Almeida

Carlos BecharaPinheiro Neto Advogados

Luiz Gustavo BicharaBichara, Barata & Costa Advogados

Gustavo BrigagãoUlhôa Canto, Rezende e Guerra Advogados

Isabel BuenoMattos Filho

Vivian CasanovaBarbosa Mussnich Aragao Advogados

Marcos CatãoVinhas e Redenschi

Tércio ChiavassaPinheiro Neto Advogados

Renata Correia CubasMattos Filho

Gabriela Silva de LemosMattos Filho

André Gomes de OliveiraCastro, Barros, Sobral, Gomes

Júlio de OliveiraMachado Associados

Thiago de Vasconcellos Chaer CuryBichara, Barata & Costa Advogados

Daniela Duque EstradaCastro, Barros, Sobral, Gomes

Gilberto FragaFraga, Bekierman & Cristiano

Alessandra GomensoroMattos Filho

Gustavo HaddadLefosse Advogados

Carlos IaciaPwC



Brazil

Mario JunquieraNatanael Martins, Mario Franco e Gustavo Teixeira

Leo KrakowiakAdvocacia Krakowiak

Daniel Lacasa MayaMachado Associados

Glaucia Lauletta FrascinoMattos Filho

Gabriel Manica Mendes de SenaCastro, Barros, Sobral, Gomes

João Marcos ColussiMattos Filho

Ricardo Mariz de OliveiraMariz de Oliveira e Siqueira Campos

Leonardo MartinsTrench Rossi e Watanabe Advogados

Marcos NederTrench Rossi e Watanabe Advogados

Mariana Neves de VitoTrench Rossi e Watanabe Advogados

Raquel NovaisMachado Meyer

Alvaro PereiraPwC

Mauricio Pereira FaroBarbosa Mussnich Aragao Advogados

Durval PortelaPwC

Marcos PradoStocche Forbes

Roberto Quiroga MosqueraMattos Filho

Lígia ReginiBarbosa Mussnich Aragao Advogados

Sergio André RochaSergio André Rocha Advocacia & Consultoria Tributária

Ana Paula Schincariol Lui BarretoMattos Filho



Brazil

Paulo SehnTrench Rossi e Watanabe Advogados

Paulo Camargo TedescoMattos Filho

André TeixeiraAndre Teixeira & Associados

Bulgaria

Milen RaikovEY



Natan Aronshtam, Deloitte Canada, is the global managingdirector for R&D and government incentives service. Natanregularly leads national and international engagements andserves many of the leading companies in Canada and around theworld. Natan and his team provide services in over 50 countries,

assisting companies with access to government incentives forR&D, investment in new or expanded operations or products,and human resources. Natan also advises governments all overthe world on policy and incentive design to increase innovationand attract specific industries and types of businesses.Natan uses his broad international experience to successfully

resolve some of the most complex disputes related to tax andnon-tax incentives.

Canada

Natan Aronshtam

Deloitte Canada

Bay Adelaide East22 Adelaide Street West, Suite 200Toronto ON M5H 0A9Canada

Tel: +1 416 643 8701Fax: +1 416 601 6706Email: [email protected] Website: www.deloitte.com



Neil Bass is highly acclaimed in the fields of tax litigation andcommodity taxation, including goods and services tax and har-monised sales tax (GST/HST), provincial sales tax (PST), andinternational customs duties, and is the leader of Dentons’national tax group. He has extensive experience in dealing with various taxation

authorities and has represented clients before the CanadianInternational Trade Tribunal, the Tax Court of Canada, theFederal Court and Federal Court of Appeal, as well as beforeprovincial courts. Neil served on the CBA/CICA joint legisla-tion review committee that examined the draft legislation thatamended the Canadian Excise Tax Act.Neil has written numerous articles and conference papers on

the GST/HST and was a co-editor of ‘Canadian GST andCom modity Tax Cases’ published by CCH Canada. Neil has been recognised as a leading practitioner in the area

of commodity tax in prominent legal and other professionaldirectories including, most recently, International Tax Review.Neil continues to address audiences on a variety of commod-

ity tax matters and is a past presenter at the CICA Commodity Tax Symposium and theCanadian Tax Foundation Conference. Neil was also awarded the 1999 Normand GuerinAward for his “outstanding contribution to the study of commodity taxation”.

Canada

Neil Bass

Dentons

77 King Street WestSuite 400Toronto, Ontario M5K 0A1Canada

Tel: +1 416 863 4757Email: [email protected]: www.dentons.com



Patrick Bilodeau, Deloitte Canada, leads the Ottawa interna-tional tax practice. He advises his clients in dealing with reviewsand challenges from tax authorities, and in particular, in respectof cross-border considerations. He works closely with his taxcontroversy and transfer pricing colleagues throughout Canadaand leverages his broad network of colleagues in countries on allcontinents with the goal of resolving these complex cross-bor-der matters for his clients. Patrick’s background as a tax lawyer and a chartered profes-

sional accountant (CPA), along with his experience as a taxadviser on complex transactions, allows him to bring a uniqueand integrated approach to tax controversy. He has assistedclients with representations as part of CRA audits, appeals pro-cedures and voluntary disclosures for a wide variety of matters.He also works closely with Deloitte’s transfer pricing controver-sy experts to assist clients with mutual agreement procedure(MAP) considerations. Patrick has advised multiple Canadian-based and foreign

multi nationals on international and Canadian taxation issues.He has developed a deep specialism in implementing cross-border transactions and structuresto help his clients navigate the complexities of international business, including the engineer-ing of tax efficient international corporate structures, cross-border mergers and acquisitionsand international IP and financing structures. Patrick frequently advises Canadian businesseslooking to expand internationally and works closely with his clients to align the implementedtax structure with their business objectives. Patrick obtained his law degree (summa cum laude) from the University of Ottawa, and

is both a member of the Quebec Bar and a CPA. Patrick also has a master of laws – taxationoption – degree from HEC Montreal and the University of Montréal.Patrick has contributed to various publications such as the Bloomberg BNA International

Tax Forum and the Revue de l’APFF. He also frequently speaks on complex international taxmatters.

Canada

Patrick Bilodeau

Deloitte Canada

100 Queen Street, Suite 1600Ottawa, ON K1P 5T8Canada

Tel: +1 613 7515447Email: [email protected]: www.deloitte.com



As former chief justice of the Tax Court of Canada, Donald GHBowman has extensive experience in resolving tax disputes. Heis counsel to Dentons’ national tax group and shares his expert-ise with members of the group as a mentor and adviser. Based in the firm’s Toronto office, Donald works to enhance

the firm’s ability to reach early resolution of tax and related dis-putes for the firm’s clients. His practice at Dentons consists of giv-ing advice on tax matters including tax litigation to clients, lawyersin the firm throughout Canada and to lawyers in other firms.Donald has spent his entire legal career as a tax litigator. He

joined the Federal Department of Justice – Tax LitigationSection soon after his call to the Ontario Bar and was appointeddirector in 1968. He joined the law firm of Stikeman, Elliott,Robarts & Bowman in 1971 and was a partner there until hisappointment to the Tax Court of Canada. He was appointedjudge of the Tax Court of Canada in 1991 and associate chiefjudge in February 2000. He was appointed associate chief jus-tice in July 2003 and chief justice in February 2005.

Canada

Donald GH Bowman, QC

Dentons


Tel: +1 416 863 4620Email:[email protected]: www.dentons.com



Olivier Fournier, Deloitte Canada, leads the Montréal office.Olivier practices tax law with a focus on tax litigation and taxcontroversy, from the audit and objection stages to tax appealsbefore the courts. He regularly assists clients in resolving taxdisputes, both in and out of court, and engages in managingcomplex tax audits, ensuring that the tax authorities operatewithin the lawful parameters regarding demands for informa-tion and documents and correcting non-compliance issues. Healso has had significant exposure to tax planning for domesticand international mergers and acquisitions.He has acted in matters before the Tax Court of Canada, the

Court of Québec, the Federal Court and the Federal Court ofAppeal.He is an active speaker, writer and presenter at various con-

ferences and seminars, such as for the Association de Plani -fication Fiscale et Financière (APFF) and the Canadian TaxFound ation (CTF).Olivier was called to the Bar of Québec in 2006, after receiv-

ing an MBA from the University of Ottawa (2005), and an LLLin 2005 (magna cum laude) and a BSc (Biology) in 2002 fromthe University of Ottawa.

Canada

Olivier Fournier

Deloitte Canada

La Tour Deloitte1190 avenue des Canadiens-de-MontréalSuite 500Montréal (Québec) H3B 0M7Canada

Tel: +1 514 393 8362Fax: +1 514 390 1808Email:[email protected]: www.deloittetaxlaw.ca



Étienne Gadbois is a tax partner in Dentons’ Montréal office.He is recognised as one of the most frequently recommendedCanadian lawyers in the area of commodity tax and customs bythe Canadian Legal Lexpert Directory and as an internationalleader in the areas of indirect tax and tax disputes by Inter -national Tax Review.Étienne practises in the commodity tax area and has recog-

nised expertise in federal and provincial sales taxes, includingCanada’s goods and services tax (GST), harmonised sales tax(HST), Québec sales tax (QST), as well as land transfer taxes,fuel, carbon, alcohol, tobacco, and other similar taxes.Étienne is regularly involved in negotiations, client represen-

tations and interventions with the Canada Revenue Agency,Québec tax authority, the Court of Québec, the Tax Court ofCanada and the provincial and federal appeals courts. His prac-tice also involves providing advice in the areas of commoditytaxes in mergers and acquisitions, corporate reorganisations,real estate transactions, joint ventures and the structuring ofpublic-private partnerships.Widely recognised for his distinctive expertise, Étienne is

regularly asked to speak at various forums and is a widely published author in textbooks andacademic journals on topics related to consumption taxes (and VAT in general) and tax dis-putes. Since 2013, Étienne has written two Carswell, Thomson Reuters publications: ‘La Loidu Praticien annotée – TPS-TVQ’ (Practitioner’s GST/QST Annotated Act), which is updat-ed twice a year, and a monthly bilingual newsletter on new trends in commodity taxes. Morerecently, he co-authored the book entitled ‘Le litige fiscal au Québec et au Canada’. Finally,Étienne founded La Revue des taxes à la consummation, a commodity tax journal that is pub-lished quarterly, where he acts as editor-in-chief.

Canada

Étienne Gadbois

Dentons

1 Place Ville Marie39th FloorMontréal, Quebec H3B 4M7Canada




As former head of Dentons’ Edmonton tax group, Cheryl AGibson practises in numerous facets of taxation law. She has extensive experience in the resolution of income tax

and goods and services tax (GST) disputes including criminaltax evasion matters. Cheryl focuses on getting results in a timelyand efficient manner. Cheryl also plans and implements tax-driven corporate reor-

ganisations and the establishment of trusts. She advises on pen-sion matters and has prepared opinions on numerous tax andGST topics.

Canada

Cheryl A Gibson, QC

Dentons

2900 Manulife Place10180 – 101 StreetEdmonton, Alberta T5J 3V5Canada




Laurie Goldbach, Deloitte Canada, focuses on tax litigation, taxcontroversy and defending criminal tax prosecutions. She hasextensive trial and appellate advocacy experience and regularlyappears before all levels of courts in Alberta, and has appearedbefore the Tax Court of Canada, the Federal Court of Canadaand the Supreme Court of Canada.Laurie has twice been recognised by Legal Media Group’s

Benchmark Canada as a future star. She also has been highlight-ed in International Tax Review’s Women in Tax Leaders guide.Laurie was admitted to the Law Society of Upper Canada

and to the Law Society of Alberta in 2000. She received herBachelor of Laws from the University of Victoria in 1998. Sheis also an active writer, speaker and presenter at conferences andseminars in the legal community. Laurie has taught for a num-ber of years at the University of Calgary’s Faculty of Law. She isalso a regular instructor at the Alberta Bar admission course(CPLED).She is a member of the Canadian Bar Association, the Can -

adian Petroleum Tax Society and the Canadian Tax Foundation.

Canada

Laurie Goldbach

Deloitte Canada

700, 850-2 Street SWCalgary, AB T2P 0R8Canada

Tel: +1 403 503 1488Fax: +1 403 920 9333Email:[email protected]: www.deloittetaxlaw.ca



Nathalie Goyette is a resident partner in the Montréal office ofPwC Law, an independent tax and immigration law firm affili-ated with PwC. Nathalie has 25 years of experience in managing and resolv-

ing audit and appeal disputes involving the provincial and fed-eral tax authorities. She assists clients with every aspect of taxaudits and represents them before courts. Prior to joining PwC Law, Nathalie was a partner in a major

Canadian law firm and before that, she acted as a senior taxlawyer with the Federal Department of Justice. Nathalie received her LLL from the University of Ottawa,

her LLB from Dalhousie University and her master’s degree intaxation from Sherbrooke University.Nathalie has written numerous publications, is a frequent

speaker in Canada and abroad, and is a member of the rulescommittee of the Tax Court of Canada. She is also a member ofthe Barreau du Québec, Canadian Tax Foundation, Inter -national Fiscal Association, and Association de planification fis-cale et financière.In addition, Nathalie received recognition from Inter nation -

al Tax Review for her role as a tax controversy leader and theOrder of Merit from the Civil Law Faculty at the University of Ottawa.

Canada

Nathalie Goyette

PwC Law

1250 René-Lévesque Blvd. West,suite 2500Montréal, Québec H3B 4Y1Canada




Jehad Haymour is a partner and tax department manager forDentons’ Calgary office.He has practiced in the area of tax litigation for over 20 years

and has represented clients before the tax authorities, the TaxCourt of Canada, the Federal Court of Appeal, and the Sup -reme Court of Canada. Jehad is recognised by Lexpert, Best Lawyers, Legal 500,

Cham bers Global: The World’s Leading Lawyers for Business andInternational Tax Review’s World Tax as a leading lawyer in thearea of tax litigation and has extensive experience in taxationissues specific to the energy sector. His experience also includesadvice related to tax reporting and structuring on various ener-gy- based projects.

Canada

Jehad Haymour

Dentons

850 – 2nd Street SW15th Floor, Bankers CourtCalgary, Alberta T2P 0R8Canada




David Kemp is a partner and leader of the global transfer pricingand dispute resolution services practice at Collins Barrow(Canadian member of Baker Tilly International), based at theToronto office. He is also a member of Baker Tilly Inter -national’s global transfer pricing committee, which oversees thedevelopment of transfer pricing globa lly within the firm.David has over 20 years of experience in the areas of global

transfer pricing, including corresponding international tax plan-ning strategies, income tax and financial advisory. During thistime he has advised multinational enterprises, within a broadscope of industries, on transfer pricing planning, documentationand dispute resolution matters. He has advised clients on a fullspectrum of cross-border transactions, including tangible assets,intangible assets, intellectual property, services, financial trans-actions, management fees and cost reimbursements.From a transaction perspective, David has significant experi-

ence regarding the identification and assessment of intangibleassets and intellectual property, as well the evaluation of finan-cial transactions and corresponding determination of loan inter-est rates and guarantee fees. From an industry perspective,David has considerable experience regarding investment adviso-ry and fund management companies, including the determina-tion of advisory, sub-advisory, distribution, management and related service fees. He has successfully defended transfer pricing policies under audit by Canadian and foreign

taxation authorities, encompassing field audit negotiations, Notice of Objection appeals,Com petent Authority submissions and advanced pricing arrangements (APAs).David has been acknowledged as one of the leading transfer pricing advisers in the world

by outside legal counsel and peer review, and has been repeatedly included in Euromoney’sguide to the world’s leading transfer pricing advisers. David has also been acknowledged asone of the leading tax dispute advisers around the world, and has been included in Inter -national Tax Review’s Tax Controversy Leaders guide.David is a chartered professional accountant and has a bachelors degree in commerce. He

is a member of the Chartered Professional Accountants of Canada, Canadian Tax Found -ation, International Fiscal Association and Licensing Executives Society.

Canada

David Kemp

Collins Barrow (Canadianmember of Baker TillyInternational)

Collins Barrow Place11 King Street West, Suite 700Toronto, ON M5H 4C7Canada

Tel: +1 647 725 1741Email:[email protected]: www.collinsbarrow.com



Andrew Kingissepp specialises in taxation with a focus on dis-pute resolution, including managing transfer pricing audits,informal appeals and tax litigation. His practice is conducted largely on a confidential basis as he

generally seeks to resolve major tax disputes on behalf of clientsprior to the litigation stage. However, he has pursued litigationon behalf of clients when necessary and has had a major role intwo of the largest Canadian transfer pricing cases (Irving Oiland Cameco).Andy has written and presented papers on a number of

income tax subjects, including transfer pricing, at various semi-nars and conferences. He is recognised as one of the leadingauthorities in the management of income tax audits and dis-putes in Canada and has been called upon to present on thissubject at leading tax conferences in Canada with the CanadianTax Foundation, International Fiscal Association and others.He is also the Canadian correspondent for the Journal of Inter -national Taxation and has written extensively for that publica-tion, as well as others.

Canada

Andrew Kingissepp

Osler, Hoskin &Harcourt

100 King Street West1 First Canadian PlaceSuite 6200, PO Box 50Toronto ON M5X 1B8Canada

Tel: +1 416 862 6507Email: [email protected]: www.osler.com



Norma Kraay, Deloitte Canada, is a tax partner with over 20years of professional experience in tax-related matters, includingthe last 19 years as a transfer pricing expert. In addition to prac-ticing in the area of transfer pricing, Norma is the Canadianindustry tax leader for consumer and industrial products.Norma is a trusted adviser to numerous multinational enter-

prises. She is recognised for successfully guiding companiesthrough large and complex transfer pricing disputes, includingadvising companies on their advance pricing agreements andmutual agreement procedures with revenue authorities. In thiscapacity, Norma has assisted multinational enterprises withcomprehensive global tax dispute strategies, including informa-tion gathering and data management, documentation, compil-ing and preparing submissions, leading discussions with revenueauthorities and dealing with secondary adjustments and post-settlement matters. Over the years, Norma has advised herclients through their business cycles, including end-to-endM&A transactions, global expansions, transfer pricing planningengagements, designing operational transfer pricing systemsand policies, assisting enterprises with financial transactions andadvising on restructuring transactions involving intangible property. Norma has been recog-nised as one of the world’s leading transfer pricing advisers in Euromoney’s Transfer PricingExpert Guide.Norma has a BBA from Instituto Tecnologico Autonomo de Mexico (ITAM), a graduate

degree from the international tax programme at Harvard Law School and a master’s in publicadministration from the Harvard Kennedy School at Harvard University.Norma is an active participant in the community. In addition to undertaking speaking

engagements at various industry and tax professional associations, such as the Tax ExecutiveInstitute, she has written a number of articles including publications in Tax Notes Inter -national and Bloomberg BNA Tax Management International. Norma is a member of theCanadian Tax Foundation. She is also a former director of the board of the Canadian Associa -tion of Importers and Exporters, former member of the corporate committee for the ArtGallery of Ontario and currently serves on the board of The Loran Scholars Foundation.

Canada

Norma Kraay

Deloitte Canada

Bay Adelaide East22 Adelaide Street EastToronto, ON M5H 4E3Canada

Tel: +1 416 601 4678Fax: +1 416 601 6706Email: [email protected]: www.deloitte.com



Patrick Lindsay is an advocate for clients in tax matters. He fre-quently appears in court to litigate substantive tax issues and todefend taxpayer rights. He also helps clients resolve tax disputesprior to litigation by negotiating with tax authorities.Patrick’s recent cases include:

• George Weston Limited v The Queen, 2015 TCC 42 – Patricksuccessfully overturned a long-standing position held by theCanada Revenue Agency (CRA), regarding the taxation ofderivatives, resulting in a favourable tax treatment on the dis-position of C$2 billion ($1.5 billion) in cross-currencyswaps;

• Birchcliff Energy Ltd. v The Queen, 2015 TCC 232 – Thiscase was under appeal to the Federal Court of Appeal. Theissue was whether the general anti-avoidance rule (GAAR)can apply to override the normal operation of the lossstreaming rules and eliminate $39 million in tax attributes;and

• Ollenberger v The Queen, 2013 FCA 74 – Patrick successfullydefended entitlement to an allowable business investmentloss where the CRA disputed whether the relevant oil and gas company carried on an“active business”.Patrick has an LLM in tax law from Osgoode Hall Law School and an LLB from the

University of Calgary, 2001.Patrick has worked with a variety of public and private company clients in the oil and gas,

real estate and other industries. He is active in the Calgary business community and is pastpresident of the Canadian Petroleum Tax Society. Patrick is ranked annually in InternationalTax Review’s Tax Controversy Leaders guide for Canada. He also is identified in the LexpertDirectory for his expertise in corporate tax and is a former chair of the CBA tax specialistssubsection. He was also honoured by the Lexpert as one of the “Rising Stars Leading Lawyersunder 40” in 2014.Patrick is active in the market as a speaker and writer on tax issues, including recent pre-

sentations and publications for the Canadian Tax Foundation, the Tax Executives Institute,CPA Canada, the Society of Trust and Estate Practitioners and the Canadian Bar Association.

Canada

Patrick Lindsay

PwC Law LLP

111-5th Avenue SW, Suite 3100Calgary, Alberta, T2P 5L3Canada




Andrew McCrodan is a transfer pricing partner with PwC’sToronto office. He has been with the firm for more than 30years and has been a partner since 1997. He began his career intransfer pricing in PwC’s New York office in 1994, assistingcompanies in complying with the first US contemporaneousdocumentation requirements and now specialises in transferpricing controversy and dispute resolution.His extensive cross-border experience includes prospective

studies for planning purposes, income tax audit defence, con-temporaneous documentation engagements, Competent Auth -ority assistance, and advance pricing agreements (APAs). He hashelped clients in obtaining unilateral and bilateral APAs in avariety of industries, including mining, manufacturing, automo-tive, entertainment, retail, and software.Andrew is a CPA and a chartered business valuator (CBV).

As a CBV, Andrew brings a wealth of valuation experience tointernational restructuring, cost sharing, and intellectual prop-erty migration assignments.The Transfer Pricing Expert Guide published by Euromoney,

Legal Media Group, has featured Andrew since 2003, and in2011 he was voted one of the “Best of the Best”, a ranking ofthe top five advisers in Canada.As a leader in the field, Andrew speaks regularly on transfer

pricing and business valuation topics for a number of professional organisations. He has alsowritten articles for CA Mag azine, the Canadian Tax Foundation, the Journal of BusinessValuation, and Tax Planning International Review. He co-authored ‘The dilemma of Glaxo -SmithKline: Un reasonable in the circumstances?’ and ‘Transfer pricing: A critique of theCRA’s position on range issues’, both published by the Canadian Tax Foundation.

Canada

Andrew McCrodan

PwC

PwC Tower18 York StreetSuite 2600Toronto, ON M5J 0B2Canada

Tel: +1 416 869 8726Fax: +1 416 814 3200Email:[email protected]:www.pwc.com/taxcontroversy



Carman R McNary is the managing partner of the Edmontonoffice. He concentrates his practice primarily in the areas of tax-ation and corporate law, with emphasis on compliance and dis-pute resolution with government agencies, and on corporate taxstrategies, structures and governance of tax risk, particularlyfocusing on First Nations and cross-border enterprises. Carmanchaired Dentons’ national tax practice group from 2002 to2012.Carman acts for Canadian and international companies

advising on tax efficient structures and effective tax manage-ment. This includes advice to First Nations and in respect ofstructures with First Nation enterprises as well as advice inrespect of cross-border investment into and from Canada, pri-vate and public transactions, structures and taxation issues, andincluding acquisitions, divestitures and reorganisations, transferpricing and withholding taxes.Assisting clients with audits, objections to the Canada Rev -

enue Agency and appeals to courts when required, Carmanworks to resolve tax related disputes at the earliest level. He hasappeared before the Supreme Court of Canada and extensivelybefore the Tax Court of Canada, the Federal Court TrialDivision and Federal Court of Appeal, and all levels of court within Alberta, on matters relat-ing to income tax, goods and services tax (GST) and other commodity taxes. Carman is a member of the board of private corporations as well as not-for-profit organ-

isations, including past chair of the Edmonton Community Foundation and chair of theAlberta Chambers of Commerce. He is a frequent speaker on tax matters. From 2001 to2006, he was a sessional lecturer in taxation for the Faculty of Law at the University ofAlberta. He has been recognised by Best Lawyers in Canada 2013 as “Lawyer of the Year” intax law (Edmonton) and as one of Canada’s leading lawyers in the area of tax law in 2013,2014 and 2015.

Canada

Carman R McNary, QC

Dentons

2900 Manulife Place10180 – 101 StreetEdmonton, Alberta T5J 3V5Canada




As a partner and head of the tax controversy practice at Osler,Al Meghji is widely regarded as Canada’s preeminent tax litiga-tion counsel, holding an outstanding record of success in com-plex tax litigation matters in various courts. Al is supported byOsler’s tax group, which is consistently ranked as one ofCanada’s largest and most sophisticated tax practices.Al has been lead counsel in many of Canada’s most impor-

tant and high-profile tax cases. He has appeared in the SupremeCourt of Canada more frequently than any other Canadian taxlitigator and has successfully argued a number of landmark taxcases in that court, including Shell Canada (widely regarded asthe leading authority on economic substance and tax avoid-ance); Canada Trustco (that defined the scope of the CanadianGAAR); and GlaxoSmithKline (the first and only transfer pric-ing case heard by the Supreme Court of Canada).He is tax litigation counsel of choice for significant Canadian

and multinational enterprises. Al is also lead counsel in a num-ber of complex transfer pricing cases proceeding through thecourts, including several cases that will be the first to testCanada’s re-characterisation rule and transfer pricing penaltyprovision. Al has been widely recognised as a leading Canadian tax litigation practitioner by third-

party and peer review legal ranking directories, including Chambers Canada (2016), BestLawyers in Canada (2016), Lexpert/American Lawyer Guide to the Leading 500 Lawyers inCanada (2016) and the Tax Directors Handbook. He is the only tax litigator in Canada toreceive the coveted “Star Individual” rating by Chambers Global and Chambers Canada(2016). Al was also recognised by Best Lawyers as “Tax Lawyer of the Year” and by Best of theBest 2015: Expert Guides as “One of the World’s Top 30 Tax Practitioners”. Al is a CPA and a graduate of Harvard Law School (LLM). He was previously counsel in

the tax litigation section of the Department of Justice. He is a sought-after speaker on mattersof tax litigation and trial advocacy, and appears regularly in the media on tax matters of sig-nificance both nationally and globally.

Canada

Al Meghji

Osler, Hoskin & Harcourt

100 King Street West1 First Canadian PlaceSuite 6200, P.O. Box 50Toronto, ON M5X 1B8Canada

Tel: +1 416 862 5677Email: [email protected] Website: www.osler.com



Dave Muha, Deloitte Canada, is a senior tax litigator with over17 years’ experience practicing in the area of tax controversyand tax litigation, and is a co-founding partner of the Torontooffice. Dave is recognised in International Tax Review’s TaxControversy Leaders guide as one of Canada’s leading tax litiga-tion practitioners. He is a former adjunct professor at the Uni -versity of Western Ontario’s Faculty of Law and is a frequentspeaker on tax controversy issues at various conferences andseminars. Dave’s practice encompasses all aspects of tax controversy

and tax litigation, including management of large and complextax audits, disputing tax assessments through administrativeappeals or litigation in the courts, voluntary disclosures, appli-cations for judicial review of decisions of tax authorities andapplications in the provincial courts for the rectification oftransactions with unintended tax consequences. Dave has repre-sented clients in proceedings in the Tax Court, Federal Court,Federal Court of Appeal and the Provincial Superior Courts ina wide variety of such tax matters. A significant portion of hispractice involves the management and litigation of transfer pric-ing and cross-border tax disputes. After receiving his Bachelor of Laws from the University of Victoria in 1997, Dave was

admitted to the Law Society of British Columbia in 1998 and to the Law Society of UpperCanada in 2000. His clients consist primarily of large domestic and multinational enterprises,including several Canadian and foreign financial institutions, Fortune 500 companies andother public multinationals.

Canada

David Muha

Deloitte Canada

Bay Adelaide East22 Adelaide Street West, Suite 200Toronto, ON M5H 0A9Canada

Tel: +1 416 601 5969Fax: +1 647 497 6865Email: [email protected]: www.deloittetaxlaw.ca



Markus Navikenas, Deloitte Canada, is a partner and an econo-mist in the transfer pricing services practice in the Calgaryoffice. Markus has significant experience in transfer pricing andbusiness model optimisation (BMO), dealing with the taxauthority on transfer pricing issues, and assisting clients withdeveloping dispute resolution and audit strategies.Markus has developed transfer pricing analysis and documen-

tation for numerous Canadian and US multinationals in theenergy sector. His experience spans a wide range, from develop-ing transfer pricing policies and studies to assisting taxpayers withdeveloping strategies for transfer pricing audits. He also assistsmultinationals with responding to tax authorities on transferpricing matters including voluntary disclosures, advance pricingarrangements, and obtaining relief from double taxation. Markus’ specialisms cover a broad number of issues including

determining pricing for intercompany loan interest rates, guaran-tee fees, receivables factoring, and energy and foreign exchangehedging transactions. He has also established royalty rates for thetransfer of intellectual property (IP) involving coiled tubingtechnologies, seismic 2D and 3D, trademarks, trade names, horizontal drilling know-how, cor-porate brands, and patents. Markus holds his MA from the University of Victoria, his MBA from the University of

Western Ontario’s Richard Ivey School of Business and he has been the co-dean of Deloitte’sGlobal Transfer Pricing School. Markus has written numerous articles and frequently speakson the topic of transfer pricing and IP for the Council for International Tax Education,Canadian Association of Petroleum Producers, Calgary Petroleum Tax Society, Deloitte’sGlobal Tax Roundtable, Acumen, as well as the Economic Society of Calgary.He was recognised by Euromoney as one of the leading transfer pricing advisers, globally,

in 2013.

Canada

Markus Navikenas

Deloitte Canada

850 – 2nd Street SW, Suite 700Calgary, AB T2P 0R8Canada




Joel A Nitikman is a tax partner. He has extensive experience intax litigation and resolving disputes between taxpayers and gov-ernmental tax authorities. He has litigated in the SupremeCourt of Canada and settled many cases before trial. Joel’s skills include organising, analysing and structuring

complex data to determine the relevant tax issues, preparingwit nesses, drafting pleadings and arguments, excellent oraladvocacy and legal research, persuading and reasoning in a com-plex environment and assimilating a large number of factsquickly. Joel is listed as a leading tax litigator by Lexpert.Joel also practices corporate, individual and international tax

planning, including cross-border tax planning for the entertain-ment industry, offshore trusts, Canada-US corporate reorgani-sations, Canadian investment in the US, US investment inCanada and cross-border estate planning. Joel advises on goodsand services tax (GST) and provincial commodity taxes. Joel islisted as a leading corporate tax lawyer by Lexpert.Joel has obtained numerous advance rulings from tax auth -

orities. His abilities include creativeness and thinking ‘outsidethe box’ in creating new structures to achieve tax efficiency. Joelhas advised non-profit and other tax exempt entities, includ ingCrown corporations. Joel has structured public offerings of tax-related securities. Joel hasacted as an expert tax witness in civil litigation for plaintiffs and defendants and has developedthe ability to simplify and explain complex technical tax issues.Joel has written and presented many tax-related articles. He was awarded the Sherbaniuk

Award for an article on rectification. Joel is a former governor of the Canadian Tax Found -ation and a member of the CRA/CBA committee, the CBA/CPA joint committee and thefederal bench and bar committee.

Canada

Joel A Nitikman

Dentons

250 Howe Street20th FloorVancouverBritish Columbia V6C 3R8Canada




Rob O’Connor, Deloitte Canada, is a tax partner based inToronto. He has 30 years of public accounting experience,including the last 27 years with Deloitte Tax Law LLP inCanada. Rob provides income tax services and specifically trans-fer pricing services and advice to Canadian and foreign corpora-tions that are members of multinational corporate groups. The majority of Rob’s practice has been focused on provid-

ing transfer pricing services and advice since Canada introducedrevised transfer pricing rules in 1997. Over this period, Rob hasheld various leadership roles within Deloitte, including Torontotransfer pricing practice leader, Canadian transfer pricing prac-tice leader, global managing director-transfer pricing, and mem-ber of Deloitte’s global transfer pricing executive team.Rob’s tax and transfer pricing experience includes planning

and CA/APA engagements, dealing with the Canada RevenueAgency (CRA) on tax and transfer pricing issues and assistingclients to compile and present information to support transferprices and develop audit defence strategies. Rob has assistedclients in a wide variety of industries. He has been involved inmany projects dealing with the reorganisation or restructuringof global operations and the movement of functions, risks and ownership of assets.Rob has also been involved in many specialised tax consulting projects, particularly involv-

ing cross-border transactions, acquisitions, divestitures and inbound investment in Canada.He is a frequent speaker and writer on international transfer pricing and related tax issues.

Rob appears in Euromoney’s Transfer Pricing Expert Guide, the Best of the Best for TransferPricing and the Tax Advisers Expert Guide.Rob is a chartered professional accountant and has a bachelors degree in mathematics

from the University of Waterloo.

Canada

Rob O’Connor

Deloitte Canada

Bay Adelaide Centre, East Tower22 Adelaide Street WestSuite 200 Canada




Clifford Rand, Deloitte Canada, is the national managing part-ner and leader of the national tax litigation practice in Canada.Cliff is recognised as a leading tax litigation practitioner in theLexpert/American Lawyer Guide to the Leading 500 Lawyers inCanada, the International Tax Review’s Tax ControversyLeaders guide, and the Lexpert Guide to the Leading US/Canada Cross-border Litigation Lawyers. He is a frequent speak-er, writer and presenter at various conferences and seminars.Cliff was called to the Bar in Ontario in 1986 and in Alberta

in 1982. He has a particular specialty in assisting clients in man-aging large and complex tax audits, including audits involvingcorporate reorganisations, the general anti-avoidance rule(GAAR), cross-border transactions and transfer pricing. Oneimportant part of Cliff ’s practice is ensuring that the tax author-ities operate within lawful parameters regarding demands forinformation and documents, and representing clients in applica-tions to the courts for judicial review of decisions made by taxauthorities regarding access to information and other issues.Cliff also assists clients in correcting non-compliance issues andin rectifying transactions with unintended tax consequences.Cliff ’s main practice objective is to help his clients resolve

their tax disputes as efficiently as possible, by helping them negotiate favourable settlementswith the tax authorities or, when necessary, by bringing appeals and applications in the courts.Cliff is a graduate of Osgoode Hall Law School (LLM 1986) and McGill University (LLB

1981, BA with honours 1977). He first began practising law in Calgary, Alberta in 1982 and,for a few years in the mid-1980s, was a law professor at the University of Windsor.Cliff is a member of the Canadian Tax Foundation, International Fiscal Association, Ad -

vocates’ Society, and Canadian Bar Association.

Canada

Clifford Rand

Deloitte Canada

Bay Adelaide East22 Adelaide Street WestSuite 200Toronto, ON M5H 0A9 Canada

Tel: +1 416 775 8830Fax: +1 647 497 6865Email: [email protected]: www.deloittetaxlaw.ca



Yves St-Cyr is a partner in Dentons’ Toronto office, and a mem-ber of the firm’s national tax law group. For the past 25 years,Yves’ practice has focused on tax litigation and dispute resolu-tion. Prior to joining the private sector, he practiced at theFederal Department of Justice. He is a member of the Bar inboth Québec and Ontario. Yves has argued many tax cases before the Tax Court of Can -

ada, Federal Court, Federal Court of Appeal, Court of Québec,Québec Superior Court, and Québec Court of Appeal. He hasalso made written representations to the Supreme Court ofCanada. Yves has experience requesting interpretations or rulings

from the tax authorities, and filing and negotiating voluntarydisclosures. He prepares submissions, on behalf of his clients, tothe tax authorities at both the audit level and the objectionstage of an assessment, and assists his clients in negotiating set-tlements. He also obtained remission orders and has made rep-resentations to the Department of Finance regarding proposedtax legislation amendments. Yves previously lectured at the Chartered Professional Ac count ants of Canada Tax Sym -

posium, the Fiscal and Financial Planning Association, and the Tax Executive Institute. Hehas also taught taxation at the University of Québec in Montréal.

Canada

Yves St-Cyr

Dentons





Marc Vanasse is the national leader of PwC’s tax dispute resolu-tion team, and is managing tax partner in Montréal.Marc’s many years working at the Canada Revenue Agency

(CRA) before joining PwC greatly benefits his clients, throughinsight and assistance in all areas of tax controversy and favour -able dispute resolution.Because of his unique experience, Marc is a popular speaker

at conferences both nationally and globally.Marc has a wealth of knowledge and experience in many

areas of Canada’s income tax system, having spent more than 20years in the Income Tax Rulings Directorate of the CRA. He has also served as a member of the CRA’s GAAR com-

mittee (1999-2011).Marc has worked with the Department of Finance on num -

erous legislative changes including tax shelters, partnerships,corporate reorganisations, income trusts and green energy ini-tiatives. He met regularly with CRA appeals officers andDepart ment of Justice lawyers to discuss cases proceeding tocourt and reviewed Notices of Reply/Appeal and related brief-ings on topics such as corporate distributions, transaction costs,contingent liabilities, trusts and GAAR.Marc has mediated numerous technical tax disputes between

CRA auditors and taxpayers in his role as a senior executive within the Rulings Directorateon issues ranging from employee/shareholder benefits to corporate surplus stripping,resource taxation and estate planning. Marc was instrumental in managing and issuingnumerous complex and sensitive advance income tax rulings and interpretations.Marc has also represented the CRA as a speaker at numerous tax conferences and semi-

nars, including those sponsored by the Canadian Tax Foundation, the Tax ExecutivesInstitute, and l’Association de Planification Fiscale et Financière.

Canada

Marc Vanasse, CPA, CA

PwC

1250 René-Lévesque BoulevardWestSuite 2500MontréalQuebec, H3B 4Y1Canada




Canada

Robert AlbaralBaker & McKenzie

François BaretteFasken Martineau

Dominic BelleyNorton Rose Fulbright

Jacques BernierBaker & McKenzie

Nathan BoidmanDavies Ward Phillips & Vineberg

Wendy BrousseauMcCarthy Tetrault

Alexandra BrownBlakes

Michael BussmanGowling WLG

Brian CarrKPMG

David ChodikoffMiller Thomson

Chia-yi ChuaMcCarthy Tetrault

Peter CorcoranDeloitte

Carrie D’EliaOsler Hoskin & Harcourt

Guy Du PontDavies Ward Phillips & Vineberg

Serge GloutnaySerge Gloutnay

Gerald GrenonOsler Hoskin & Harcourt

Ed KroftBlakes

Wilfrid LefebvreNorton Rose Fulbright

Paul LynchKPMG



Canada

Martha MacDonaldTorys

Bill MaclaganBlakes

Janice McCartBlakes

Pooja MihailovichOsler Hoskin & Harcourt

Warren MitchellThorsteinssons

Stevan NovoselacGowling WLG

Yves OuelletteGowling WLG

David RobertsonEY

Daniel SandlerEY

Alan M SchwartzFasken Martineau

Jeffrey ShaferBlakes

Ken SkingleFelesky Flynn

John SorensenGowling WLG

Craig SturrockThorsteinssons

Paul TamakiBlakes

Louis TasséEY

Roger TaylorEY

Deborah ToazeBlakes

Jeffrey TrossmanBlakes



Canada

Scott WilkieBlakes

Matthew WilliamsThorsteinssons

Gary ZedEY



Gonzalo Schmidt Gabler is a partner at PwC Chile, in the San -tiago tax and legal services practice, and he is the partner incharge of the tax controversy and dispute resolution depart -ment.Gonzalo joined PwC Chile in January 2007, advising nation-

al and multinational enterprises in their defence in tax auditsand tax claim processes. From August 2010 to November 2012,he worked in the Chilean tax administration (SII) at the tax lit-igation department of the National Directorate, helping toimplement and develop the fiscal defence in the new tax justiceprocedure in the whole country, whereby for the first time ofthe history of Chile, the tax courts are independent from the taxauthorities.Gonzalo has substantial experience in the tax audits process,

administrative appeals, tax claims, taxpayers rights violation pro-cedures, real estate tax claims and transfer pricing tax claimsbefore the Chilean Internal Revenue Service, tax and customscourts and the Chilean courts of law.Gonzalo has a bachelor’s degree in law from the University

of Los Andes, and he also holds a degree in management andtax planning from the Pontifical Catholic University of Chile.He also has participated as a lecturer at the specialisation programme ‘New Tax Justice’ andhe has written and co-published several articles regarding tax matters (e.g. ‘The New TaxJustice in Chile’, ‘Discovery in Chile’, ‘Transfer pricing tax claims under Chile’s new tax jus-tice law’, and ‘Chile: New anti-avoidance rules: Substance over form?’).

Chile

Gonzalo Schmidt Gabler

PwC

Av. Andrés Bello 2711Las CondesSantiagoChile

Tel: +562 29400152Email:[email protected]:www.pwc.com/taxcontroversy



Chile

Cristian AsteVillarroel, Lecaros, Aste and Baraona Abogados

Roberto EdwardsEdwards y Cia

Oscar FerrariGarrigues

Alex FischerAmplo

Pablo GonzálezSapag & González Abogados

Francisco LyonKPMG

Jessica PowerCarey

Sergio SapagSapag & González Abogados

Francisco SelaméPwC

Francisco ValdiviaAlcalde & Cia Abogados



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 of 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, detailedregulations and historical development of China’s tax laws andregulations and is familiar with tax administration, tax audit’smethodology and procedures.After 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 provides im -portant advice to the MoF and the SAT on some vital tax regu-lations on M&A, and proactively drives the issuance of someregulations relating to international taxation. Xiaoying is one of the few top level tax experts, even in PwC

China, with the experience from both the SAT and top levelinternational accounting firms. She accumulated extensive experience in M&A tax disputesand the related implementation. She assisted a client in getting the first special tax treatmentin a M&A deal in China, and assisted various foreign institutions/funds in negotiating vari-ous tax related matters with all levels of tax authorities for exit deals from China. Xiaoyingalso assisted the first REITs issued in China to negotiate its tax treatments with all levels oftax authorities, and set an excellent example for all later REITs’ tax-related structures issuedin China. In addition, Xiaoying acted as a tax adviser for Beijing-Zhangjiakou, applying forthe 2022 Winter Olympic Games. She assisted the related taxpayers to solve tax issues relatedto the transformation from business tax to value-added tax (B2V), and related disputes uponChina implementing the B2V reform nationwide. She is the tax adviser of many state-ownedenterprises and domestic private enterprises. She helped a lot of famous domestic privateenter prises in getting listed in overseas capital markets, offshore M&A, and privatisationdelisting.

China

Xiaoying Chen

PwC China

26/F Office Tower ABeijing Fortune Plaza7 Dongsanhuan Zhong RoadChaoyang DistrictBeijing 100020PRC




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 Inland Rev -enue Department. He has more than 25 years of experience intax 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 con-tributes frequently to professional publications on the subject.Spencer manages the firm’s ‘high potential cities’ initiative,

as well as managing the legal practice. On top of his involve-ment in securing the first five advance pricing agreements (APAs) negotiated in China,Spencer assisted a prominent South Korean multinational group in securing the first bilateralAPA between South Korea and China, assisted a Danish multinational group in securing thefirst bilateral APA between China and Europe, and was also involved in the first bilateral APAbetween China and Singapore.

China

Spencer Chong

PwC China

5/F, 3 Corporate Avenue168 Hu Bin RoadHuangpu DistrictShanghai, 200021PRC

Tel: +86 (21) 2323 2580Fax: +86 (21) 2323 8800Email:[email protected]:www.pwc.com/taxcontroversy



Frank Feng is a tax director of PwC China, Beijing Office.Before joining PwC China, Frank worked in the State Ad -

min istration of Taxation (SAT) for more than 17 years. His finalposition in the SAT was director of the Tax Treaty Divisionwithin the International Taxation Department. For more than12 years, he was engaged in bilateral tax treaty negotiations,drafting circulars to interpret tax treaty provisions for the pur-pose of application, handling cases of treaty application or dou-ble taxation through the mutual agreement procedure (MAP),and regularly participating in the OECD meetings of WorkingParty 1 on tax conventions and related issues. Frank is veryknowledgeable with international taxation policies and adminis-tration.Being the original author of the Chinese MAP application,

acceptance and examination procedures, Frank has deep insightson how to solve cross-border tax controversies through MAP.Frank has first-hand experiences in handling and settling MAPcases, which were not commonly used until recently, as moreand more cross-border tax disputes have arisen, involving signif-icant tax amounts. Through his prior exposures, he establishedand is maintaining a good network with the CompetentAuthority officials of other jurisdictions, which puts him in anadvantageous position in dealing with MAP cases. Frank has handled or helped to handle cases in relation to permanent establishment con-

stitution, attribution of profits, royalties, capital gains, international traffic, non-discrimina-tion, dual residency, beneficial ownership, general anti-avoidance rules, among others.

China

Frank Feng

PwC China

26/F Office Tower ABeijing Fortune Plaza7 Dongsanhuan Zhong Road,Chaoyang DistrictBeijing, 100020PRC

Tel: +86 10 6533 3336Fax: +86 10 6533 8800Email: [email protected]:www.pwc.com/taxcontroversy



Liang Gong is a tax controversy partner in PwC China, Shang -hai office, and leads the tax controversy practice in the centralregion of PwC China. He has over nine years’ experience inproviding China tax and business advisory services for multina-tional enterprises and domestic companies.Before joining PwC China, Liang had seven years of working

experience in Qingdao State Tax Bureau and gained first-handexperience in VAT refund, tax audit and tax administrationissues. During that time, Liang was often called up by the StateAdministration of Taxation (SAT) to join the taskforce of manynationwide tax audits. Further, Liang shared his experience andviewpoints via articles in several national and provincial journals.Liang has been dedicated to providing China tax and busi-

ness advisory services for his clients, and he is experienced in taxcontroversy services. His major industrial focuses include man-ufacturing, FMCG, and real estate, among others. Over theyears, Liang has achieved various successful outcomes for hisclients on tax controversy cases in a wide range of corporaterestructuring, VAT, business tax, export VAT refund, treatybenefits, tax audit defence and tax appeal cases.Liang’s capacity covers China tax and structure planning, tax

negotiation, China indirect tax, tax internal control, foreign contractor advice, 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. Liang obtained his bachelors degree in economics with a majorin taxation from Xiamen University. He also holds a CTA qualification.

China

Liang Gong

PwC China

5/F, 3 Corporate Avenue168 Hu Bin RoadHuangpu DistrictShanghai, 200021PRC




Lian-Tang He, Deloitte China, is the co-leader of the transferpricing team and a core tax controversy team member.Lian-Tang worked with the State Administration of Taxation

for more than 28 years and served as chief of the Anti-taxAvoidance Division, International Tax Section, as well as chiefof the Third Office of Large Enterprise Taxation, Administra -tion Section (Management of Tax Risks of Large Enterprises).He was the main architect of Chinese transfer pricing regula-tions. He has practised in taxation relative to the oil and gasindustry since 1984, and is an international tax and tax manage-ment specialist in this area. Lian-Tang has substantial experience serving multinational

clients in negotiation of APAs and other rulings, formulation ofinternal transfer pricing policy, audit defense and tax planning.

China

Lian-Tang He

Deloitte China

8/F Office Tower W2The Towers, Oriental Plaza1 East Chang An AvenueBeijing, 100738China

Tel: +86 10 85207666Email: [email protected] Website: www.deloitte.com.cn



Mike Jiang, Deloitte China, is a tax partner based in Shanghai.Between 1997 and 2008, Mike was with the foreign taxation

branch of Shanghai State Tax Bureau and gleaned a broad rangeof first-hand experiences through a profound portfolio of cases.Mike has held positions in various departments of the branch,including the tax policy, tax administration, and tax auditdepartments. During this period, his responsibilities includedtaxation management, tax inspection and explanation of taxpolicies regarding foreign invested enterprises. Mike’s provenrecord with the tax authorities has further been endorsed by hisfive-year plus leadership role during his 11-year tenure with thebureau.Since joining Deloitte China, Mike has been dedicated to

providing China tax and business advisory services to his clients,particularly in rendering tax controversy services given his sea-soned background. His major industrial focus includes manu-facturing and real estate.Over the years, Mike has achieved various successful out-

comes for his clients in tax controversy cases involving a widerange of issues, such as: tax audit support, enterprise income tax(EIT), overseas remittance, permanent establishment, beneficial ownership, VAT exemption,and many more. Since 2002, Mike has become a frequent and sought-after speaker at various tax policy

seminars hosted by renowned organisers, such as the Shanghai Institute of Certified Account -ants, Shanghai Foreign Invested Enterprises Committee and many accounting firms. Mean -while, Mike has also published articles in various magazines such as Shanghai Finance andTaxation, and contributed to tax policy research in Shanghai along the way. Mike is a certified public accountant (CPA) and a certified tax agent (CTA) in China.

China

Mike Jiang

Deloitte China

30/F Bund Center222 Yan An Road EastShanghai, 200002China

Tel: +86 21 6141 1465Fax: +86 21 6335 0003Email: [email protected]: www.deloitte.cn



Daisy Kang is a tax director of PwC China, Guangzhou Office.She is specialised in providing solutions to clients’ tax contro-versial issues, including tax investigations, tax disputes, tax rul-ings, applications for favourable tax treatments, etc.Prior to joining PwC China, she was a tax official of the tax

assessment branch of the Xiamen State Tax Bureau.Daisy’s portfolio includes giant multinational groups and big

name SOE clients engaging in the industries of energy and util-ities, manufacturing, media, automobile, logistics, real estateand fast consumption products. She helped these clients in for-mulating strategies to defend their tax positions which cover awide spectrum, both income tax, withholding tax, VAT, busi-ness tax, real estate tax and transfer pricing matters. She alsohelped the clients to obtain favourable advanced tax rulingsfrom tax authorities, including tax preferential treatments forthe envisaged restructuring, etc. Throughout the years at the Guangzhou office of PwC

China, Daisy has participated in various technical training andworkshops conducted by the tax bureaux across China andmaintained close contact with the tax officials in major cities inSouthern China. Daisy also established good relationships withrelevant authorities at the state level, including the State Admin -istration of Taxation (SAT) and the Ministry of Commerce.

China

Daisy Kang

PwC China

18/F, PwC Center10 Zhujiang Xi RoadPearl River New CityTianhe DistrictGuangzhou, 510623PRC




Based in Shanghai, Yang Kun is a senior partner and director atLong An law firm since 2007. Yang specialises in the settlement of tax controversy and also

focuses on tax law, business law, corporation law, securities law,finance law, real estate law, asset securitisation, among others.He provides legal services in many aspects like corporate coun-selling, law business for enterprises, legal affairs on real estateand other civil and economic affairs. Yang is the legal adviser formany Chinese listed companies. He also excels in the opera-tional practice of project financing, industrial investment andfinancing, and credit financing.Yang obtained his BA in law from Dongbei University of

Finance and Economics in 1992 and his LLM from East ChinaUniversity of Political Science and Law in 1998. In 2005, hereceived his PhD from the economics department of TongjiUniversity.Before joining Long An, Yang worked on credit manage-

ment at Shanghai Pudong Development Bank for three years.He was also the vice director of Shanghai Hua Yi law firm andthe senior partner of Shanghai Jin Mao law firm.With nearly two decades of law practice experience, Yang has had numerous articles pub-

lished in various publications.

China

Yang Kun

Long An Law Firm

Zhong Jin PlazaShanghai, 200030China

Tel: +86 13501846129Office: +86 021 60857666Fax: +86 021 60857655Email: [email protected]: www.longanlaw.com



Eunice Kuo, Deloitte China, is a tax partner and the nationalleader for China/Hong Kong cross-border tax services, incharge of transfer pricing, business model optimisation (BMO)and tax structuring services.She has 29 years of experience providing cross-border tax

services. Before joining Deloitte China in 2010, she was the taxpractice leader and led the transfer pricing and international taxteams of Deloitte Taiwan.Eunice has many years’ experience providing transfer pricing

services. She started Deloitte Taiwan’s transfer pricing practice,where she helped clients by preparing transfer pricing reports,planning for cross-border transactions including those involvingsupply chain issues, performing transfer pricing due diligencefor M&A projects, helping to mitigate transfer pricing risk,assisting in settling tax audit cases, helping with the conclusionof advance pricing agreements (APAs) and mutual agreementprocedures (MAPs), and advising on tax issues arising frombusiness restructures. Eunice has led MAP and APA projects, aswell as significant tax dispute cases, and has successfully helpedclients achieve satisfactory results.Eunice is experienced in solving complex and difficult tax

dispute cases for clients. She has helped clients through formal tax controversy processes andhas also helped clients close tax disputes through negotiation and settlement.Eunice is a Taiwanese certified public accountant (CPA) as well as a Chinese CPA. She has

been named a leading transfer pricing adviser consecutively every year by Euromoney. She wasalso named one of the “Best of the Best” in global transfer pricing by International TaxReview in 2013-14.Eunice is a frequent speaker at public seminars and trainings for the tax authorities. She

has been active in associations in Shanghai and has spoken on behalf of enterprises. Eunicehas also contributed articles on transfer pricing to International Tax Review and other pub-lications.

China

Eunice Kuo

Deloitte China

Unit 7, 20F Bund Center222 Yan An Road EastShanghaiChina

Tel: +86 21 6141 1308Fax: +86 21 6141 0003Email:[email protected]: www.deloitte.cn



Sam Li, Deloitte China, has over 20 years of working experiencein tax, including corporate tax and individual tax.Before joining Deloitte China, he worked in the Tax Bureau,

participating in the establishment and explanation of some cen-tral and local tax rules. Sam knows the tax rules and regulationson domestic and foreign ventured enterprises well. He has richtax working experience in various industries and has supplied taxplanning and tax consulting services to many foreign anddomestic enterprises, as well as state-owned enterprises andlarge private real estate groups. He is experienced in tax rules,market entry and foreign exchange in China’s real estate indus-try.Sam is a certified taxation agent of China.

China

Sam Li

Deloitte China

35/F One Pacific Place88 QueenswayHong Kong

Tel: +852 2238 7881Fax: +852 2520 6205Email: [email protected]: www.deloitte.cn



Donald Lin is a tax director of PwC China, Guangzhou office,specialising in tax controversy services. Before joining PwCChina in early 2016, he gained rich experiences in providing taxservices. Donald has over 10 years’ experience with the Guang -zhou Municipal State Tax Bureau and has worked in anotherinternational Big 4 firm for tax controversy services for anotherseven years. Donald has rich knowledge in tax laws, policies, and tax

admin istration. He also has extensive practical experiences inthe tax controversy services field. He is familiar with China’scommercial environment and norms. He has developed goodworking relationships with the Ministry of Finance, StateAdministration of Taxation and many other local tax authoritiesin various regions.With years of practice, Donald has successfully assisted many

multinational and domestic enterprises in different industries tosolve their tax controversies with tax bureaus, covering variousstages within tax administration cycle, namely tax assessment,tax audit, large enterprise tax audit, outward remittance taxrelated matters, and tax refunds, as well as applications for taxincentives and policy formulation.Donald has an MBA and is a qualified CTA from the China

Institute.

China

Donald Lin

PwC China





Martin Lin, Deloitte China, leads the tax controversy service,which consists of more than 30 controversy specialists, formertax officers and lawyers. Martin has extensive experience ininternational taxation and tax risk management, and has workedclosely with central and local tax authorities on policy makingand dispute resolution. The tax controversy team of DeloitteChina has substantial experience dealing with defence of anti-avoidance inspections and negotiations, regular tax audits,admin istrative reviews, applications for rulings and other taxadministrative confirmations. Martin has worked with Deloitte Tax LLP (Deloitte US) and

the Deloitte China tax practice for the past 25 years.

China

Martin Lin

Deloitte China

Unit 7, 20/F Bund Center222 Yan An Road EastShanghai 200002PRC

Tel: +86 2161411048Email: [email protected]: www.deloitte.cn



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). Hisfamiliarity with SAT officials and in-charge officers at variousprovincial and municipal tax offices is effectively functioning asa communication channel between tax bureau and taxpayers.He has assisted in resolving tough tax controversy issues andrepresented clients in tax negotiations in different locations inChina. His leverage of the connections and resources he haswithin the Chinese tax system is highly valued and appreciatedby clients.In recent years, Long has extensively provided tax service in

various fields, including application for tax treaty benefits,mutual agreement procedures (MAP) involving both SAT and local level tax authorities, anddefence against the application of the general anti-avoidance rule (GAAR) on cross-bordertransactions. He has engaged in various cases on tax audit defence, and his proven trackrecord of success in defence has been well recognised by his clients. The experiences gainedin these pursuits have proved a valuable resource for the tax controversy services team.Long graduated from the law school of Peking University with double bachelor degrees

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

China

Long Ma

PwC China

26/F Office Tower ABeijing Fortune Plaza7 Dongsanhuan Zhong RoadChaoyang DistrictBeijing, 100020PRC




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, Mat -

thew supports the practice nationally in respect of capturing thelatest tax and business regulatory developments, exploring taxefficiency 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 hasthe advantage of appreciating the motivations behind tax poli-cies and the approach of implementing the tax policies, and is ina strong position to communicate taxpayer views to the SAT.Thus, Matthew’s unique calibre has proved to be very helpful in preventing, managing, andresolving tax controversies between 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

PwC China

26/F Office Tower ABeijing Fortune Plaza7 Dongsanhuan Zhong RoadChaoyang District Beijing 100020 PRC

Tel: +86 (10) 6533 3028Fax: +86 (10) 6533 8800Email: [email protected]:www.pwc.com/taxcontroversy



Jason Su, Deloitte China, has gained 28 years of solid experi-ence in providing multinational and local clients in Tianjin withChina tax and business consulting services, which mainlyincludes tax planning, corporate restructuring and advice onbusiness and tax issues related to day-to-day operations of for-eign investment enterprises of various industries. Jason is aTianjin Economic-Technological Development Area (TEDA)business consultant, lead partner of the YuJiaPu FinancialDistrict overall strategic service project, financial risk manage-ment and control programme partner of Tianjin Port FreeTrade Zone Committee, and lead partner of Airbus negotiation,among other roles. Before joining Deloitte China, Jason served the various tax

bureaus in Tianjin for more than 12 years. His solid Chinese taxknowledge and experience enables him to provide quality andpractical advice. He actively represents clients in discussionswith tax authorities in connection with tax disputes and obtain-ing preference incentives.

China

Jason Su

Deloitte China

30/F, The Exchange North TowerNo.1189 Nanjing RoadHeping DistrictTianjin 300051PRC

Tel: +86 22 2320 6680 Email: [email protected]



Frank Tang, Deloitte China, is a tax partner, who has dedicatedmore than 26 years of his professional career to China tax devel-opment and practice.His career started in 1987, when he joined the foreign taxa-

tion branch of Tianjin Municipal State Tax Bureau of China asa tax officer. He was one of the first tax officers in China whohad dealt with international taxation after the policy of reformand opening-up had been widely rolled out in China. Frankhandled various important international and domestic tax casesback then and his work has earned him wide recognition fromthe taxpayers, the tax authority, as well as the tax professionals.Frank joined Deloitte China in 2001. During the past 14

years, he has provided excellent services to a great number ofmultinational and domestic clients in helping them to properlymanage their tax matters. He has extensive experience in varioustax and business related areas including tax controversy, customsdisputes, advance pricing agreements (APAs) and transfer pric-ing audit defence, China tax planning, compliance and businessadvisory. In the meantime, Frank has also maintained a verygood working relationship with multiple levels of Chinese government authorities, includingthe tax authority, customs office, administration of foreign exchange, investment promotionbureau, and others. He is also well respected by the government authorities.The proven track records of his practice, as well as his solid technical skills, have made

Frank highly regarded by his clients. He now represents significant number of enterprisesfrom multi national enterprises to small business in the fields of manufacturing, servicing,banking, and construction and engineering. In 2013 and 2014, Frank was recognised in International Tax Review's Tax Controversy

Leaders guide, which bases its research on a wide range of interviews with clients and otherprofessional lawyers and advisers.

China

Frank Tang

Deloitte China

30/F, The Exchange North Tower 1189 Nanjing RoadHeping DistrictTianjin 300051PRC

Tel: +86 22 23206609Email: [email protected]



Janet Xu is a tax partner at PwC China, Guangzhou office. Shehas over 20 years of tax professional experience, of which 19years have been in Chinese tax practice.Janet has substantial experience in advising companies on

dealing with tax audits, managing tax disputes on Chinese taxcontroversy issues, as well as proactively managing tax risks viaapplications for tax rulings, etc.Janet also has extensive experience in providing PRC tax

consulting on indirect tax, M&A, and corporate reorganisationand restructuring related to PRC tax issues. She has been serv-ing companies across a broad range of industries, including con-sumer and industrial manufacturing, retail, trading, banking andfinancial services.Janet has developed extensive networks with various govern-

ment departments, such as state and local tax bureaus and localbureaus of foreign trade and economic cooperation in theGuang dong region through her China tax career.Janet received her tertiary education in Australia where she

received both her bachelors degree in international business andher master’s degree in accounting. She is a member of theInstitute of Chartered Accountants in Australia.

China

Janet Xu

PwC China





Julie Zhang, Deloitte China, is a tax partner in Deloitte’s inter-national tax and mergers and acquisitions group and the nation-al tax and legal technical centre. She has more than 17 years of experience in advising finan-

cial investors and multinational enterprises in various industriesin China and international tax implications of a wide range ofissues related to investment in China, including entry strategies,joint venture formation, mergers and acquisitions, tax planning,reorganisations, individual income tax issues, permanent estab-lishment issues, application of tax incentives, etc. Julie also fre-quently participates in consultation meetings with the StateAdministration of Taxation on China tax issues. Prior to return-ing to China, Julie worked in New York and Silicon Valley forfive years, focusing on mergers and acquisitions and internation-al tax planning. Julie received her Juris Doctorate with distinction from the

Stanford Law School and Bachelor of Arts from Foreign AffairsCollege in China. She is licensed to practice law in the states ofNew York and California. In recent years, Julie has been recog-nised by prestigious publications including PLC Which Lawyer?,Chambers Asia Pacific, Legal 500 Asia Pacific. In 2014, Juliewas listed in Euromoney’s Women in Business Law Expert Guide.

China

Julie Zhang

Deloitte China

8/F Office Tower W2, The Towers,Oriental Plaza1 East Chang An AvenueBeijing 100738PRC

Tel: +86 10 85207511Email:[email protected]: www.deloitte.cn



Andrew Zhu, Deloitte China, is the managing partner of theDeloitte Northern China tax practice and a member of the taxcontroversy group. He has more than 26 years of experience inDeloitte China and Deloitte US tax practices, and extensiveexperience in global tax planning, compliance and structuring.He represents large multinational clients in dealing with largetax disputes with the Chinese revenue agencies and customsadministration. He also advises China-based companies on han-dling various tax audits in China and around the world.Before joining Deloitte China, Andrew had seven years of

experience working for the Chinese State Administration ofTax ation (SAT, national office). During his tenure with theChinese tax authority, he undertook senior responsibilitiesincluding drafting two of 18 Chinese tax laws and other poli-cies, and served as one of the key representatives from theChinese tax authorities responsible for tax issues on foreigninvestment in China. Andrew now serves as a specially invitedtax expert by the National People’s Congress, Ministry ofFinance and the SAT assisting in the China taxation reform.Andrew is a CPA both in China and the US. He is a frequent

speaker regarding Chinese business and tax issues at variousconferences and has published more than 40 articles and (co-authored) three books onChinese taxation both in English and Chinese.

China

Andrew Zhu

Deloitte China

8/F Office Tower W2The Towers, Oriental Plaza1 East Chang An AvenueBeijing, 100738China

Tel: +86 10 8520 7508Fax: +86 10 8518 1326Email: [email protected]: www.deloitte.cn



China

Henry ChanEY

Jon EichelbergerBaker & McKenzie

Brendan KellyBaker & McKenzie

Nancy LaiBaker & McKenzie

Lilly LiKPMG

David LingKPMG

Jinghua LiuBaker & McKenzie

Lewis LuKPMG

Curtis NgKPMG

Peter NiZhong Lun

Jane WangPwC

Jason WenBaker & McKenzie



Camilo Cortés is a partner and head of the firm’s tax group. Heis also in the firm’s mergers and acquisitions, trusts, estates andwealth preservation groups.

Major legal directories universally recommend him for hisdepth of knowledge and experience in this area. With almost 25years in the field, Camilo’s practice benefits from his previousexperience at a leading tax boutique firm, as well as his interna-tional education at Austral University (Argentina) and HarvardUniversity (US).

Camilo handles the full range of tax work, including day-to-day advisory and planning, transaction structuring, internal re -organ isations and corporate restructurings, and litigation. Hisclients include leading local entities and major multinationalsfrom a variety of sectors, including construction, energy andnatural resources, manufacturing, consumer goods, foods andbeverages, and IT industries.

Colombia

Camilo Cortés

Dentons

Carrera 7 No. 71-52Torre-B Piso 9Bogotá D.C

Tel: +57 1 313 7800 x225Email:[email protected]: www.dentons.com



Nacira Lamprea Okamel is the partner of PwC Colombia’s taxcontroversy and dispute resolution practice as well the leader oftax and legal services department of the Barranquilla andMedellin offices. She has been working with the firm for morethan 25 years. She has experience in development, managementand leadership of tax litigation and tax processes at both admin-istrative and jurisdictional levels.

Nacira has represented numerous companies in disputesagainst national and municipal tax authorities. She has also ledimportant projects on tax management and outsourcing ofcompanies’ tax functions, in particular with recognised compa-nies in the pharmaceutical, aeronautical and retail sectors.Furthermore, she has advised domestic and international com-panies on important matters related to income, VAT, and indus-try and commerce taxes, as well as provided advice and assis-tance on withholding tax issues.

As a recognised lawyer, she has been a speaker at conferencesorganised by the Association of Financial Executives (ACEF),the National Association of Manufacturers (ANDI), the Nation -al Federation of Commerce (Fenalco), and various bi-nationalChambers of Commerce.

Nacira is a professor at Pontifical Xavierian University, and former professor at the Univer -sity of Medellín and Universidad de la Sábana in Colombia.

Nacira is an attorney from Universidad de la Sabana and obtained a major in tax law fromthe University of Los Andes. She has also completed degrees and post-graduate courses inseveral topics such as corporate law (Del Rosario University), evidence law (Pontifical Xavier -ian University) and international taxation (University of Santiago de Compostela, Spain).

Colombia

Nacira Lamprea Okamel

PwC

100 Street 11a-35, 7th floorBogotáColombia

Tel: +57 1 6340555 ext. 10242Email:[email protected]:www.pwc.com/taxcontroversy



Colombia

Lucy Cruz de QuiñonesQuinones Cruz

Jaime Andres GirónBaker & McKenzie

Carlos Mario Lafaurie EscorcePwC

Camilo RodriguezKPMG

Margarita SalasEY

Vicente Javier TorresKPMG

Croatia

Maja MaksimovicKPMG

Dénes SzabóEY

Cyprus

Chris DamianouEurofast Taxand

Zoe KokonoEurofast Taxand

Philippos RaptopoulosEY

Angelos TheodorouEuroglobal SEE Audit



Denmark

Kaspar BastianBech-Bruun

Peter BjareKPMG Acor

Nikolaj BjørnholmBjørnholm Law

Johnny BøgebjergKPMG Acor

Tommy V ChristiansenTommy V Christiansen Law Firm

Lena SD EngdahlPwC

Ossi HaapaniemiHannes Snellman

Hans Severin HansenPlesner

Lida HulgaardHulgaard Advokater

Tom Kári KristjánssonPlesner

Henrik LundKPMG Acor

Martin NielsenKPMG Acor

Anders Oreby HansenBech-Bruun

Arne RiisAccura

Michael SerupBech-Bruun

Erik TodbjergPwC

Ecuador

Pablo AguirrePwC



Lari Hintsanen, Deloitte Finland, is one of the leading taxexperts in the country. He is well known in the market for hisexpertise in international tax matters and his vast restructuringand litigation experience.

Lari has gained extensive experience in advising the top man-agement of global groups to find practical solutions to tax strat-egy, transfer pricing and litigation strategies in variety of juris-dictions. He has also advised clients in finance transformationinitiatives.

Lari’s best capabilities are innovativeness and an ability toinspire people working with him to excel themselves.

Lari is a member of Finnish Industries, as well as the taxboard of the Chamber of Commerce.

Finland

Lari Hintsanen

Deloitte Finland

Porkkalankatu 24P.O. Box 12200180 HelsinkiFinland




Outi Ukkola, Deloitte Finland, serves a wide range of industrieswith more than 20 years of experience. Outi supports clientsgetting ready for tax audits and managing the audits through-out the process. She has an excellent relationship with the taxadministration and proactively communicates with the adminis-tration to explore the best options available for clients. Shecounsels on litigation strategies and assists with appeals indomestic courts and in mutual agreement processes. She ispraised for her analytical approach in most complex tax matters.

She has led and participated in business model conversionprojects cross borders, focusing in particular in intellectualproperty. Her recent projects include risk profile conversions ofmanufacturing sites, transfers of production lines and prepara-tion of supporting business analysis. Outi has coordinated trans-fer pricing documentation and valuation work, participated indue diligences and many post-acquisition/integration planningprojects. She has initiated BEPS readiness reviews, value chainanalysis and relevant documentation for clients working crossborders. In M&A, she recently led Finnish tax advisory andcontributed to international tax planning of two large multina-tional manufacturing groups planning to merge.

She has also assisted the Ministry of Employment and the Economy in R&D incentiveresearch and planning.

Outi joined Deloitte & Touche Oy in 2002, working as the head of tax and legal until2007. Since 2007, she has focused on development and risk management. Before joiningDeloitte, Outi was the leader Arthur Andersen’s international and corporate tax service inHelsinki from 1991-2002. From 1990 to 1991, Outi worked at PwC. Previous to that, shewas at the National Taxpayers’ Association from 1987–1990.

Outi has a LLM degree from Helsinki University and is trained at bench by the PiikkiöCourt.

Finland

Outi Ukkola

Deloitte Finland

Porkkalankatu 24, PL 12200181 HelsinkiFinland

Tel: +358 (0)20 755 5314Mobile +358 (0)40 588 3632Fax: +358 (0)20 755 505Email: [email protected]: www.deloitte.fi



Hanna Viilo, Deloitte Finland, has more than 15 years of expe-rience in international taxation. Her main focus is on supplychain related tax matters and group reorganisations. She is aregular adviser in corporate taxation and transfer pricing mattersto Finnish and foreign multinational groups.

Before joining Deloitte Finland in 2012, Hanna worked asthe head of tax in a multinational industrial company in Finland.In this role, she was responsible for the overall tax managementand strategy of the group. Based on her in-house experience,she has a superb understanding of the interaction of businessand tax. Hanna’s clients especially respect her pragmaticapproach and ability to implement complex tax issues in theirbusiness environment. During her in-house career, she alsogained extensive experience in business reorganisations andM&A.

In the early years of her career, Hanna worked at the FinnishTax Administration for several years and has maintained a goodrelationship with the tax authorities.

During her professional years, Hanna has developed exten-sive experience in tax controversy, especially in tax audit defence, court procedures andadvance ruling processes, mainly focusing on cross-border transactions and tax matters. Shehas also assisted clients in a number of significant Competent Authority procedures.

Hanna has obtained a Master of Laws degree from the University of Helsinki.

Finland

Hanna Viilo

Deloitte Finland

Porkkalankatu 24P.O. Box 12200181 HelsinkiFinland




Finland

Mikko AlakareBorenius Attorneys

Henri BeckerAlder & Sound

Ossi HaapaniemiHannes Snellman

Jussi JärvinenKPMG

Janne JuuselaBorenius Attorneys

Einari KarhuBorenius Attorneys

Eija KuivistoPwC

Antti LehtimajaKrogerus

Hannu-Tapani LeppänenAlder & Sound

Reima LinnanvirtaAlder & Sound

Jukka LyijynenEY

Jarno MäkeläKPMG

Kennet PetterssonKPMG

Petteri RapoAlder & Sound

Eric SandelinKPMG

Sami TuominenBird & Bird



Laurent Borey is one of five practice leaders heading MayerBrown’s tax practice worldwide and is also member of the teamleading Mayer Brown’s investment fund group.

Admitted to the Paris Bar, Laurent is one of France’s leadingtax lawyers on private equity matters (fund structuring andtransaction). He is popular for his work representing privateequity sponsors and his vast experience in the tax structuring oflarge, complex, cross-border M&A transactions. Laurent alsoregularly advises prominent entrepreneurs on their personal taxmatters and has developed a renowned expertise in tax litiga-tion.

Over the last few years, he has advised and played a key roleon many big international deals, with deal values totalling morethan $100 billion. These include: Cooper (Charterhouse),Cable vision (Altice), Suddenlink (Altice), NextRadioTv (GroupNews Participation), Comexposium (Charterhouse), PortugalTelecom (Altice), Express Roularta Group (Altice), Numeric -able-SFR (Altice), Worldwide Flight Services (LBO France),Labeyrie (LBO France), Elis (Eurazo), Parex Group (CVCCapital Partners), SFR (Numericable), Hamleys (Ludendo), and Vivarte.

Laurent ranks in band one in Chambers Global 2016 and was one of the nominees for the‘Law 360 MVP’ award for 2015. He was named ‘Lawyer of the Year’ in 2014 by the Frenchmagazine Option Finance and ‘Tax Advisor of the Year’ by Magazine des Affaires for 2011,2014 and 2015. Laurent is also one of the Mayer Brown practitioners listed in Who’s WhoLegal and in Who’s Who France.

France

Laurent Borey

Mayer Brown

20 Avenue Hoche75008 ParisFrance

Tel: +33 1 53 53 51 87Fax: +33 1 53 96 03 83Email: [email protected]: www.mayerbrown.com



Michel Combe is an international tax partner with more than 30years of experience in advising French and non-French multina-tional enterprises in the management and planning of their localand international tax issues.

He has developed an expertise in international tax structur-ing and transfer pricing projects including defence work, whetheras part of field audits in France and abroad, of mutual agree-ment procedures (MAP), or at French court level.

His clients are mainly active across the automotive, pharmaceu -tical and chemical industries as well as in technology, tele com -munications and communications, and transport and logistics.

He leads the value chain transformation team for Francewhich assists clients in aligning their tax strategy with their busi-ness strategy with regard to structures and flows.

Michel was the managing partner of PwC Société d’avocatsfrom 2009 to 2013.

He is regularly nominated as one of the best French expertsin the transfer pricing area including in 2015 by the French pro-fessional magazine Décideurs Juridiques.

Michel graduated from the Aix en Provence University ofLaw in business law in 1982. He also graduated from the HECMBA programme in 1984.

Michel is a registered lawyer (avocat).

France

Michel Combe

PwC

Crystal Park61 rue de Villiers92208 Neuilly-sur-Seine CedexFrance

Telt: +33 1 56 57 45 86Mobile: +33 6 07 85 46 90Email:[email protected]:www.pwc.com/taxcontroversy



Sabina Comis is a tax partner and international co-leader ofMayer Brown’s private investment funds group.

She has a wide-ranging 19 years’ tax experience with a strongemphasis on complex tax structuring of international transac-tions, restructurings and/or refinancing involving multi-spon-sors leveraged buy-outs. In addition to her experience in generaltax assistance to French and international enterprises, financialinstitutions have relied on Sabina’s tax guidance regarding secu-ritisations and on offers and issues of other types of structuredfinancial instruments, such as collateral debt obligations andrepo structures.

As a co-leader of the firm’s private investment funds group,Sabina also focuses on the creation and structuring of privateinvestment funds (such as French FPCIs, SLPs and SCRs andEuropean platforms such as SICARs, SIFs or UK LP) with aparticular emphasis on private equity, venture capital and mez-zanine/preferred equity funds.

Her tax experience coupled with her funds experience allowsSabina to advise on tailor-made, often innovative, structures forinvestments in France, but also throughout Europe, such as setting up: (i) the first Frenchtype endowment fund; (ii) the first French regulated and leveraged investment vehicle for thepurchase of discounted debt; and (iii) the first dedicated provider of mezzanine and preferredequity financing for private equity portfolios. In addition, Sabina has developed a specificknow-how in being able to help clients in the modeling of the ‘cash distribution article/waterfall mechanism’ of the funds documentation.

Sabina joined Mayer Brown in 2007 after 10 years of practice with two UK Magic Circlefirms, having trained and worked in their London and New York tax teams for four years andin their Paris tax teams for more than five years.

She is fluent in French and English, as well as in her native Italian.

France

Sabina Comis

Mayer Brown





With more than 40 years’ experience, Philippe Derouin is wide-ly respected in the French market, including by internationalclients and other professionals.

He works as an independent adviser, expert or litigator andis best known for complex tax controversies including beforeFrench courts, the European Court of Justice, the EuropeanCourt of Human Rights and courts in Monaco. He also givesexpert opinion in other jurisdictions. Philippe is also highlyregarded for his knowledge on tax and corporate law advice onmergers and acquisitions, corporate reorganisations, both indomestic and cross-border contexts. Areas of growth are taxcontro versy and independent opinion on complex/importanttransactions.

Throughout his career, Philippe has worked on key mergertransactions (Stallergenes/Greer, Match/Meetic, Air France/KLM, SCOR/MRM, Sanofi/Aventis). He obtained landmarkdecisions (Alitalia, Roval, Satam, Fonds turbo) and ground-breaking test cases (Golovan/Ukraine, Sudfer) that have beenpivotal for French law or have set a precedent.

Philippe has been a member of the Paris bar since 1973.Previously, he has been a partner at three major multinationallaw firms, namely Gide Loyrette Nouel (1987–99), Linklaters (1999–08) and Skadden ArpsSlate Meagher & Flom (2008–15).

Philippe has worked with a number of industry sectors including financial services (Creditagricole, SCOR SE a reinsurance company, The Carlyle group), retail and consumer products(LVMH and Quiksilver), pharmaceuticals and life sciences (Ares life sciences Stallergenes/Greer, Financiere BioAlfras), professional services (certain members of multinational partner-ships), utilities (motorway companies), and mining and metals (Glencore-Xstrata for theKon iambo site in New-Caledonia).

Some of Philippe’s clients include Layher (the French subsidiary of a German scaffoldingbusiness, in a test case currently pending before the French constitutional court), Staller -genes/Greer (a cross-border merger), Cheetah Mobile Inc. (China), DocuSign Inc. (bothcross-border acquisitions), and Parrot (the listed drone manufacturer, in a rights issue).

France

Philippe Derouin

Philippe Derouin, Avocatau barreau de Paris

140, rue du faubourg Saint-Honoré75008 Paris France

Tel: +33 1 42 25 88 91Mobile: +33 6 16 58 11 63Email: philippe.derouin@ cabinet-

derouin.comWebsite:www.philippe-derouin.com



Bruno Gibert joined CMS Bureau Francis Lefebvre as an equitypartner in 2001 and heads the transfer pricing group that theCMS network put in place within the tax practice. He specialisesin international taxation, more specifically in transfer pricing mat-ters.

He has 16 years’ experience in the government service,where he was in charge of international tax affairs (negotiationof tax treaties with foreign countries, OECD and EU work, andCompetent Authority). He was the co-chairman of the OECDForum on Harmful Tax Practices from 1996 to 2001. Since2002, he has been the chairman of the EU Joint Forum onTransfer Pricing and is also a member of the International FiscalAssociation (IFA) and chairs the scientific committee of the IFAFrench branch. He is a member of the IACF (Institute of taxlawyers), and the chairman of the tax committee of the Club desJuristes.

After graduating in political sciences at the IEP Paris(Sciences-Po) in 1979, Bruno completed his education with amaster’s degree in corporate and tax law at the University ofParis II (Assas) before entering the ENA. Bruno is a French native, who is fluent in English.

Bruno is the author of a report to the French government on tax security in France in2004 and co-author of two other reports to the French government, one on intangible assets(2006) and one on how to improve the commentary on French tax law (2010). He is alsothe co-author of the chapter on rulings of a book on French tax procedures (published in2005 and updated in 2008), a book on transfer pricing in France (‘Ed F Lefebvre’, 2010)and the author of the chapter on France of the book ‘Transfer Pricing and DisputeResolution’ published in 2011, updated on a yearly basis, and of the chapter on the mutualagreement procedure of a book on the OECD Model Convention (‘Ed Francis Lefebvre’,2014). He regularly publishes articles on international tax matters in French and internation-al publications.

France

Bruno Gibert

CMS Bureau FrancisLefebvre

2 rue Ancelle92522 Neuilly-sur-SeineFrance

Tel: +33 1 47 38 42 19Email: [email protected]: cms.law/bfl



Michel Guichard, Deloitte France, is a lawyer and tax partner.He also serves as leader of the Taj indirect tax, customs and taxcontroversy teams.

Michel has nearly 30 years of experience in international andFrench VAT law. After working for 17 years in the tax legislationdepartment of the Ministry of Economy, Finance and Budgetwhere he was in charge of VAT, customs and international taxtreaties, Michel joined Arthur Andersen in 1999. Followingthat role he joined Taj, where he now focuses his practice oncounselling French and foreign companies, advising some of thefirm’s largest clients.

Michel is a member of the International Fiscal Associationand APTE, a non-profit organisation of EU VAT experts. Hehas written articles for many tax newspapers.

France

Michel Guichard

Taj, Société d’Avocats

181 avenue Charles de GaulleF-92524 Neuilly-sur-Seine CedexFrance

Tel: +33 1 55 61 66 72 Fax: +33 1 55 61 47 97 Email: [email protected] Website: www.taj.fr



Sandra Hazan is a partner at the Paris office who practicesFrench and international tax law. Sandra is head of the Europetax group and co-head of the global tax group.

She is well versed in issues concerning restructuring and taxplanning and has a wide experience in assisting clients in taxaudits and litigation. While Sandra advises clients on tax issuesin all areas of business, she has developed specific expertise inthe luxury and cosmetics industry and in the field of privateequity, advising both investment funds and investors.

France

Sandra Hazan

Dentons

5 Boulevard MalesherbesParis, 75008France

Tel: +33 1 42 68 47 85Email:[email protected]: www.dentons.com



Admitted to the Paris Bar, Benjamin Homo is a partner in thetax practice of Mayer Brown’s Paris office.

He focuses on advising private equity clients and multina-tional enterprises on their acquisitions, mergers and reorganisa-tions. Benjamin has also developed extensive experience ofmulti-country transactions. He assists clients on all aspects ofthe transaction, from tax due diligence to structuring work,including financing matters and management incentives.

Benjamin also advises on the creation of French and pan-Euro pean private equity funds and assists corporate groups inthe day-to-day management of their tax affairs (tax audit/litiga-tion, reporting tools), as well as in the reduction of their globaleffective tax rate (French and international tax planning, trans-fer pricing, etc.). In this part of his work, he has handled numer-ous tax controversy assignments, from the audit phase to courtproceedings, including every step of the administrative process.His litigation experience spans a broad spectrum of issues, fromVAT or corporate tax claims for French companies to cross-bor-der transfer pricing disputes for US-based multinational enter-prises or debt to equity re-characterisation, as well as personal tax litigation. He also has expe-rience in APA negotiation.

France

Benjamin Homo

Mayer Brown





Admitted to the Paris Bar, Christopher Lalloz is a partner in thetax practice of Mayer Brown’s Paris office.

Christopher advises a large number of French and foreigncorporate enterprises in their acquisition and reorganisationtransactions, as well as their day-to-day tax management. Healso has extensive experience in assisting corporate enterprisesand individuals in the course of tax audits and litigations. Hispractice includes fund structuring assistance to French and for-eign private equity clients (including the structuring of carriedinterest rights held by managers) and assistance to individualson their personal tax issues.

Prior to joining Mayer Brown in 2007, Christopher was amember of a major financial consulting firm in Paris. He alsoworked for a year and a half in their New York office.

In addition to his native French language, Christopher is flu-ent in English.

France

Christopher Lalloz

Mayer Brown





Eric Lesprit, Deloitte France, was the former head of advancepricing agreements and mutual agreements procedures regard-ing double taxation elimination at the French tax administra-tion. He has more than 15 years of experience in transfer pricingand international tax with the French tax administration.

Since 1998, Eric worked for the French tax administrationregarding companies and individuals’ international taxationissues.

He participated in the design and the creation of the APApro gramme in France in 1999, and negotiated and concludedthe first agreements. He led the French APA programme sincelate 2008. In 2013, he created the new French CompetentAuthority, merging the APA programme and the mutual agree-ment procedures in a single department and constituted thenew team. As part of his missions, he was the French adminis-tration representative for Competent Authority procedures withforeign countries, especially those involving transfer pricing.

Moreover, he took part in the legislative drafting processregarding the fight against tax fraud and tax control policy, aswell as the management of tax information exchanges and guiding of the French audit direc-tions network.

At the international level, he intervened in the definition of French positions during theEuropean Community and OECD working sessions, especially regarding the fight against taxhavens and the negotiation of tax information exchange agreements with non-cooperativeterritories. He has been deeply involved in the OECD BEPS works.

From 2003 to 2006, he was the technical adviser for the IMF in Washington DC for pub-lic revenues (taxes and customs duties).

Eric was educated at the French Tax Administration School.Eric is working on several projects connected to various sectors of activities, including the

pharmaceutical, industrial or financial sectors. He is leading works in APA procedures, mutualagreement procedures, tax audit assistance and international tax strategy.

France

Eric Lesprit


181, avenue Charles de Gaulle92524 Neuilly-sur-Seine CedexFrance

Tel: +33 1 40 88 86 75Fax: +33 1 40 88 22 17Email: [email protected]: www.taj.fr



Gianmarco Monsellato, Deloitte France, is a tax attorney andthe global tax and legal leader for client and markets. He is amember of both the Deloitte global tax and legal executive andDeloitte France executive. He was previously the CEO of Tajfrom 2004 to 2016.

Gianmarco has more than 20 years’ experience in interna-tional tax and transfer pricing. He advises leading French com-panies in setting up and managing their global tax policies anddefends international companies regarding their French taxcontroversies. Gianmarco is considered as a thought leader ontax governance and has been consulted several times by theFrench government. He has published books and articles inFrance, Japan, the UK, the US and Switzerland.

He is the chairman of the French tax committee of the Inter -national Chamber of Commerce, a member of the InternationalFiscal Association and of the European American Chamber ofCommerce. He is also a board member of Fedora, the EuropeanFederation of Opera Houses.

He received in 2013 the United Nations ‘Women’s Empower -ment Principles’ award, saluting his exceptional championship ofgender diversity in the work place.

France

Gianmarco Monsellato


181 avenue Charles de GaulleF-92524 Neuilly-sur-Seine CedexFrance

Tel: +33 1 55 61 63 46Fax: +33 1 55 61 61 04Email: [email protected]: www.taj.fr



Pascal Seguin, Deloitte France, is a partner and the nationalleader for tax management consulting. He has more than 28years of experience, first as a civil servant with the French TaxAdministration for 17 years, where he started working in thecomputerised tax audit/data analytics field in 1986 and in thelegal e-invoicing field in 1988. He became an attorney-at-law in2000 and is now serving some of the firm’s largest clients. Hespecialises in e-invoicing advice, tax audit and computerised taxaudit management, and e-archiving strategies.

Pascal is a frequent speaker on e-invoicing and computerisedtax audit matters and is regularly consulted by the French taxadministration when preparing new administrative guidelinesregarding these matters.

Pascal is a graduate of the University of Paris in econometricsand in audit and expertise of information systems and digitaltechnologies. He was trained by the French National TaxSchool (Ecole Nationale des Impôts) and has been a fully quali-fied certified information system auditor (CISA) since 1992.

France

Pascal Seguin


181 Avenue Charles de Gaulle 92524 Neuilly-Sur-Seine CedexFrance

Tel: +33 1 55 61 69 80Fax: +33 1 40 88 22 17Email: [email protected] Website: www.taj.fr



France

Vincent AgulhonDarrois Villey

Gauthier BlanluetSullivan & Cromwell

Delphine BocquetPwC/Landwell & Associés

Eric BonneaudPwC

Bernard BoutémyDe Pardieu Brocas Maffei

Ariane CalloudBaker & McKenzie

Jean-Charles DavidAteleia

Nicolas de BoynesSullivan & Cromwell

Gilles EntrayguesCleary Gottlieb Steen & Hamilton

Pierre EscautPwC

Richard FoissacCMS Bureau Francis Lefebvre

Alain FrenkelFrenkel & Associés

Nadine GelliAshurst

Antoine GlaizeArsene Taxand

Audrey-Laure Illouz-ChetritFidal

Philippe LionBaker & McKenzie

Laurence MazevetKPMG/Fidal, Direction Internationale

Eric MeierBaker & McKenzie

Charles MénardEY



France

Eve ObadiaWagener & Associés

Marc PelletierFrenkel & Associés

Elisabeth RivièrePwC/Landwell & Associés

Régis TorletBaker & McKenzie

Jérôme TurotCabinet Turot

Cyril ValentinFreshfields Bruckhaus Deringer



Dr Ulf Andresen is an international tax partner in PwC’s Frank -furt transfer pricing team with 20 years of experience in advisingmultinational enterprises in international tax matters and trans-fer pricing. Moreover, he is a specialist in permanent establish-ment taxation and in transfer pricing matters in the financialservices industry.

Ulf has substantial experience in serving multinationalgroups of companies in complicated tax audits, appeals proce-dures in German tax courts and mutual agreement procedures.He has advised on a large number of APAs including in Den -mark, Finland, France (2), Ireland, Japan (2), South Korea, UK(2), and US (3). In the most recent APA, he managed to havethe two tax authorities extend the APA period beyond the orig-inal five years to a total of 14 years, including a rollback into apending tax audit, within only six months.

He is the co-publisher and co-author of the PermanentEstab lishment Handbook (Betriebsstätten Handbuch), the lead-ing publication in PE taxation in Germany, and speaks frequent-ly at tax conferences and contributes to national and interna-tional tax journals on a regular basis.

Ulf is also lecturing on tax and transfer pricing matters at the Friedrich-Alexander Uni -versity in Erlangen-Nuremburg and at the Federal Tax Academy (Bundesfinanz akademie).

Germany

Dr Ulf Andresen

PwC

Friedrich-Ebert-Anlage 35-3760327 Frankfurt am MainGermany

Tel: +49 69 9585 3551 Mobile: +49 171 178 3720Email: [email protected]:www.pwc.com/taxcontroversy



Dr Stephan Busch is the managing partner of Dentons’ Berlinoffice and head of the German tax law practice group.

He is a lawyer, certified specialist in tax law, and a certifiedtax adviser, who works primarily in the areas of tax and corpo-rate law.

Stephan focuses on mergers and acquisitions, restructuring,credit institutes, state-owned companies and also acts as a bar-rister before the finance courts and the Federal Fiscal Court(Bundes finanz hof).

Germany

Stephan Busch

Dentons

Markgrafenstraße 33Berlin, 10117Germany

Tel: +49 30 2 64 73 205Email:[email protected]: www.dentons.com



Axel Eigelshoven is a transfer pricing partner in PwC’s Düssel -dorf office. He has more than 20 years of experience in interna-tional taxation and transfer pricing. Before joining PwC, Axelworked for another Big 4 firm and assumed various roles,including head of their transfer pricing practice.

Axel is working on a wide variety of transfer pricing projectsincluding tax audits, IP migration, tax effective supply chainmanagement, permanent establishment issues, APAs andCompetent Authority procedures under the tax treaty and theEU Arbitration Convention. He has led many projects formultinationals to set up supply chain structures in BRICS coun-tries. His clients involve a number of DAX 30 companies, largemultinationals and mid-size companies. Axel is focused on theautomotive, engineering and chemical industry.

Axel lectures at the Mannheim Business School and is a fre-quent speaker on transfer pricing at national and internationalseminars. He is co-author of Vogel/Lehner, Doppelbesteuer ungs -abkommen, a leading commentary on tax treaties, co-author ofKroppen, Handbuch der Verrechnungspreise, a leading publica-tion on transfer pricing and is contributing the German country chapter in IBFD’s GlobalTransfer Pricing Explorer. Moreover, he has published numerous articles in national andinter national tax journals.Axel holds a degree in business economics (Diplom-Kaufmann) from the University of Cologne. He is a certified tax adviser(Steuerberater) and is a member of the Tax Advisors Association and the International Fiscal Association.

Germany

Axel Eigelshoven

PwC

Moskauer Straße 19D-40227 DüsseldorfGermany

Tel: +49 (0)211 981 1144Email:[email protected]:www.pwc.com/taxcontroversy



Stefan Grube, Deloitte Germany, joined Arthur Andersen in1996 following his graduation in German tax administration(Dipl. Finanzwirt). In 2002, he started with Deloitte Germanyin Düsseldorf, becoming the German business tax advisoryleader in 2013. He is a member of Deloitte Germany’s gover-nance board and internal tax quality assurance board, the latterdealing especially with difficult tax technical questions on spe-cific and general tax topics.

He serves a wide range of different clients, focussing on largemultinational inbound investors into Germany, especially USand UK headquartered multinationals with large German andEuropean operations. Apart from regular client tax advice, hefocuses on transactions and project-related tax advice with aninternational focus, such as M&A transactions, PMI restructur-ings, internal group restructurings, etc.

In this context, Stefan has experienced the German taxadministration’s changing approach in tax audits by becominggenerally more aggressive compared to previous years. Thus,Stefan has applied a more focused, concentrated and organisedapproach to tax audits. Besides tax technical defence and negotiations in tax audits in whichStefan is engaged, his experience covers tax litigations at different tax courts with a widerange of tax technical topics such as tax accounting, international tax, German participationexemption and German capital gains exemption. Furthermore, he is actively involved in man-aging Competent Authority procedures and arbitration procedures.

His experience has allowed him to develop a process and a training program together withNorbert Endres, external negotiation experts and representatives from the tax administration,on ‘how to professionally manage a tax audit’. The training course was released in 2016 anddeals with the soft skill areas in tax audits considering the Harvard Concept.

Stefan is a certified tax adviser (Steuerberater).

Germany

Stefan Grube

Deloitte Germany

Schwannstr. 640476 DüsseldorfGermany




Ulrich Grünwald, Deloitte Germany, has been a partner in theindirect tax service team in the Berlin office in 2015. Ulrich hasmore than 23 years of professional experience in the field oftaxes with a strong focus on indirect taxation. Ulrich started hisprofessional career as the head of a VAT audit department withthe German tax authorities. He continued his career as head ofthe VAT service team, as well as the international VAT centre ofexcellence of a global audit network for more than 10 yearswhen he joined a well-known tax focused German law firm as apartner specialising in indirect taxes.

Ulrich has extensive practical experience in advising domesticand multinational clients. He focuses on German and EuropeanVAT law, as well as in insurance premium tax law. His profes-sional experience includes VAT, insurance premium tax, otherindirect taxes and procedural law. He has developed a broadworking experience and serves clients in a wide variety of indus-tries including the service sector, the manufacturing and con-sumer industries.

He is a regular speaker at public tax events and a frequentpublisher on VAT and other indirect tax issues.

Ulrich received his JD in European VAT law at Erlangen/Nürnberg University. He is acertified tax adviser and a lawyer.

Germany

Dr Ulrich Grünwald

Deloitte Germany

Kurfürstendamm 2310719 BerlinGermany

Tel: +49 (0)30 25468 258Fax: +49 (0)30 25468 213Email: [email protected]: www.deloitte.com



Jörg Hanken is a transfer pricing partner in Munich and theglobal TP technology solutions leader. He has performed andmanaged numerous projects such as analysing, planning, imple-menting, documenting and defending transfer pricing struc-tures for more than 15 years. The recent projects mainly refer todispute resolution, value chain transformation and holistic TPimplementation including the use of software technology.

Some of his recent MAP/APA projects comprise of bilateralAPAs regarding distribution (Germany/US, TNMM berryratio), manufacturing (Germany/Poland, C+), distribution(Germany/Switzerland, TNMM ROS), business restructuring(Germany/US, valuation), manufacturing (Germany/Romania,C+), manufacturing/distribution/service (Germany/Sweden,profit split). He concluded the first bilateral APA regarding‘extraction royalty concepts’ (automotive, Poland) and heapplied a similar APA with Romania (automotive). Joerg nego-tiated some MAPs, recently regarding distribution and repairservices (aerospace industry, France).

Jörg gained experiences as an adviser, as well as a head of taxCentral Europe, for a US multinational. He frequently performsnational, as well as international, transfer pricing workshops and seminars and he is the authorof a leading German publication on transfer pricing from a tax and controlling perspective,‘Verrechnungspreise im Spannungsfeld von Controlling und Steuern’.

Jörg is a German certified tax adviser and a certified valuation analyst.

Germany

Jörg Hanken

PwC

Bernhard-Wicki-Str. 880636 MünchenGermany

Tel: +49 89 5790 5424 Email:[email protected]:www.pwc.com/taxcontroversy



Claudia Lauten is a transfer pricing partner at PwC Duesseldorfand Essen, Germany.

Claudia has over 20 years of comprehensive experience in taxconsulting, and more than 15 years in the area of transfer pric-ing.

Her expertise lies in the execution of global documentationprojects as well as the optimisation of value chains in considera-tion of principal structures. She also has extensive experience inM&A projects (due diligence, post-merger structuring), moni-toring audits by fiscal authorities and negotiating transfer pric-ing structures with competent authorities, including APA pro-cedures. Claudia’s clients comprise large multinationals, bothheadquartered in Germany or abroad.

Claudia is heading the German TP dispute resolution prac-tice, focussing on avoidance of disputes, tax audit defence work,litigation and Competent Authority procedures. She has excel-lent working relationships with various representatives from theGerman Competent Authority. In addition, Claudia is a mem-ber of PwC’s global tax controversy dispute resolution leader-ship team, combining efforts with PwC offices in other coun-tries on a day-to-day basis.

She publishes articles on dispute resolution issues and is a frequent speaker on the topic.

Germany

Claudia Lauten

PwC

Friedrich-List-Str. 20 45128 Essen Germany




Michael Massbaum, Deloitte Germany, is a tax partner in thetax and legal practice and has more than 25 years of experienceserving national and multinational clients. He is the leader ofthe private company services tax service line, and is experiencedin tax structuring and tax controversy work.

Michael has wide industry expertise in manufacturing, ener-gy, resources and real estate.

Michael is a lawyer and a member of the Berlin Bar. He isalso a licensed tax adviser. Michael is a member of the Inter -national Fiscal Association, German Tax Law Society (DeutscheSteuer juristische Gesellschaft) and Verein Berliner Kaufleute undIndustrieller.

Michael is the author of several articles on national and inter-national tax law. He is co-author of the DBA-Kommentar, aleading publication on double tax treaties, and of the HermannHeuer Raupach, Einkommensteuer und Körperschaftsteuer, aleading publication on income and corporate tax. Furthermore,he is a regular lecturer for corporate and international tax law.

Michael studied at the University of Osnabrück. He wrote adissertation on international tax law for which he was awarded his PhD in law.

Germany

Michael Massbaum

Deloitte Germany

Kurfuerstendamm 23 NeuesKranzler EckBerlin, 10719Germany




Dr Michael Puls, Deloitte Germany, is a tax partner in theDuesseldorf office leading the transfer pricing service line there.He has more than 14 years of relevant professional experiencein the area of transfer pricing and international tax.

Michael specialises in advising multinational enterprises in alltransfer pricing questions, being experienced in managing glob-al documentation projects, relocating of functions, supportingclients with government tax audits, mutual agreements andarbitral procedures, as well as in terms of tax planning projectsincluding advance pricing agreements (APAs).

Michael is the author of various publications in national andinternational tax law and transfer pricing. For example, he is theco-author of the Wassermeyer/Baumhoff handbook of transferpricing, a leading publication on transfer pricing in Germany.Michael is a frequent speaker at transfer pricing and internation-al tax expert seminars. Moreover, he is a lecturer at the Uni -versity of Augsburg, Faculty of Economics, in international taxlaw.

He is a lawyer and certified tax adviser.

Germany

Dr Michael Puls

Deloitte Germany

Schwannstraße 640476 Düsseldorf Germany

Tel: +49 211 8772 2235 Fax: +49 151 5800 3880Email: [email protected]: www.deloitte.com



Heiko Ramcke, Deloitte Germany, is a partner and the leader ofthe criminal tax law team. Heiko joined Deloitte in 2001 andhas many years of experience in criminal tax law.

With his team, Heiko defends clients in criminal tax proceed-ings and prepares self-disclosures to gain impunity for theclients. He also advises clients in preliminary investigations.Heiko serves multinational enterprises, as well as the manage-ment of national medium-sized businesses and individuals.

Heiko is also specialised in procedural tax law and advisesclients in all types of national disputes with tax authorities.Throughout his career, Heiko has represented businesses andindividuals in all stages of litigation proceedings and has assistedmany companies to litigate tax issues before the German taxauthorities and the finance courts.

Heiko is an attorney-at-law and studied law at the Universityof Kiel.

Germany

Heiko Ramcke

Deloitte Germany

Aegidientorplatz 2a30159 HannoverGermany

Tel: +49 (0)511 3075593Fax: +49 (0)511 30755950Email: [email protected]: www.deloitte.com



Prof Dr Stephan Rasch is a transfer pricing partner in PwC’sMunich office. He has 16 years of experience in internationaltaxation and transfer pricing. Before joining PwC in December2013, Stephan worked with another Big 4 firm as a transferpricing partner. Stephan advises clients in tax matters associatedwith cross-border transactions, including permanent establish-ment issues and value chain transformations. Stephan’s clientsinclude German-based DAX companies as well as European andUS multinationals.

Besides all transfer pricing-related matters, Stephan is suc-cessfully involved in German and European tax/transfer pricingaudits defending the restructuring and/or the transfer of intan-gible property in business model reorganisations. Stephan’s exp -erience with mutual agreement procedures includes bilateraland multilateral cases as well as the negotiation of bilateral andmultilateral advance pricing agreements. Finally, he is involvedin tax court litigation relating to transfer pricing cases. He hasbeen appointed as German national reporter on Subject 1, ‘Dis -pute Resolution’, for the 70th International Fiscal Associa tion(IFA) Congress in Madrid in 2016.

Stephan is a professor at the University of Augsburg and haslectured on international and European tax law since 2007. He is a frequent speaker on trans-fer pricing at national and international seminars. He has published a volume on transfer pric-ing legislation in international German, bilateral and European tax law. He is co-editor andauthor of one of the leading transfer pricing publications in Germany, Handbuch Interna tion -ale Verrechnungspreise, and co-author of a leading commentary on double tax treaties. He isalso editor of the Internationale Steuer-Rundschau (ISR), a German international tax journal.

Stephan is a member of the Munich Bar, IFA and the IFA Bavaria board. Stephan holdsa PhD in international tax law and a degree in law from the University of Bochum. He is atax lawyer (Rechtsanwalt/Fachanwalt für Steuerrecht).

Germany

Prof Dr Stephan Rasch

PwC

Bernhard-Wicki-Straße 8 München 80636 Germany




Alexander Schemmel, Deloitte Germany, is a partner and joinedthe firm in 2015.

He is responsible for the white collar crime prevention andinvestigations service line, and his core areas are corporatedefence and corporate compliance.

With his team, Alexander defends national and internationalcompanies as well as individuals in all areas of white collar andtax criminal law. He has extensive experience conducting inter-nal investigations and in the field of public, regulatory and cor-porate compliance. Alexander has defended several officers ofDAX companies and has advised major corporations in large-scale tax investigations.

In 2014, Alexander was ranked as one of the best consultantsin the area of white collar crime by Chambers Europe and BestLawyers.

Alexander has been an attorney-at-law since 2001. He stud-ied law at the University of Passau.

Germany

Alexander Schemmel

Deloitte Germany

Rosenheimer Platz 681669 München Germany

Tel: +49 (0)89 290368916Fax: +49 (0)89 290368911Email: [email protected]: www.deloittelegal.de



Dr Harald Stang, Deloitte Germany, is an attorney-at-law, taxconsultant and partner. He joined the firm in 1998 and wasappointed equity partner in 2002.

Harald has 16 years’ experience in advising different clientsin M&A transactions as well as in all respects of corporate law,in particular corporate restructurings. He also focuses on advis-ing the shareholders of family owned companies in connectionwith the law of succession.

Harald is also specialised in procedural tax law and advisesclients in all types of national disputes with tax authorities.Through out his career, Harald has represented businesses andindividuals in all stages of litigation proceedings and has assistedmany companies to litigate tax issues before the German taxauthorities and the finance courts.

Harald has studied law and economics at the University ofGöttingen. He previously worked as an assistant auditor with amedium size firm of auditors and tax consultants.

Germany

Dr Harald Stang

Deloitte Germany

Aegidientorplatz 2A30159 HannoverGermany

Tel: +49 (0)511 3075593Fax: +49 (0)511 30755950Email: [email protected]: www.deloittelegal.de



Susann van der Ham has more than 16 years of experience inconsulting multinationals in the field of transfer pricing. Herexpertise encompasses transfer pricing structuring, value chaintransformation, system implementation, documentation and taxaudit defence.

Susann’s clients include several DAX 30 multinationals, aswell as other US, European and Chinese corporations repre-senting a wide range of industries. During the few last years,Susann led a number of projects involving permanent establish-ments, complex restructurings including transfer of functionsand post-merger integrations. Susann is a member of PwC’sGerman retail and consumer competence team and the interna-tional retail and consumer transfer pricing network. As such,Susann has in-depth knowledge of industry specific transferpricing aspects.

Susann is a certified speaker on the German Federal CertifiedTax Consultant Association’s seminars and events and regularlyspeaks at international tax and transfer pricing conferences. Sheis the co-author of one of the leading German publications,Borberg Praxishandbuch. Verrechnungspreise. She frequentlypublishes in national and international tax literature on transferpricing in German and English. Her recent publications include ‘New Profit AttributionRules for Construction and Exploration Permanent Establishments’, published in the Inter -national Transfer Pricing Journal and a German article on the current issue of whether for-eign affiliated companies need to be charged for the use of the group’s name, published inthe German journal, Internationales Steuerrecht (IStR).

Susann studied business economics and tax law at the Dresden Technical University,Germany, and Japanese and international tax law at the KEIO University Tokyo, Japan. Shelater enrolled at Maastricht University for postgraduate studies of international tax law. Sheis a German certified tax adviser (Steuerberater).

Germany

Susann van der Ham

PricewaterhouseCoopersAG WPG

Moskauer Straße 19D-40227 DüsseldorfGermany

Tel.: +49 (0)211 981 7451Email:[email protected]:www.pwc.com/taxcontroversy



During more than 35 years of advising international corpora-tions and leading law firms, Alexander Voegele has special ised inthe defence of major international transfer pricing and IP cases.He has developed innovative economic structures for transferpricing strategies which have become the industry standard. Hehas led hundreds of large transfer pricing and IP projects anddefence cases for clients in a wide range of industries all over theworld. In recent years, he has defended transfer pricing auditsand litigation in North America, Scandinavia, Eastern Europe,and Germany.

In recent years, Alexander and his colleagues Philip deHomont and Tom Braukmann have established new standardsfor the separation and quantification of IP, financial instru-ments, and contractual clauses. They have advanced discussionwithin the industry by frequently explaining their methods atconferences and in publications. Using economic reasoning,they lead arbitrations and testify as expert witnesses in court.Their insights have helped shape transfer pricing and audit stan-dards in Germany and Austria, and they regularly exchangeviews with tax inspectors at conferences and seminars. In nego-tiations, they find well-structured and understandable arguments that are convincing andrelatable.

Alexander regularly publishes articles and books on transfer pricing and international taxplanning, and is the author and editor of the two leading German commentaries on IP, trans-fer pricing, and economic consulting: Transfer Pricing and Intellectual Property. His publica-tions have anticipated many aspects of the recent base erosion and profit shifting (BEPS) dis-cussions, such as the use of profit split methods or the analysis and quantification of risk. Hehas spoken at more than 250 conferences and seminars on transfer pricing and IP in Europe,the US, and Asia.

Alexander holds a PhD in economics and a MSc in tax and business administration fromthe University of Mannheim.

Germany

Alexander Voegele

NERA

Messeturm60308 FrankfurtGermany

Tel: +49 69 710 447 501Fax: +49 69 710 447 550Email:[email protected]: www.nera.com



Ludger Wellens is a tax and transfer pricing partner of PwC inGermany. He coordinates PwC’s transfer pricing activities in theregion of West. He has more than 19 years of experience in allaspects of transfer pricing and international tax planning.

Ludger is certified as a German tax adviser (Steuerberater).He holds a diploma in international business from the Uni -versity College Dublin (Ireland), an MBA from the Uni versityof Aachen and a PhD from the University of Bayreuth.

Ludger has worked for two of the Big 4 firms in their tax andtransfer pricing departments. He was also member of the boardand head of the transfer pricing group of a German based taxconsulting firm. Furthermore, he worked as tax director andhead of global transfer pricing for a major German based multi-national enterprise.

Both as an in-house consultant in industry and as an outsideexpert, Ludger has planned and implemented numerous trans-fer pricing systems. He has worked extensively on value chaintransformation projects both inbound and outbound.

He has extensive experience solving controversies throughdefending tax audits and supporting mutual agreement proce-dures as well as advance pricing agreements (APAs).

He has experience in planning, especially optimising valuechains, dispute resolution (audits, MAPs and APAs), business restructuring, documentationand IT-based documentation, and valuations.

Ludger specialises in the pharma and life sciences industry, chemicals industry, as well asin the consumer products and energy sectors.

Germany

Ludger Wellens

PricewaterhouseCoopersAG Wirtschaftsprüfungs-gesellschaft

Moskauer Str. 1940227 DüsseldorfGermany




Germany

Christoph BeckerBaker & McKenzie

Lorenz BernhardtPwC

Burkhard BinnewiesStreck Mack Schwedhelm

Dieter BirkP+P Pöllath

Eugen BogenschützAllen & Overy

Gero BurwitzMcDermott Will & Emery

Uwe ClausenOppenhoff & Rädler

Dr Felix DörrDr Gunter Dorr & Kollegen

Kati FiehlerPwC

Wilhelm HaarmannLinklaters

Ulf JohannemannFreshfields Bruckhaus Deringer

Andreas KempfPwC

Heinz-Klaus KroppenPwC

Thomas KüffnerKüffner Maunz Langer Zugmaier

Martin LenzKPMG

Nicole LooksBaker & McKenzie

Jochen LüdickeFreshfields Bruckhaus Deringer

Stefan MaunzKüffner Maunz Langer Zugmaier

Dirk PohlMcDermott Will & Emery



Germany

Ulrich RaenschBaker & McKenzie

Martin RenzPwC

Jürgen SchimmeleEY

Ulrich SorgenfreiUlrich Sorgenfrei

Gerhard SpeckerP+P Pöllath

Rudolf StahlCarlé Korn Stahl Strahl

Dr Michael StreckStreck Mack Schwedhelm

Thomas StreitKüffner Maunz Langer Zugmaier

Klaus von BrockeEY

Greece

Effie AdamidouKPMG

Tassos AnastassiadisEY

Angela IliadisKPMG

Georgios KatrinakisPwC

Spyros MaratosZepos & Yannopoulos

Spyros OikonomidisOikonomidis - Kontos

Andreas TsourouflisYour Legal Partners



Gulf Cooperation Council

Talal Al NaserKPMG

Rasheed Al-QenaeKPMG

Ebrahim BaeshenKPMG

Ashok HariharanKPMG

Zubair PatelKPMG

Robert PeakeCragus Group

Ganesh RamanathKPMG

Craig RichardsonKPMG

Mark StevensCragus Group



Colin Farrell has more than 37 years of professional experiencein Hong Kong and London, with the last 23 being in HongKong.

In the tax area, Colin is unusually, and probably uniquely,recognised by his external peers in three quite distinct areas:transfer pricing, tax disputes, and international tax, with a grow-ing additional recognition in M&A. He is twice recognised asone of the expert transfer pricing practitioners in Hong Kongby the Transfer Pricing Expert Guide, and further recognised byAcquisition International in its 2015 M&A Awards as ‘Best forTransfer Pricing – Hong Kong’ (as well as ‘Tax Expert of theYear – Hong Kong’). He is also recognised, for the third timein succession, as a leading dispute resolution expert by Inter -national Tax Review’s Tax Controversy Leaders guide (havingpreviously been recognised by International Tax Review as“among the firm’s leading lights for tax controversy in Asia”).He is also named, for the fourth time in succession, as one ofthe pre-eminent international tax practitioners in Asia byEuromoney’s Tax Advisers Expert Guide. Additionally, Colin wasrecognised in 2016 as ‘Corporate Tax Adviser of the Year inHong Kong’ in CIM’s global awards.

In Hong Kong, Colin services a wide range of clients, who range from individuals to themajor MNEs. He acts as general global tax coordinator for a number of these, and as global/regional coordinator for major due diligences. He also regularly spends very significant timeon non-tax consulting and general business issues with his clients, and is the global relation-ship partner on all matters with a few of these.

Colin has spoken and published extensively, including his own entirely external and wellregarded personal publications.

Colin has a MA in economics from Cambridge University, and is a fellow of the HKIC-PA, ICAEW & TIHK. He is a certified tax adviser and international tax examiner.

Outside of work, Colin sits on the joint liaison committee on taxation, is a twice-appoint-ed member of the HKSAR’s public affairs forum, and a board of advisers member of Inter -national Care Ministries.

Hong Kong

Colin Farrell

PwC Hong Kong

21/F Edinburgh TowerThe Landmark15 Queen’s Road CentralHong Kong

Tel: +852 2289 3800Fax: +852 2810 9888Email: [email protected]:www.pwc.com/taxcontroversy



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 Kongenter prises 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 practice 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 variousprofessional bodies in Hong Kong.

Angela is a member of the Hong Kong Institute of CertifiedPublic Accountants, the Association of Chartered Certified Ac -count ants, the Chartered Professional Accountants of BritishColumbia and the Hong Kong Institute of Chartered Secret -aries. She is a graduate of the Hong Kong Polytechnic University.

Hong Kong

Angela Ho

PwC Hong Kong

21/F Edinburgh TowerThe Landmark15 Queen’s Road CentralHong Kong




David Smith is a senior adviser to PwC’s tax practice in HongKong and China.

He commenced his career with the Australian TaxationOffice before joining the tax profession in Hong Kong almost30 years ago. During his career advising on Hong Kong andinternational tax issues, David has advised many of the world’slargest corporate groups, across all industries, on tax planning,structuring and dispute resolution. This has provided Davidwith an enviable understanding of the technical and practicalaspects of local and international tax issues.

In his role as a senior adviser to the tax practice, David actsas an experienced resource to assist partners and staff in relationto complex technical issues, dispute resolution and litigationsupport. As a consequence, he has involvement in a significantnumber of the firm’s clients’ major transactions as well asdomestic and cross-border tax disputes. Through this work hegains a unique insight into trends regarding issues being scruti-nised, attitudes of revenue authorities and methods of disputeresolution.

David also plays important roles in the practice with regardto thought leadership and international tax policy developmentsand trends. This ensures that the firm is well placed to ensure that its services and advice willwithstand the stricter rules and practices which they will be measured against, and the greatertransparency which they will face, in the years ahead.

David is a regular speaker and author of articles on tax matters in Hong Kong and China.

Hong Kong

David Smith

PwC Hong Kong

21/F Edinburgh Tower, TheLandmark15 Queen’s Road CentralHong Kong




Raymond Tang, Deloitte China, is a tax partner in the businesstax services group. He specialises in Hong Kong, Macau andChina tax, including tax planning for corporate restructuring,group re-organisations, IPO tax planning and tax controversyservices.

Raymond has 20 years of experience in the tax professionand has extensive experience in dealing with controversy casesfor various industries. He has participated in tax controversycases for retailing groups, manufacturing entities, constructioncompanies, PE funds, etc. In particular, he has solid experiencein dealing with controversy cases for clients with cross-bordertransactions like mainland China, Macau and Hong Kong, bygetting personally involved in various negotiations with taxassessors in Hong Kong, Macau, and southern mainland China.

Raymond has been invited to speak at seminars for the HongKong Institute of Certified Public Accountants (HKICPA), theAssociation of Chartered Certified Accountants (ACCA), andvarious universities in Hong Kong and Macau. He is also therecurring technical reviewer for the Hong Kong Master TaxGuide issued by CCH.

Raymond has a bachelor’s degree in professional accountancy from the Chinese Universityof Hong Kong. He is a member of the Hong Kong Institute of Certified Public Accountants(HKICPA), and a fellow member of the Association of Chartered Certified Accountants(FCCA).

Hong Kong

Raymond Tang

Deloitte China

35/F One Pacific Place88 QueenswayHong Kong




Philip Wong, Deloitte China, is a partner in the internationaland M&A tax services group and the lead transfer pricing part-ner in the Hong Kong office. He has a strong background incorporate taxation, spanning some 30 years, including priorprofessional experience with Deloitte’s Hong Kong office, theInland Revenue Department and as the regional tax director ina multinational enterprise.

Philip specialises in a wide range of areas, including HongKong taxation, cross-border transactions between Hong Kongand China, inbound investment strategies into Hong Kong andChina, transfer pricing management, pre-listing tax planningand restructuring, regional tax planning and group reorganisa-tion, and M&As in an international context.

Philip’s distinguished career has equipped him with compre-hensive skills and competence in serving MNEs that have vari-ous forms of investment in the Asia Pacific region and advisingthem on transfer pricing planning, supply chain optimisation,R&D/headquarter/regional cost sharing arrangements, andtax-efficient structuring for cross-border supply chain transac-tions. Philip has advised clients in a wide range of industries, including the real estate, phar-maceuticals, apparel, electronics, telecommunications, financial services, entertainment, andmanufacturing sections.

Philip has been recognised consistently as a leading transfer pricing adviser in Hong Kongin Euromoney’s Transfer Pricing Expert Guide in 2009, 2011, 2013 and 2015.

Hong Kong

Philip Wong

Deloitte China

35/F, One Pacific Place88 QueenswayHong Kong

Tel: +852 2852 1004Fax: +852 2854 2979Email: [email protected]: www.deloitte.com



Hong Kong

Lee Travis BenjaminIndependent

Daniel ChanDLA Piper

Joe ChanEY

Pierre ChanBaker & McKenzie

Kaiser KwanPwC

Ayesha LauKPMG

Amy LingBaker & McKenzie

Michael OlesnickyKPMG

Steven SiekerBaker & McKenzie

Richard WeismanBaker & McKenzie



Mihály Harcos, Deloitte Hungary, is an attorney-at-law and part-ner associate. He joined in 2016 as leader of the tax controversypractice. He provides comprehensive assistance in legal disputesinvolving the tax authority from tax audits through administrativeremedies to judicial proceedings.

As a tax lawyer, Mihály has successfully represented numer-ous precedent-setting cases before the Hungarian SupremeCourt. He also regularly represents clients before the taxauthority and courts in tax controversy matters. Mihály hasgained significant experience in tax cases involving the applica-tion of EU law and the practice of the European Court ofJustice. Mihály is the author of several tax litigation articles andhe regularly attends tax controversy conferences.

Before joining Deloitte Legal, Mihály worked at internation-al law firms and also gained experience at Deloitte Hungary’stax department between 2006 and 2008. He is a lawyer and acertified tax expert. Mihály has been a member of the BudapestBar since 2008 and speaks fluent English.

Mihály was mentioned in the Chambers Europe 2012 guide asa “…true up-and-comer who finds great examples to supporthis findings…”. He was also ranked in the Chambers Europe2013 and 2014 guides.

Hungary

Mihály Harcos

Deloitte Legal Szarvas,Erdős and Partners LawFirm (Hungary)

Dózsa György út 84/C1068 BudapestHungary

Tel: +36 (1) 428-6800Fax: +36 (1) 428-6801Email: [email protected] Website: www.deloitte.com



Barbara Koncz is a senior manager of the indirect tax depart-ment of PwC Hungary. She is a member and coordinator of thefirm’s tax controversy and dispute resolution group in Hungary.

Barbara Koncz joined PwC Budapest’s tax and legal depart-ment in 2008 where she started to work in the indirect taxgroup, focusing on VAT. Before joining PwC, she gained threeyears of public administration experience in the HungarianMinistry for National Economy and the Hungarian Investmentand Trade Agency where she was handling VIP cash subsidies.

During her years with PwC, Barbara has worked continuous-ly for both domestic Hungarian and international companies inthe pharmaceutical, automotive, and technology, information,communication and entertainment (TICE) industries. Sheoften advises her clients in VAT disputes and represents them intax audits. Besides VAT, she has a wide experience in connectionwith research and development and the related tax credits andsubsidies. She has good relationships with public and privateplayers of the domestic R&D sector.

Since 2011, Barbara has been the leader of the R&D work-ing group of the Hungarian Association of International Com -panies. The working group played an active role in the preparation of tender schemes andalso contributed to the elaboration of the national R&D strategy.

Barbara gained her JD from Eötvös Lóránd University, Faculty of Law and has a collegedegree in economics. She is a certified tax adviser.

Hungary

Barbara Koncz

PwC Budapest

Bajcsy-Zsilinszky u. 78.1055 Budapest Hungary




Zoltán Várszegi is a member of Réti, Antall & Partners Law Firm– PwC Legal in Budapest, Hungary. He is an experienced lawyerwith 20 years’ of experience in various legal fields including taxand customs litigation, M&A, corporate restructuring, energylaw, public utilities, civil law litigation, and so on. He advises abroad range of clients in different industries including the elec-tricity supply, financial services, public transport organisation,energy production and supply, and manufacturing sectors.

Zoltán has acted as the legal representative of both domesticand international companies as defendant before the court intax litigation cases. Most of these cases require highly versatilelegal approaches to countervail proceedings initiated by the taxauthority.

Zoltán leads the tax litigation practice group of PwC LegalHungary, which is a unique player in the legal services marketin Hungary as it is the only Hungarian qualified law firm thathas a long-standing cooperation with a Big 4 advisory firm.

His clients include some of the largest multinational compa-nies, from all industry sectors, such as financial services, energy,automotive, industrial manufacturing, and telecommunications.His experience is not limited to the most common taxes such asVAT or corporate income tax but also to personal income tax, local business tax, other indi-rect taxes (energy tax, innovation and education contribution) and tax administration. Zoltánalso participates in general tax advisory services in cooperation with PwC (involving the tax-driven structuring of groups of companies).

Zoltán has also gained significant experience in tax cases involving the application of EUlaw and the practice of the European Court of Justice. PwC Legal is one of the few firms inHungary that have been successful in convincing the court to apply EU law over the provi-sions of national tax law.

Zoltán graduated from Eötvös Loránd University, Faculty of Law as doctor iuris. Hespeaks both Hungarian and English.

Hungary

Zoltán Várszegi

Réti, Antall & Partners LawFirm / PwC Legal

H-1055 BudapestBajcsy-Zsilinszky út 78.Hungary

Tel: +36 1 461 9506Email: [email protected]:www.retiantallpartners.hu



Hungary

Balázs BékésBekes Partners

Michael GloverKPMG

Pál JalsovszkyJalsovszky Law

Tamás LőcseiPwC

Kovács OrsolyaNagy és Trócsányi

Botond RenczEY

Gergely RiszterBaker & McKenzie

Levente TormaDLA Piper

Zoltán VárszegiPwC/Reti, Antall & Partners Law Firm



Neeru Ahuja, Deloitte India, is a global business tax partnerbased in the Gurgaon office. Neeru is also the Asia Pacific globalbusiness tax leader for Deloitte India and leads the tax brandand communication team in India.

Neeru has over 20 years of diverse experience in corporateand international taxation. Neeru’s key areas of specialisationinclude corporate tax strategy and planning, tax litigation andcontroversy management, tax due diligence, tax and regulatoryaspects of mergers and acquisitions, inbound investment adviso-ry, and structuring cross-border transactions. Her client portfo-lio includes leading companies in consumer business, telecom-munications, aerospace, and defence.

Over the years, Neeru has developed a strong reputation inthe area of tax controversy management, working with manywell-known clients on several complex issues, including:• Assisting clients in strategy formulation to manage tax litiga-

tion more efficiently, considering alternative dispute resolu-tion mechanisms, scenario planning, and achieving closure;

• Assisting clients in resolving/mitigating their significant liti-gation issues;

• Assisting clients in representing their matters before variouslevels of tax authorities; and

• Representing industry on tax controversy issues with prominent chambers of commerceincluding meetings and committees set up by government. In addition to advising clients, Neeru is actively involved with various reputable industry

chambers and has been responsible for strengthening Deloitte’s eminence in the marketplace.She is the co-chairperson of the American Chamber of Commerce (AMCHAM) tax and tariffcommittee, as well as a member of the tax committees of the Confederation of IndianIndustry (CII), Federation of Indian Chambers of Commerce and Industry (FICCI) and theTDS committee of the Ministry of Finance. She is also a regular contributor to several leadingtax journals and mainstream papers.

India

Neeru Ahuja

Deloitte Haskins & SellsLLP

7th Floor, Building 10 Tower BDLF Cyber City ComplexDLF City Phase II (New Delhi / NCR)Gurgaon, Haryana 122002India

Tel: +91 124 679 2141 (Work)Mobile: +91 9811101589Email: [email protected]: www.deloitte.com



Rajiv Anand, Deloitte India, is a corporate tax partner in theglobal business tax practice in India. He has over 25 years ofexperience in domestic and international corporate taxationmatters including cross-border restructurings, legal interpreta-tions, in-depth analysis and strategic planning and advisory sup-port to clients. Rajiv has significant experience dealing with var-ious domestic and international organisations in relation to han-dling and assisting in their assessments and appellate matters.

The core areas of Rajiv’s experience includes internationaltaxation, due diligence and tax restructurings, in-depth analysisand strategic planning for inbound investments, keeping in viewthe taxation regime, double taxation avoidance agreements andexchange control regulations connected with complex cross-border transactions. In addition, he specialises in advising clientson various regulatory, corporate and tax aspects of corporationsdoing business with/in India, dealing with various domesticand international multinationals in relation to handling theircorporate and withholding tax assessments and appellate pro-ceedings including courts.

Rajiv’s experience also includes analysing the constitutionalvalidity of statutory provisions including retrospective amend-ments and advising clients on the same and day-to-day advisory and compliance support toMNE clients.

Rajiv is a member of the Institute of Chartered Accountants of India (ICAI) and also theInstitute of Cost and Works Accountants of India (ICWAI).

India

Rajiv Anand


7th Floor, Building 10Tower B DLF Cyber City ComplexDLF City Phase IIGurgaon – 122 022, HaryanaIndia




Manisha Gupta, Deloitte India, is a partner in the transfer pric-ing practice. She has more than 15 years of experience in thefields of transfer pricing and international tax and has securedsome key transfer pricing litigation in India.

Since joining Deloitte India, Manisha has assisted leadingIndian and foreign multinational enterprises to manage andresolve contentious transfer pricing controversy issues. She hasalso conducted a number of transfer pricing projects in a varietyof industries, such as pharmaceutical, infrastructure, FMCG,software and ITeS, hospitality, logistics and more, involvingaudit defence, MAPs, APAs, as well as planning and documen-tation studies. These have addressed a wide range of transferpricing issues such as financial transactions including guaran-tees, intangibles, and characterisation, among others.

Manisha is a frequent speaker on transfer pricing topics. Shehas written and co-authored various articles on transfer pricingcontroversies, alternate dispute resolution, and other topics. Sheis a member of the Institute of Chartered Accountants of India.

India

Manisha Gupta


India Bulls Finance CentreTower 3, 27th–32nd Floor, Senapati Bapat Marg, Elphinstone Road (W)Mumbai, Maharashtra 400013India

Tel: +91 22 6185 4288Email:[email protected]: www.deloitte.com



Gagan Kumar is a commerce graduate from Delhi Universityand a member of the Bar Council of Delhi, as well as a fellowmember of Institute of Chartered Accountants of India.

Before setting up Krishnomics Legal, Gagan was principalassociate with one of the largest law firms of India. Gagan hasalso worked with Big 4 accounting firms and brings with himmore than 17 years of experience.

He has extensive experience in litigation and advisory aspectsof the tax practice. He has successfully represented various cor-porates before the Supreme Court, High Court and IncomeTax Appellate Tribunal (ITAT) and Commissioner of IncomeTax (Appeals), Dispute Resolution Panel of Income Tax,Central Excise & Service Tax Appellate Tribunal, NationalConsumer Dispute Redressal Commission, among others.

Gagan has been recognised as India’s leading corporate taxlawyer by Who’s Who Legal in 2012 and as a tax controversyleader by International Tax Review in 2013 and 2014.

He has been a regular speaker at various national and inter-national forums. Gagan is a member of the Delhi High CourtBar Association and of the American Bar Association.

He has contributed various articles to national and international journals.Over the years, Gagan has advised a number of domestic and international companies on

tax issues relating to corporate tax, transfer pricing, mergers and restructurings, value addedtax (VAT), central excise, customs, service tax and others. He has also advised on structuringoptions to various private equity funds.

Gagan has advised many not-for-profit organisations from a tax and regulatory laws per-spective including compliance with the Foreign Contribution Regulations Act. He hasadvised leading multinational charities functioning in India. He is actively associated withplatforms helping not-for-profit organisations on a pro bono basis.

India

Gagan Kumar

Krishnomics Legal

N-117 (LGF)Panchsheel ParkNew Delhi-110 017India

Tel: +91 11 65092194Email:[email protected]:www.krishnomicslegal.in



KR Sekar, Deloitte India, is a tax partner and leads the globalbusiness tax practice. He is also the regional practice leader forDeloitte South India. Sekar has over 25 years of experience inthe field of direct taxes, mergers and acquisitions, internationaltaxation and transfer pricing. His client portfolio includes lead-ing companies in technology, media, telecommunications, man-ufacturing and engineering.

Sekar’s key areas of expertise include inbound structuring,litigation support and tax controversy management, and advis-ing on cross-border tax issues. He advises inbound global com-panies on entry strategy, inbound structuring and assists themon mitigating tax risks.

Sekar works closely with several reputable clients on litiga-tion and tax controversy management related matters. He hassuccessfully led several cases on critical issues relating to litiga-tion. He has also assisted global clients with path-breaking res-olutions on critical tax issues. He has been associated with manylandmark litigation cases for global companies.

In addition to advising clients, Sekar is active in representingbefore the government on various tax issues impacting industrythrough his position in the Chambers of Commerce. He is alsoa prolific writer, contributing regularly to tax journals and main-stream newspapers. He has written many books including ‘Transfer Pricing Law & Practice’,‘Taxation of Merger, De-merger & Foreign Collaboration’ and ‘Landmark Judgments ofSupreme Court on Direct Tax Laws: An Analysis’.

Sekar is the chairman of the direct taxes expert committee for the Bangalore Chamber ofIndustry & Commerce. He is also a member of the India board of International FiscalAssociation and also works closely with other chambers including NASSCOM. He is thefounder director of International Tax Research and Analysis Foundation (ITRAF), which isa dedicated research body in the field of international tax.

India

KR Sekar


Deloitte CentreAnchorage II100/2, Richmond RoadBangalore, Karnataka 560025India

Tel: +91 80 6627 6105Mobile: +91 98452 04631Email: [email protected]: www.deloitte.com



Rohan Shah is the managing partner at Economic Laws Practice(ELP) and leads the tax practice.

Rohan received his law degree from the Government LawCollege of the Bombay University. After his LLB, he workedwith Crawford Bayley and Co., Advocates and Solicitors inMumbai from 1988 to 1989. In 2001, Rohan co-founded ELP,a leading full-service law firm in India that has offices in six citiesand a team of over 130 professionals.

Rohan is a qualified solicitor and as a member of the UK LawSociety. He is authorised to also practice in England and Wales.He is well known for his expertise in advisory, policy and con-troversy issues related to indirect taxes (excise tax, service tax,VAT and customs), domestic and international taxation inIndia. He is also actively engaged in various advisory and trans-actional issues in the areas of corporate and commercial transac-tions, media and international trade laws. As a litigator, Rohanhas successfully represented a wide spectrum of clients beforethe Supreme Court, various high courts and the tribunals,resulting in several reported judgments in the areas of indirecttax and trade remedial disputes.

Rohan has been appointed to various expert committees formed by India’s Ministry ofFinance and Ministry of Commerce on issues related to the introduction of presumptive tax-ation for the gems and jewellery sector. He was also a member of the Indian CommerceMinister’s negotiating team at the WTO ministerial conferences in Seattle, held in November1999. At present, he is the legal expert on the CBEC sub-committee constituted by theMinistry of Finance in March 2016 to look into all issues relating to the imposition of exciseduty on jewellery.

Rohan has been listed as a leading lawyer in India for his expertise in taxation and TMTpractices by Asia Pacific Legal 500 and Chambers Asia-Pacific from 2009 until 2016, and byAsialaw Leading Lawyers from 2013 to 2015. International Tax Review hailed him as beingamong the leading tax lawyers in the world, while the Tax Directors Handbook recommendedhim from 2007 to 2016. He has also been selected as a leading lawyer by Who’s Who Legal –Corporate Tax from 2010 to 2016 and in Who’s Who Legal – Trade & Customs from 2013 to2016. Rohan was featured in Asian Legal Business Hot 100 in 2010 and India Today’s January2000 edition as one of the ‘50 Indians for the Next Millennium’. He won the Client ChoiceAwards 2014 in India for corporate tax, as a leading tax controversy adviser in India by TaxControversy Leaders (4th, 5th and 6th editions). World Transfer Pricing 2015 listed him as aleading individual for transfer pricing advisory services, while Benchmark Asia-Pacific 2014said he is a Leading Disputes Star in India.

India

Rohan Shah

Economic Laws Practice

109 – A Wing, Dalamal TowersNariman PointMumbai 400021 India

Tel: +91 22 6636 7000Mobile: + 91 99670 23300Email: [email protected]: www.elplaw.in



SP Singh, Deloitte India, advises multinational enterprises oninternational and domestic transfer pricing, encompassing doc-umentation, planning, and controversy defence. SP is the headof the tax controversy management practice and is the chiefnegotiator for advance pricing agreements (APAs) and mutualagreement procedures (MAPs). He provides services to majormultinational clients in a wide range of industries, includingsourcing of apparel, software development, IT and ITeS, phar-maceutical, cosmetics, chemicals and energy. Apart from Indianmultinationals, his clients are from various countries, includingthe US, the UK, Japan, Australia and France.

Before joining Deloitte India, SP was with the Indian Rev -enue Service for more than two decades. He held various posi-tions in the service, including director of income tax (interna-tional taxation) and commissioner of income tax (appeals). Heparticipated in the negotiation of tax treaties with more than 30countries and took part in MAPs. He has represented India inseveral international conferences and presented papers. SP was amember of the expert group on transfer pricing constituted bythe Ministry of Finance for drafting transfer pricing regulations. He also represented theIncome Tax Department before the Authority for Advance Rulings in several cases.

SP has an MSc in fiscal studies from Bath University in the UK, and has a master’s degreein physics from India. He is a member of the Bar Counsel of Income Tax Appellate Tribunaland is a regular contributor at the National Academy of Direct Taxes (apex training institutefor the Indian Revenue Service), Institute of Chartered Accountants of India, InternationalFiscal Association, and Indian Institute of Management, Lucknow. He is co-chairman of thedirect tax committee of ASSOCHAM. SP was included in 2013 and Euromoney’s 2014Transfer Pricing Expert Guide and has been named as a leading tax controversy leader for2014 and 2015. He has co-authored several white papers on transfer pricing-related mattersincluding APAs and safe harbour provisions, among others, and has co-authored two bookson transfer pricing.

He regularly contributes to international and national journals on taxation.

India

SP Singh

Deloitte Haskins & Sells LLP

iPark, Plot 15, Phase IV, GurgaonDelhi, 07 122001India




Naresh Thacker is a partner in the litigation and dispute resolu-tion practice of Economic Laws Practice (ELP), specialising inarbitration, commercial and tax disputes. He is a qualifiedlawyer and a solicitor in England and Wales.

Naresh has successfully represented clients in matters per-taining to economic offences before diverse tribunals and courtsin India. He is also actively involved in the field of alternatemodes of dispute resolution and has managed a number of ICC,LCIA, SIAC, UNCITRAL, Swiss rules and ad-hoc arbitrations.He has been part of mediation and conciliatory proceedings atthe clients’ behest and has brought them to fruition.

Naresh is currently active in a number of professional organ-isations including The Law Society UK, London Court ofInternational Arbitration (LCIA) and the All India Federationof Tax Practitioners (AIFTP). He is often quoted by prestigiousinternational journals and his articles continue to appear intrade publications around the world. He has been featured as aleading tax controversy adviser in India by the Tax ControversyLeaders (4th, 5th and 6th editions) and as an expert in WorldTax 2015.

Prior to ELP, Naresh practiced as an independent counsel on indirect tax and litigationmatters.

India

Naresh Thacker



Tel: +91 22 6636 7000Mobile: +91 98212 37857Email: [email protected]: www.elplaw.in



Alok Yadav is a partner in the litigation and dispute resolutionpractice of Economic Laws Practice (ELP). Based in Delhi, hespecialises in tax-related disputes.

Alok’s expertise spans across several aspects of law includingcustoms, central excise, service tax and litigation matters relatedto indirect taxes. He has appeared in more than 250 mattersindepen dently before the Supreme Court for clients such asPepsi Co, Hewlett Packard, Bharti Airtel, Cargill India, NestléIndia and Kelvinator Electrolux.

Alok holds a law degree from Delhi University and is a mem-ber of the Supreme Court Bar Association.

With over 14 years of experience as a legal professional in theareas of direct and indirect tax litigation, Alok started his careeras a lawyer with J.B. Dadachanji and Co. in Delhi in 2000. Sinceleaving that firm he has been associated with Lakshmikumaran& Sridharan Attorneys.

Alok has recently featured as a leading tax controversy advis-er in India in Tax Controversy Leaders (5th and 6th editions).

India

Alok Yadav



Tel: +91 11 4152 8400Mobile: +91 99714 99911Email: [email protected]: www.elplaw.in



India

Mukesh ButaniBMR Legal

Arvind DatarSole practitioner

S GaneshSole practitioner

Sujit GhoshAdvaita Legal

KR GirishKPMG

Akil HiraniMajmudar & Partners

Porus KakaSole practitioner

Dinesh KanabarDhruva Advisors

Gagan KumarKrishnomics Legal

Sunil LalaSML Tax Chamber

Vikram NankaniIndependent

Rajendra NayakEY

Percy PardiwalaSole practitioner

Karishma PhatarphekarKPMG

Rohan PhatarphekarKPMG

Alpana SaksenaOracle India

Harish SalveSole practitioner

Sanjay SanghviKhaitan & Co

Hasnain ShroffBSR & Co



India

Himanshu SinhaTrilegal

Vikas SrivastavaLuthra

Sanjay ToliaPwC

Vikas VasalKPMG

Rajan VoraEY



Yan Hardyana, Deloitte Indonesia, is a partner with more than12 years of experience in taxation with Deloitte and other Big 4firms. Yan has extensive experience serving a broad range ofmultinational enterprises, private equity firms and state-ownedenterprises from various industries including telecommunica-tion, advertising, manufacturing, and construction.

Yan is extensively experienced in tax consulting, and M&Aprojects, which include projects that comprise the taxationmerit for inbound and outbound investments.

Yan holds both the tax consultant and tax court practicelicenses, which enable him to assist clients in dealing with theIndonesian tax authorities and Tax Court. As part of DeloitteIndonesia’s tax disputes team, Yan has achieved a number ofsuccesses in assisting with tax dispute processes, tax refundprocesses, tax private ruling applications, tax facilities applica-tions, and many other assignments.

Indonesia

Yan Hardyana

Deloitte Indonesia

The Plaza Office Tower 32nd FloorJl. M.H. Thamrin Kav 28-30Jakarta Pusat, 10350Indonesia

Tel: +62 21 2992 3100 (ext: 33869)

Fax: +62 21 2992 8303Email: [email protected]: www.deloitte.com/id



Carlo L Navarro, Deloitte Indonesia, leads the transfer pricingpractice and specialises in transfer pricing, international corpo-rate restructuring and planning, cross-border taxation, and taxeffective supply chain transformations. Before Deloitte, Carloled the transfer pricing and international tax practices of a Big 4firm. He has more than 19 years of experience working in vari-ous jurisdictions in Southeast Asia as an international tax andtransfer pricing practitioner.

Carlo has assisted clients in various phases of transfer pricingengagements, from planning, documentation and audit defenceto negotiating APAs and MAPs. He has an excellent reputationin handling transfer pricing audits and bilateral negotiations.

He has published various articles in international tax jour-nals, covering issues on permanent establishments, taxation andtransfer pricing aspects of business restructuring, and the latestdevelopments in the area of transfer pricing in Southeast Asia.

Carlo completed his postgraduate studies at Harvard LawSchool, Harvard University, Cambridge, Massachusetts, US andhis law and political science degrees with honours from theUniversity of the Philippines.

In 2011, 2013 and 2015, he was listed as a leading Indo nesian transfer pricing adviser inEuromoney’s Transfer Pricing Expert Guide. He was recognised by World Tax (2013) for hismarket leading transfer pricing abilities. Under his leadership, Deloitte Indonesia was cited asa leading transfer pricing firm in Indonesia by World Transfer Pricing in 2013, 2014 and 2015.In 2014 and 2015, he was also recognised as one of the tax controversy leaders in Indonesiaby International Tax Review.

Under his leadership, Deloitte Indonesia was awarded as the ‘National Transfer PricingFirm of the Year’ in 2016 in recognition of its pioneering contributions to the transfer pricingland scape in Indonesia.

He leads a strong transfer pricing practice at Deloitte, consisting of foreign and local spe-cialists that combine international and local experience. His team has an impeccable reputa-tion for technical knowledge and precision, responsiveness and negotiation skills.

Indonesia

Carlo Navarro

Deloitte Indonesia

The Plaza Office Tower 32nd FloorJl.M.H Thamrin Kav 28 – 30Jakarta 10350Indonesia

Tel: +62 21 29923100 ext. 33620Fax: +62 21 29928303Email: [email protected] Website: www.deloitte.com/id



Cindy Sukiman, Deloitte Indonesia, is a partner with more than15 years of experience in taxation.

Cindy has extensive experience serving a broad range ofmulti national and large national clients, energy and resourcescompanies, manufacturing companies, consumer business com-panies and services companies. He has been substantially in -volved in various restructuring and tax planning projects inIndonesia. His tax advisory roles have covered a broad range oftax services including tax dispute/tax audit resolutions for vari-ous industries and acted as a legal proxy for appeals before theTax Court. In particular, Cindy has been regularly involved inundertaking various tax reviews and due diligence projects.

Cindy is a licensed tax adviser and licensed proxy for the TaxCourt. He has completed the Indonesian tax consulting exam,certificate C level. He is also a frequent speaker at conferencesnationally and abroad focusing on mergers and acquisitions(M&A) and energy and resources (E&R). Cindy is Deloitte In -do nesia’s M&A tax specialist, and E&R tax leader.

Cindy holds a Master of Business Administration in Financequalification from Michigan State University, US and a bachelorof science degree in agricultural engineering from Bogor Agricultural University (IPB).

Indonesia

Cindy Sukiman

Deloitte Indonesia

The Plaza Office Tower 33rd FloorJl MH Thamrin Kav 28-30Jakarta 10350Indonesia

Tel: +62 21 2992 3100Fax: +62 21 2992 8303Email: [email protected]: www.deloitte.com/id



Otto Sumaryoto is a director at PwC Indonesia and has been atax consultant since 2011, providing tax advice to a variety ofmultinational and domestic enterprises.

In 1994, Otto started working as a tax officer under theDirectorate General of Taxation for about 17 years. During thecourse of his career, he has gained comprehensive experienceand technical knowledge relating to tax audits, tax objectionsand tax litigation, as well as drafting proposed tax legislation.

With respect to the tax court proceedings, Otto is well estab-lished in handling tax controversy and dispute resolution. Ottois a licensed proxy of the Indonesian Tax Court.

Otto specialises in the taxation of mining companies. He hasextensive experience in a wide range of tax matters relating totheir business operations and has in-depth knowledge of con-tracts of work. He provides on-going advice to several leadingmining companies operating in Indonesia, including the largestprivate mining company and the largest coal mine in Indonesia,and also other companies or permanent establishments in vari-ous industries.

Indonesia

Otto Sumaryoto

PwC Indonesia

Plaza 89Jl. HR Rasuna Said Kav. X-7/6Jakarta 12940Indonesia

Tel.: + 62.21.52890328Fax: +62.21.5213946Email:[email protected]:www.pwc.com/taxcontroversy



Heru Supriyanto, Deloitte Indonesia, is a partner in the taxsolutions department with more than 25 years of experience intax, which includes five years as a government tax auditor and20 years as a tax consultant with a Big 4 firm.

Heru has extensive experience serving a broad range ofmultinational and large national clients in different industriesincluding manufacturing and consumer goods, media/enter-tainment, and telecommunication.

Heru’s tax advisory roles cover a broad range of tax servicesincluding restructuring, mergers and acquisitions, tax consult-ing projects, tax compliance and tax dispute resolutions (i.e. taxaudits, objections and appeals). In particular, he has been regu-larly involved in undertaking various tax reviews and due dili-gence projects. Heru’s experience also includes assisting clientswith discussions with local tax and land/building tax authori-ties.

Heru holds a post-graduate degree in tax administration,bachelors degree in economics (accounting) and a bachelorsdegree in law. He is a certified Indonesian tax consultant and isa member of the Indonesian Tax Consultant Association. Inaddition, Heru is a registered Tax Court attorney.

Indonesia

Heru Supriyanto

Deloitte Indonesia

The Plaza Office Tower 32nd FloorJl. M.H. Thamrin Kav 28 – 30Jakarta 10350Indonesia

Tel: +62 21 29923100 ext. 33886Fax: +62 21 29928303Email: [email protected] Website: www.deloitte.com/id



Turino Suyatman is a partner at PwC Indonesia with experienceas a tax consultant since 1993, providing tax advice to a varietyof multinational and domestic enterprises. He has in-depthknowledge of the full range of Indonesian tax issues includingcorporate income tax, VAT, withholding taxes, taxation of em -ployees and special tax regimes. He also has experience with cor-porate tax restructuring, tax planning with respect to loans andbond issuances, and the full process of tax controversy.

Turino has extensive litigation experience in litigating taxdisputes at the Tax Court. He represents several leading miningcompanies operating in Indonesia, including the two largest pri-vate mining companies, and other companies or permanentestab lish ments in various industries.

Indonesia

Turino Suyatman

PwC Indonesia

Plaza 89,Jl. HR Rasuna Said Kav. X-7 No. 6Jakarta 12940Indonesia

Tel: +62 21 52890375Fax: +62 21 5213946Email:[email protected]:www.pwc.com/taxcontroversy



Turmanto, Deloitte Indonesia, is a partner who has extensiveexperience in serving a broad range of multinational clients invarious industries including energy companies, pharmaceuticals,manufacturing and services companies. He has worked for morethan 24 years in the taxation and customs consulting world withseveral other Big 4 firms.

Turmanto is the national VAT and customs services leader ofDeloitte Indonesia. Aside from leading these tax services,Turmanto has performed substantial work on tax and customsadvisory, corporate tax compliance, tax due diligence reviews,tax diagnostic reviews, and various other tax and customs reviewto identify tax and customs exposures. Turmanto provides clientswith optimum solutions and alternatives as part of the review ofclients’ potential tax and customs exposure.

Turmanto has extensive experience in mergers and acquisi-tions projects in Indonesia, representing clients in various cor-porate income tax, VAT and customs dispute resolution casesbefore the Indonesian Tax Court.

Turmanto is a graduate in fiscal administration from theUniversity of Indonesia. His professional affiliations include theIndonesian Tax Court–licensed proxy, completed tax consulting exam–brevet C level,Deloitte international corporate tax school and workshop, and he is also a certified customsexpert.

Indonesia

Turmanto

Deloitte Indonesia

The Plaza Office Tower 32nd FloorJl. M.H. Thamrin Kav. 28-30Jakarta 10350Indonesia

Tel: +62 21 2312381 ext. 33891Fax: +62 21 3852776Email: [email protected]: www.deloitte.com/id



Indonesia

Ponti PartogiBaker & McKenzie

Ay-Tjhing PhanPwC

Abraham PierreKPMG

Eko PrajantoKPMG

Bambang SuprijantoEY

Dodi SuryadarmaEY

Ali WidodoPwC

Wimbanu WidyatmokoBaker & McKenzie

Ireland

Brian DuffyWilliam Fry

Joe DuffyMatheson

Michael FarrellKPMG

Greg LockhartMatheson

Martin PhelanWilliam Fry

Gavan RylePwC

David SmythEY



Aldo Castoldi, Deloitte Italy, is a partner and the leader of thetransfer pricing practice since 2008. He has almost 20 years oftransfer pricing and international tax experience, and he hasserved a wide range of foreign-owned multinationals, as well asItalian concerns.

Aldo has extensive experience of transfer pricing and interna-tional tax issues. Since the establishment of Deloitte’s Italianservice line in 1999, Aldo has been in charge for all major trans-fer pricing projects carried out by Deloitte in Italy. He hasworked for a large number of Italian, European, US, and Far-East multinationals in a wide range of industries, including theconsumer goods, luxury and technology – media – telecom(TMC) industries, gaining significant experience both in per-forming and coordinating comprehensive transfer pricing stud-ies, tax planning, documentation, litigation projects, advancepricing agreements (APAs), and Competent Authority proce-dures in general, as well as in providing consultancy in the con-text of business model optimisation (BMO) projects.

Aldo negotiated a number of unilateral and multilateralAPAs, including the first Italian unilateral and multilateral ones,respectively. Besides defending them during tax audits and litigations, he also assisted manyclients in the filing and negotiating of mutual agreement procedure (MAP) applications toavoid double taxation, including in the first settlement of an Italian transfer pricing assess-ment by means of the EU Arbitration Convention.

Having pioneered this advisory sector in Italy, Aldo has had the chance to develop excel-lent business relationships with many senior officers of the Italian Competent Authority,including the head of the ruling office.

Italy

Aldo Castoldi

Deloitte Italy

Studio Tributario e SocietarioVia Tortona 25,20144 MilanItaly

Tel: +39 02 83324111Fax: +39 02 83349181Email: [email protected]: www.deloitte.it



Matteo Costigliolo, Deloitte Italy, is a tax partner who previous-ly worked with Arthur Andersen and a tax consultancy firmbased in Milan and Genoa.

Matteo has over 20 years of experience in national and inter-national tax, group reorganisations, mergers and acquisitions,tax and corporate consultancy for multinational enterprises. Hespecialises in tax controversy and litigation, specifically assistingclients, usually large and medium-sized companies, in adminis-trative proceedings in front of the tax authorities and mattersheard by the tax courts. He also gives advice on all aspects relat-ed to tax audits, assessment and collection procedures and onadministrative and criminal penalties, as well as other adminis-trative procedures such as rulings or tax claims, for both Italianand foreign companies.

Matteo’s clients are many of the largest Italian and interna-tional companies operating in a wide range of industries includ-ing shipping, logistics, automotive, steel, leisure and entertain-ment, oil and gas, banking and insurance, environmental servic-es, construction, defence, aviation, pharmaceutical, chemical,information technologies, communications and telecommuni-cation, professional sports, large retailers and food and bever-age.

Matteo is member of the Statutory Auditors Board of Medium/Large Companies. He isa chartered accountant, statutory auditor and court consultant. He earned a degree in eco-nomics from Genoa University and served the Italian Navy as lieutenant.

Matteo regularly speaks about tax issues at domestic and international conferences andworkshops in Italy, also on the request of the Revenue Agency and other public bodies. Heregularly contributes articles concerning significant tax issues to specialised technical publica-tions.

Italy

Matteo Costigliolo

Deloitte Italy

Piazza della Vittoria 15/3416121 GenoaGalleria San Federico 5410121 TurinItaly

Tel: +39 010 5317811Email:[email protected]: www.deloitte.it



Eugenio della Valle, Deloitte Italy, is a tax partner, a tax law pro-fessor at Sapienza University of Rome, and a tax lawyer (Avvo -cato tributarista). Prior to joining Deloitte, Eugenio workedwith the Italian desk of one of the major international law firms.

Eugenio has over 25 years’ experience in national and inter-national tax, group reorganisations, mergers and acquisitions,tax and corporate consultancy for multinational enterprises. Hespecialises in tax controversy and litigation, specifically assistingclients, usually large and medium-sized companies, in adminis-trative proceedings in front of the tax authorities and mattersruled by the tax courts. He also gives advice on all aspects relat-ed to tax audits, including assessment and collection proceduresand on administrative and criminal penalties, as well as otheradministrative procedures such as rulings or tax claims, for bothItalian and foreign companies.

Eugenio’s clients are some of the largest Italian and interna-tional companies operating in a wide range of industries.

Eugenio is member of the Rome Bar, as well as member theItalian Tax Law Professors’ Association. He earned a degree inlaw from Sapienza University of Rome and served the Italian Tax Police as a lieutenant.

Eugenio regularly either speaks at (or organises) domestic and international tax confer-ences and workshops in Italy, also on the request of the Revenue Agency, Tax Police andother public bodies. He is a member and sole director of the editorial boards and scientificcommittees of the most important Italian tax journals. He has written more than 100 publi-cations, spanning from articles to books.

Eugenio speaks Italian and English.

Italy

Eugenio della Valle

Deloitte Italy

Via XX Settembre 100187 RomeItaly

Tel: +39 06 48990834 Email: [email protected]: www.deloitte.it



Stefano Fedele, Deloitte Italy, is a lawyer and tax partner withover 20 years’ experience in domestic and international taxa-tion. Stefano specialises in tax litigation and tax controversy,including representing clients in Italian tax, civil, criminal andadministrative courts proceedings. He assists clients with re -struc turing and business planning operations and tax audits, andadvises on administrative procedures of the Italian tax authori-ties, as well as all aspects of assessment procedures and adminis-trative and criminal penalties.

Stefano assists clients with matters from audit to litigation,including every step of the administrative process. His litigationexperience spans the full spectrum of issues, from VAT to cor-porate tax claims for both Italian and foreign companies. Withrespect to tax claims related to individuals, he advises clients rel-ative to all aspects of matters that are before the Tax Court of Idegree, the Tax Court of II degree and the Supreme Court.

Stefano serves many of the largest Italian and internationalcompanies, doing business across a wide range of industriesincluding pharmaceutical, chemical, information, communica-tion and telecommunications, logistics, automotive, hospitality, gas, banking and insurance,laundry and home care, large retailers and food.

Stefano has written articles for specialised Italian tax magazines and is engaged as a speakerat conferences.

He earned a Master of Tax Law degree from INFOR (Milan, 1995/1996) and was admit-ted to the Bar in 1998. Stefano is also qualified to represent clients in front of the ItalianSupreme Court.

Italy

Stefano Fedele

Deloitte Italy

Via Tortona 2520144 MilanItaly

Tel: +39 (0)2 83324111Email: [email protected]: www.deloitte.it



Valentino Guarini is partner at PwC’s tax controversy and dis-pute resolution network. He is based in the Milan office in Italy.

Valentino has achieved 21 years of experience inside the PwCnetwork dealing with tax controversies. He also developed hisexperience through a wider range of activities in M&A, corpo-rate restructurings, domestic and international tax advising.

Valentino and his team specialise in tax controversy and dis-pute resolution, handling assistance in the course of tax audits,as well as pre-litigation phases (settlements and rulings) and lit-igations before the tax courts.

He is an attorney-at-law before the tax courts and serves awide range of clients (MNEs) in dealing with tax controversies,as well as providing tax advice on both domestic and interna-tional tax matters. He serves and advises clients in a variety ofsectors with particular focus on consumer and industrial prod-ucts, fashion and luxury, and pharmaceutical sectors.

Valentino is member of the International Taxation Commis -sion of the Chartered Tax Consultants Council of Milan. Hegraduated both in economics and in law.

Italy

Valentino Guarini

PwC

Via Monte Rosa, 91 20149 MilanoItaly

Tel: +39 02 91605807Email:[email protected]:www.pwc.com/taxcontroversy



Marco Lio is an associate partner in PwC’s tax and legal practicein Italy, focusing on tax and transfer pricing advisory, disputeresolution and tax policy areas.

Before joining PwC in 2015, Maco served with the Italiantax authority where he achieved 13 years of experience. Hebecame the chief officer in charge of the large business taxpayersunits in Rome and, subsequently in Milan.

In his role as chief officer of the large business taxpayers unit,he was in charge of the organisation working on risk analysisand detection procedures, as well as focused on tax audits andconsequent tax settlement procedures.

During his service with the Italian tax authority, Marco alsoadvised the Italian Central Directorate of Assessment of theItalian Tax Authority, on drafting official guidelines, tax regula-tions and tax rulings.

Relying on his previous work experience and on the skills hedeveloped during his service with the Italian Tax Authority,Marco supports the activities of PwC in the area of tax contro-versy and dispute resolution, with particular reference to cross-border and domestic direct taxation.

Marco is actively engaged in the implementation of the projects related to the CooperativeCompliance Regime, adopted by Italy in 2015, and the outcomes of the BEPS project.

Italy

Marco Lio

PwC


Tel: +39 02 91605005Email: [email protected]:www.pwc.com/taxcontroversy



Carlo Romano is a partner of PwC tax and legal services and heis the tax controversy and dispute resolution leader in Italy.

He is a tax lawyer with 20 years of experience. He is qualifiedto appear before the Supreme Court and has a PhD in interna-tional and comparative tax law (cum laude) from the Universityof Groningen, Netherlands. His areas of specialisation includedomestic, European and international business taxation andtransfer pricing.

Carlo has been involved in several leading national and inter-national cases and has a broad experience in dealing with tax litigations – also before the Italian Supreme Court and theEuro pean Court of Justice – and with pre-litigation settlements.He has gained a broad experience in APA negotiations and rul-ing practices.

He writes for various Italian and international tax journalsand he is the author of various publications in international taxlaw. His book ‘Advance Tax Rulings and Principles of Law’(IBFD, 2002) is a milestone in the academic studies about rul-ings and APAs.

He has been a professor of tax law in various Italian univer-sities, at the SSEF Scuola Superiore dell’Economia e delle Finanze(now SNA – Scuola Nazionale dell’Amministrazione) and visiting researcher at New YorkUniversity. He regularly teaches in several courses for the officials of the Ministry of Financeand of the Revenue Agency as well as at LUISS and Bocconi Universities.

Italy

Carlo Romano

PwC Tax and Legal Services

Largo Angelo Fochetti 2900154 RomeItaly

Tel: +39 06 57127202Mobile: +39 335 6075317Email: [email protected]:www.pwc.com/taxcontroversy



Dario Sencar is an associate partner in PwC’s tax and legal prac-tice in Italy, focusing on tax and transfer pricing advisory, dis-pute resolution and tax policy areas.

Dario joined PwC in 2015, after having served for 16 yearswith the Italian tax authority, where he became the chief officerin charge of the special tax audits unit, focusing on transfer pric-ing, attribution of profits to permanent establishments, (withspecific focus on banking branches), mergers and acquisitions,tax avoidance, beneficial ownership, detection of aggressive taxplanning transactions (both domestic and cross-border), such aspost tax hedging, foreign tax credit generators, dividend wash-ing through stock exchanges and other forms of structuredfinance.

As part of his service with the Italian tax authority, he alsoprovided, on regular basis, advisory and support to the largetaxpayers unit offices throughout Italy. He worked, on regularbasis, with the Central Directorate of the Italian tax authoritywith respect to tax regulations and tax rulings. The main areasof his activities were: IAS/IFRS; exit taxation; the financialtransaction tax (FTT), reform of the Italian cross-border taxlegislation; general anti-avoidance rule (GAAR); and the allowance for corporate equity.

Relying on his previous work experience and on the skills he developed during his servicewith the Italian tax authority, Dario supports the activities of PwC in the area of tax contro-versy and dispute resolution, with particular reference to cross-border and domestic directtaxation.

Dario is actively engaged in the implementation of projects related to the CooperativeCompliance Regime, adopted by Italy in 2015, and the outcomes of the BEPS project.

Dario has represented the Italian tax authority at the OECD as part of the ATP steeringgroup (from 2010 to 2015) and the BEPS project (namely: Action 1 on the digital economy;Action 2 on hybrid mismatches; Action 3 on CFCs and Action 4 on interest expenses deduc-tion).

Italy

Dario Sencar

PwC


Tel: +39 91605038Email: [email protected]:www.pwc.com/taxcontroversy



Giancarlo Zoppini is a practicing lawyer and partner at StudioTremonti Romagnoli Piccardi e Associati. Based in the Milanoffice of the firm, he specialises in tax litigation. His areas ofexpertise include settlements, advance ruling proceedings, legaldefence in fiscal cases, providing assistance in tax audits, pre-lit-igation, litigation, and taxpayer representation in cases beforethe Italian Revenue Agency. He also acts as counsel in criminaltax cases.

Since joining Studio Tremonti Romagnoli Piccardi e As -sociati in 1993 (then called ‘Studio Tremonti e Associati’),Gian carlo has been engaged in professional practice with thefirm and became a partner on January 1 2000.

Giancarlo received his degree in law (summa cum laude)from the University of Bologna in 1991. He passed the stateexam at the first session (1993-1994) for the Court of Appealsin Milan and was admitted to the Milan Bar in 1995. A yearlater in 1996, he was admitted to the Accountant Auditors As -soc iation. Since 2007, he has regularly defended cases beforethe Supreme Court.

In 1988, Giancarlo graduated from a four-year degree coursefor officers in full permanent service at the Italian Tax PoliceAcademy in Bergamo. From 1988 to 1991 he served as an offi-cer in full permanent service with the Italian Tax Police engagedin tax and criminal matters. From 1991 to 1993, he was engaged in professional practice withanother leading Italian firm, Falsitta e Associati.

From 1991 to date, he has published numerous articles and tax law essays in Italian schol-arly reviews.

Italy

Giancarlo Zoppini

Studio Tremonti RomagnoliPiccardi e Associati

Via Crocefisso, 1220122 MilanItaly

Tel: +39 02 58313707Fax: +39 02 58313714Email: [email protected]: www.virtax.it



Italy

Maria Antonietta BiscozziEY

Gianluca BoccalatteStudio Biscozzi Nobili

Alessandro CaridiPwC

Aurelia CasaliDLA Piper

Marco CerratoMaisto e Associati

Paolo ComuzziPwC

Roberto Cordeiro GuerraCordeiro Guerra & Associati

Nicola CrispinoBaker & McKenzie

Marco Di SienaChiomenti Studio Legale

Barbara FainiBaker & McKenzie

Bruno GangemiMacchi di Cellere Gangemi

Guglielmo MaistoMaisto e Associati

Alessandro MartinelliDLA Piper

Renato PaternolloFreshfields Bruckhaus Deringer

Pietro Piccone FerrarottiLudovici Piccone & Partners

Giuliana PolaccoBaker & McKenzie

Andrea SilvestriBonelli Erede

Antonio TomassiniDLA Piper

Giuseppe ZizzoZizzo e Associati



Yang Ho Kim, Deloitte Japan, is a Japanese licensed tax ac -count ant and US CPA who is Deloitte's financial services taxgroup leader in the country. He has over 25 years of experiencein public accounting, serving many Japan-based and US-basedmultinational enterprises. He supports various clients in all typesof national and international disputes and negotiates settle-ments with the tax authorities.

He has extensive practical experience in the taxation of vari-ous aspects of financial and international transactions and taxaccounting issues. His specialties include international tax plan-ning, structured finance, and inbound and outbound M&A.

He has also assisted many foreign-based private equity fundsand sovereign wealth funds with advising on the various aspectsof tax-efficient structuring alternatives.

From January 1997 to March 2001, he was assigned to thebanking and securities group and Japanese services group in theDeloitte New York Office.

Further, Yang Ho is a frequent speaker at conferences andseminars on various structure finance related matters and is theauthor of numerous articles and publications in the field ofinternational taxation such as entity classification, foreign taxcredit and CFC regimes.

He is a graduate of Keio University, Tokyo, where he earned a BA in economics. He alsoearned a Master of Science in Taxation at Fordham University, New York.

He is a member of the American Institute of Certified Public Accountants and JapanFederation of Licensed Tax Accountant’s Association.

Japan

Yang Ho Kim

Deloitte Japan

Shin Tokyo Building3-3-1 Marunouchi, Chiyoda-kuTokyo 100-8305Japan

Tel: +81 3 6213 3841Fax: +81 3 6213 3808Email:[email protected]: www.deloitte.com



Masahiko Kobayashi, Deloitte Japan, is a certified tax account-ant and has been a partner of the transfer pricing consultinggroup since July 2008. He also has been a leader of DeloitteJapan’s tax dispute resolution group.

Before joining Deloitte in 2006, he spent 26 years as a taxofficial in various departments of Japan’s National Tax Agency(NTA), including the Tokyo Regional Taxation Bureau(TRTB), the National Tax College and local tax offices, as wellas three years at the Ministry of Finance. In particular, he spentmore than five years as a deputy director in the NTA’s Office ofMutual Agreement Procedures (OMAP).

Through these roles, Masahiko gained significant experiencein international tax, transfer pricing and APA’s. While in theOMAP, he dealt with a wide variety of cases between Japan andvarious foreign competent authorities. These included majorEuropean countries and some Asian developing countries. Mostof the double taxation cases he participated in managed to reachagreement among the parties involved. Since joining Deloitte,he has dealt extensively with transfer pricing disputes, includinga case where a substantial amount of money was recovered for aforeign financial company through a tribunal procedure.

Other notable cases include: transfer pricing taxation andAPA cases within the pharmaceutical industry; transfer pricing taxation and APA cases onglobal trading of financial derivative products; and PE taxation cases of foreign companiesdoing business in Japan, and those of Japanese companies doing business in foreign develop-ing countries.

Masahiko is the co-author of ‘All About Tax Audit in Japan’ (Seibunsha 2013) and ‘Trans -fer Pricing and Tax Management’ (Seibunsha 2011). He is a member of the Japan Associationof Tax Litigators and the Japan Tax Accounting Association.

Japan

Masahiko Kobayashi

Deloitte Japan

Shin Tokyo Building3-3-1 MarunouchiChiyoda-ku TokyoTokyo, 1008305Japan

Tel: +81 3 6213 3938Fax: +81 50 3116 0190Email: masahiko.kobayashi@

tohmatsu.co.jpWebsite: www.deloitte.com



Daisuke Miyajima is a partner in the international tax services(transfer pricing) group of PwC Tax Japan. During his career ofmore than 25 years at the firm, he spent several years on assign-ment with the transfer pricing group in the Washington DC andNew York offices. In the transfer pricing area, Daisuke has pro-vided advice towards numerous Japanese and foreign clients ontheir inter-company transactions with related parties and itseffect on Japanese and foreign transfer pricing rules. He has alsoassisted in preparing studies for presentation to the appropriatetax authorities and has successfully defended several well-knownJapanese and foreign companies in transfer pricing audits.

He is also an expert in the area of Competent Authoritynegotiations and advance pricing agreements. While his experi-ence includes clients in virtually every industry, he particularlyspecialises in the high-tech, automotive, entertainment, andluxury goods industries.

Daisuke has also written extensively on the above areas invarious publications and is a frequent speaker at seminars heldby PwC and outside organisations. He has been chosen as oneof the world’s leading transfer pricing consultants in variouspublications. He also writes and is fluent in both Japanese andEnglish.

Daisuke is also an associated member of the American Institute of Certified PublicAccountants.

Japan

Daisuke Miyajima

PwC Tax Japan

Kasumigaseki Bldg 15F2-5 Kasumigaseki 3-chomeChiyoda-ku, Tokyo 100-6015Japan




Akio Miyamoto is a partner in the international tax services(transfer pricing) group of PwC Tax Japan. He is a leadingtransfer pricing specialist in Japan with more than 20 years’experience in the field, beginning in 1991, which was aroundthe time Japan commenced transfer pricing examinations, afterthe introduction of transfer pricing legislation in 1986. GivenJapan’s robust transfer pricing audit environment, and the wideuse of advance pricing agreements (APAs) in Japan, he has beenextensively involved in transfer pricing audit defence cases,Competent Authority negotiations, APA negotiations, transferpricing documentation projects and transfer pricing risk assess-ment reviews. As one of the first transfer pricing professionals inJapan, Akio has an in-depth knowledge of Japanese transferpricing practice and procedures.

He has assisted foreign and Japanese multinational clients innumerous industries, with particular emphasis in the medicaldevice, pharmaceutical and luxury goods industries, which hehas been involved with since the time the Japanese tax authoritybegan to focus on these industries. He also has significant expe-rience in the consumer goods and technology industries. He hasdealt with a wide variety of transfer pricing and transfer pricingrelated issues, including business restructurings, profit attribution to permanent establish-ments, treaty application to transfer pricing disputes and commissionaire structures. He hasalso participated as a speaker at various transfer pricing conferences throughout the world.

Akio joined the Tokyo office of PwC in 1979 and spent four years working in PwC’sToronto office. His career began in audit, and he was heavily involved with both Japaneseand non-Japanese multinationals. He moved to transfer pricing in 1991, and has been leadingthe Japan firm’s transfer pricing practice since then. Miyamoto has been a partner since 1995.

Miyamoto is a licenced Japanese certified public accountant (CPA) and a licencedJapanese certified public tax consultant. He holds a bachelors degree in commerce fromWaseda University.

Japan

Akio Miyamoto

PwC

Kasumigaseki Bldg 15F2-5 Kasumigaseki 3-chomeChiyoda-ku, Tokyo 100-6015Japan




Jun Sawada, Deloitte Japan, is a partner working in the transferpricing group. After starting his career with Arthur Andersen in1999, Jun has advised both foreign and Japanese multinationalson various transfer pricing and cross-border taxation issues.Before joining Deloitte Japan in October 2013, Jun workedwith EY and White & Case.

Jun has represented clients in various discussions with theJapanese tax authorities. He has defended companies underaudit, assisted companies in their negotiations with tax authori-ties to obtain advanced approval of their transfer pricing(through unilateral/bilateral APAs), and supported companiesin domestic tax appeals. In particular, he has assisted clients inindustries such as pharmaceuticals, medical devices, software,luxury goods and apparel, consumer products, high-tech,chemical, automotive, entertainment, and trading houses. Junhas also supported clients with their needs for assistance in com-pliance (transfer pricing documentation), establishing transferpricing policies, and determining tax effective supply chains.

Having lived overseas for more than 12 years during hisyouth, Jun is bilingual in English and Japanese. Jun has con-tributed articles in Tax Analysts, International Tax Review, andseveral major Japanese tax magazines, and has also co-authoredseveral books in Japanese regarding transfer pricing.

Japan

Jun Sawada

Deloitte Japan

Shin Tokyo Building3-3-1 MarunouchiChiyoda-ku TokyoTokyo, 1008305Japan




Gary M Thomas, Deloitte Japan, is a senior adviser on transferpricing services. He is registered as a Japanese licensed tax attor-ney. He has worked in Japan for over 35 years and is fluent inspoken and written Japanese.

Gary advises US, European, Japanese and other companiesin connection with tax planning and defence and resolution oftax controversies in audits, domestic appeals, and governmentalbilateral consultations under tax treaties. He is well known as anauthority in transfer pricing planning and documentation,audits, Competent Authority procedures and advance pricingagree ments (APAs) involving Japan. He also has handled casesinvolving permanent establishment issues for foreign firms.

Gary was the chair of the taxation committee of the Ameri -can Chamber of Commerce in Japan (ACCJ) from 2000 to2002. He was deeply involved in the effort to encourage the USand Japan to negotiate a new US/Japan income tax treaty,which was finally ratified in March 2004. He has written andlectured extensively (in both Japanese and English) on transferpricing, international tax planning, and dispute resolution.

Gary obtained a bachelors degree in political science andJapanese language from the University of Washington (1973) and a Juris Doctor degree fromHarvard Law School (1977). He also has a master’s degree in Japanese law (taxation) (1989)and a master’s degree in business administration (accounting) (1994) from Asia University,Tokyo, Japan.

Japan

Gary Thomas

Deloitte Japan

Shin-Tokyo Bldg, 5F3-3-1 Marunouchi, Chiyoda-kuTokyo 100-8305Japan

Tel: +8 3 6213 1139Email:[email protected]: www.deloitte.com



Japan

Brajeshwar BanerjeeKPMG

Atsushi FujiedaNagashima, Ohno & Tsunematsu

Yushi HegawaNagashima Ohno & Tsunematsu

Akihiro HironakaNishimura & Asahi

Yuichi KomakineKPMG

Takayuki KozuKPMG

Toshio MiyatakeAdachi, Henderson, Miyatake & Fujita

Hisashi MiyatsukaNishimura & Asahi

Yuko MiyazakiNagashima Ohno & Tsunematsu

Toyoharu NakamuraPwC

Yo OtaNishimura & Asahi

Koichi SekiyaEY

Edwin WhatleyBaker & McKenzie

Hideyuki YamamotoBaker & McKenzie



Laurent Engel leads the tax policy, dispute resolution and litiga-tion practice within KPMG in Luxembourg.

He has built up an experience in advising a number of theTop 20 Luxembourg banks over the past 15 years, becomingthe best-equipped individual to identify tax risks and to providestrategic advice on tax risk management, including ex-antenegotiation of advance tax agreements.

Laurent believes in long term relationships. With an excep-tion of two years, where he worked as a member of the Lux em -bourg Bar in litigation, he has spent his entire career at KPMG.To Laurent, “great service is about clients receiving the bestquality work, on time and on budget from our firm. It’s aboutlistening. About resolving problems early”. This is an assetwhen providing services in relation to tax audits and ex-postnegotiation of settlements with administrative authorities.

Laurent is at his best when spending time with interdiscipli-nary teams. Tax controversy is based on domestic legislation,EU Law, and more recently, BEPS considerations. Involvingsubject matter experts in each of these areas is how Laurentmanages to inspire his clients when helping them develop a lit-igation strategy, handle court proceedings and the managementof tax controversies generally.

Laurent is fluent in English, French and German.

Luxembourg

Laurent Engel

KPMG Luxembourg, Sociétécoopérative

39, Avenue John F. KennedyL-1855 Luxembourg

Tel: +352 22 51 51 5535Mobile: +352 621 87 5535Fax: +352 22 51 71Email: [email protected]: www.kpmg.lu



Luxembourg

Eric FortArendt & Medernach

John HamesEY

Fabienne MoquetPwC

Philippe NeefsKPMG



Kuo Seng Chow, Deloitte Malaysia, is the business tax audit andinvestigation (A&I) leader. Based in Kuala Lumpur, he hasmore than 30 years’ experience in tax audits and back dutyinvestigations. Kuo Seng’s experience in A&I controversy man-agement includes providing tax advisory and consultancy serv-ices, and managing compliance work for local and multinationalenterprises, as well as high-net worth individual clients and pru-dential audit reviews for tax risk management purposes.

His years of experience in client services and his profoundengagement with the clients and the tax authorities have yieldedexceptional resolutions, resulting in positive settlements beingnegotiated, facilitation and amicable resolutions of disputesthrough the dispute resolution proceeding at local tax head-quarters. Kuo Seng’s approach has earned the tax authorities’acknowledgement of his uncompromising and yet mutuallybenefitting methodology, which respects the tax authorities’position and at the same time protects the taxpayer’s rights andresponsibilities both under law and in adherence with local prac-tices and policies.

Kuo Seng is also a tax appeal specialist and a much sought-after speaker at public forums on current tax issues organised by the tax authorities and pro-fessional firms. He is a chartered accountant of the Malaysian Institute of Accountants andan approved tax agent under the Malaysian Income Tax Act, 1967.

Malaysia

Kuo Seng Chow

Deloitte Malaysia

Level 16, Menara LGB, 1 JalanWan KadirTaman Tun Dr. Ismail60000 Kuala LumpurMalaysia

Tel: +60 3 7610 8836Email: [email protected] Website: www.deloitte.com



Theresa Goh, Deloitte Malaysia, is the national transfer pricingleader based in Kuala Lumpur. She has more than 25 years ofexperience, encompassing several facets of tax and transfer pric-ing matters. Her experience covers tax audits, investigations andtax planning/advisory work for clients in a wide range of indus-tries, including manufacturing, services, and the oil and gas sec-tors. She has extensive experience in successfully completingmany tax planning and consulting assignments in areas such asrestructuring, and mergers and acquisitions.

Theresa is widely experienced in tax and transfer pricing con-troversy management, which encompasses a broad gamut ofspheres, including preparation of strategy for litigations involv-ing anti-avoidance issues and application of alternative transferpricing methodologies during audits. She also assisted clients inconcluding the first three and the only advance pricing agree-ments (APAs) signed in Malaysia to date.

Under Theresa’s leadership, Deloitte Malaysia was success-fully recognised as ‘Malaysia Transfer Pricing Firm of the Year’at the 2016 International Tax Review Asia Tax Awards, and as‘Transfer Pricing Law Firm of the Year – Malaysia’ by theLawyer Legal Awards 2015. In addition, her achievements include being voted as Malaysia’stax controversy leader by International Tax Review in 2013/2014 and 2015, being recog-nised as one of the world’s leading transfer pricing advisers by Euromoney consistently from2009–2015, and being voted as a leading female practitioner in international tax and transferpricing in Euromoney’s Women in Business Law Expert Guide 2012. She has also been votedas a leading tax adviser by International Tax Review in 2008/2009.

Theresa is a council member of both the Malaysian Institute of Certified PublicAccountants (MICPA) and the Chartered Tax Institute of Malaysia (CTIM). She is the chair-person of MICPA’s membership affairs committee. She also chairs CTIM’s transfer pricingtechnical committee and regularly participates in operational dialogues with the InlandRevenue Board of Malaysia.

Theresa is a certified public accountant (CPA) in Malaysia and a chartered accountant ofthe Malaysian Institute of Accountants (MIA). She is an approved tax agent under theMalaysian Income Tax Act 1967. She is a sought after speaker for national and internationaltax conferences, focusing on emerging transfer pricing and tax issues.

Malaysia

Theresa Goh

Deloitte Malaysia

Level 16, Menara LGB1 Jalan Wan KadirTaman Tun Dr. Ismail60000 Kuala LumpurMalaysia




Chandran Ramasamy, Deloitte Malaysia, is a tax director in thegoods and services tax (GST), customs and global trade divi-sion, specialising in tax controversy dispute resolution cases.Chandran has more than 20 years of experience in Malaysianindirect tax dispute resolution, as well as advisory, planning andanalysis. Prior to joining Deloitte, he was with another Big 4firm for 18 years.

Chandran’s experience in tax controversy dispute resolutionincludes obtaining GST and customs rulings from customs,seeking administrative reviews of GST decisions made by cus-toms, dealing with customs during audits, acting as counsel onbehalf of clients in appeals to the Customs Appeal Tribunal andGST Appeal Tribunal, being sought as a client’s expert witnessin the Customs Appeal Tribunal, and even representing clientswhen dealing with customs to settle negotiations at the outsetof Tribunal proceedings.

Chandran has been admitted to the Malaysian Bar and holdsa Bachelor of Laws degree from the University of London anda certificate in legal practice issued by the Legal ProfessionalQualifying Board, Malaysia.

Malaysia

Chandran Ramasamy

Deloitte Malaysia

Menara LGB, 1 Jalan Wan KadirTaman Tun Dr. Ismail60000 Kuala LumpurMalaysia

Tel: +60 3 7610 8873Fax: +60 3 7725 7768 /

+60 3 7725 7769 Email:[email protected]: www.deloitte.com



Jagdev Singh is a senior executive director in PwC’s globaltransfer pricing network based in Kuala Lumpur. He is the taxleader for PwC Malaysia.

Jagdev has extensive experience in handling a vast variety oftransfer pricing and corporate tax assignments including twoyears on assignment in London. He specialises in assistingmulti national enterprises and local conglomerates with corpo-rate international tax planning, transfer pricing, tax audits andinvestigations.

Jagdev’s experience spans across various industries and sec-tors including semiconductor, consumer products, constructionand services, chemicals, oil and gas – both upstream and down-stream services – automotive, logistics, pharmaceuticals andfinancial services. He currently assists multinationals and Malay -sian listed groups in restructuring exercises, post-merger inte-gration, and standardisation of global transfer pricing policies.He is also widely experienced in tax planning, preparation ofcore transfer pricing documentation, reviewing cost sharingmodels, developing pricing policies and representations beforethe local tax authorities with respect to tax audits, tax investiga-tions, transfer pricing audits, mutual agreement procedures andadvance pricing arrangements.

Jagdev led PwC Malaysia to win International Tax Review’s‘Malay sia Tax Firm of the Year’ award for 2016. Under his leadership, PwC Malaysia was alsonominated for the ‘Malaysia Tax Disputes and Litigation Firm of the Year’ and ‘MalaysiaTransfer Pricing Firm of the Year’ awards in the same year.

Jagdev is a frequent presenter at local and foreign seminars and conferences and hasauthored several technical articles. He has worked closely with a range of regulatory author-ities to contribute towards the development of government policies and legislation. Morerecently, Jagdev has dealt extensively with tax incentives, and has been working with variousgovernment agencies in attracting foreign investors and helping them structure their invest-ments.

Jagdev has a bachelors degree in business and is a member of the Malaysian Institute ofTaxation and CPA Australia.

Malaysia

Jagdev Singh

PwC Malaysia

PricewaterhouseCoopers TaxationServices Sdn BhdLevel 10, 1 Sentral, Jalan RakyatKuala Lumpur Sentral, P O Box10192, 50706 Kuala LumpurMalaysia




Malaysia

Nicholas CristKPMG

Dato’ William Stanley Walker DavidsonAzman Davidson

Goh Ka ImShearn Delamore & Co

Vijey M KrishnanRaja, Darryl & Loh

Azhar LeePlatinum Tax Consultants

Kah Fan LimEY

Sue Lynn NgKPMG

Anand RajShearn Delamore & Co

Nik Saghir Mohamed NoorNik Saghir & Ismail

Lian Seng SohKPMG

Francis TanAzman Davidson

Adeline WongBaker & McKenzie

Simon YeohEY

Irene YongShearn Delamore & Co



Karina Pérez is part of the transfer pricing and tax controversyand dispute resolution team in Mexico. Karina has experience insuccessfully solving complex international tax controversies indifferent industries such as the financial services, consumerproducts, pharmaceuticals, automotive, telecommunications,and oil and gas sectors. She is a partner that has practised in thearea of international taxation for more than 25 years and hasrecognised experience in Competent Authority processes, man-aging audits and settling disputes. She maintains close contactwith competent authorities around the world.

Before joining PwC she worked at the Central Bank, and atthe Ministry of Finance and the Tax Administration Service for17 years in different relevant positions. Under these responsibil-ities she negotiated 44 of the Mexican tax treaties, including thetreaties and protocols with the US, Germany, UK, Netherlands,Switzerland, Spain, Canada, Ireland, Singapore, Brazil, India,and Chile. She also negotiated exchange of information agree-ments with the US and Canada. Karina worked on proposed taxlegislation and regulations regarding international transactions,issued international private rulings and was the CompetentAuthority for mutual agreement procedures with different juris-dictions. She was responsible for the registry of foreign financial institutions, including pen-sion and investment funds and was in charge of administrating reporting obligations regard-ing the placement of securities abroad. As part of her responsibilities as the legal counsel ofthe large taxpayers unit she issued internal guidelines applicable to central and field officersfor the legal, audit and collection offices. As a tax official she was the delegate for Mexico atthe OECD in different working groups (including the committee on fiscal affairs, workinggroup 1, treaties and related issues).

Karina has been, for several years, a member of the IFA Mexican branch and participatesactively at the case law committee of this association where advisers, tax officials and taxjudges discuss international controversies on a regular basis.

She has participated in different publications where she provides her expertise based onher recognised knowledge of Mexico’s tax treaties.

She graduated as a lawyer from the Escuela Libre de Derecho.

Mexico

Karina Pérez Delgadillo

PwC

Mariano Escobedo No. 573Col. Rincón del BosqueCP 11680, Mexico DFMexico

Tel: +52 (55) 52 63 57 34Email: [email protected]:www.pwc.com/taxcontroversy



Ricardo González Orta, Deloitte Mexico, is a partner and leaderof the Deloitte Mexico tax and legal practice. He is also thebusiness tax leader for Deloitte member firms in Latin America.Ricardo is based in the Mexico City office where he advisesmultinational enterprises on tax-related matters, including: con-troversy issues with tax authorities on domestic and internation-al matters, structuring new businesses, acquisitions, reorganisa-tions, joint ventures, double taxation issues and transfer pricing.Ricardo is the former leader of the Deloitte Mexico business taxpractice and, from 2001 to 2010, served as the Latin Americantransfer pricing leader for Deloitte member firms in the region,as well as being the Deloitte Mexico transfer pricing leader.

Before joining Deloitte, Ricardo spent eight years in a num-ber of top executive posts with the Ministry of Finance and theMexican Tax Administration Service.

From July 1999 to November 2000, Ricardo was generaldirector of tax and customs policy at the Under Ministry ofIncome, where his duties included designing tax and customspolicy. In this position, he negotiated the Mexico-US intergov-ernmental transfer-pricing agreement in the maquiladora indus-try. Before this, he acted as general director of legislation andinternational negotiations (1998 to 1999), where his main functions included: drafting taxand customs legislation, negotiating double-taxation treaties, and representing the Mexicangovernment in international forums (especially OECD).

From March to June 1998, he was general director of international tax affairs at the TaxAdministration Service (formerly Under Ministry of Income of the Ministry of Finance andPublic Credit). Primary responsibilities included: transfer-pricing audits, the negotiations ofadvance pricing agreements (APAs), the issuance of private letter rulings regarding foreign res-idents with Mexican source income, the exchange of tax and cus toms information with othercountries and the performance of audits and issuance of rulings in line with Mexico’s free tradeagreements. Before this, he was assistant general director for international audits (1993 to1998). In this position, Ricardo created the international audit programme, which included:transfer pricing inspections, negotiating APAs, drafting the 1997 tax reform on transfer pric-ing, the inspection of international transactions, audits of origin pursuant to Mexico’s com-mercial agreements, acting as Competent Authority for the exchange of tax and customs infor-mation, and inspection of Mexican residents with investments in low-tax jurisdictions.

Ricardo graduated from Universidad Iberoamericana. Ricardo is a frequent speaker in different national and international forums. He writes

periodically for the International Management Tax Journal on domestic and internationaltopics. For almost a decade he has been named by Euromoney as a leading transfer pricingand tax adviser.

Mexico

Ricardo González Orta

Deloitte Mexico

Paseo de la Reforma 505 Col Cuauhtémoc06500 México, DFMexico

Tel: +52 55 50 80 70 23Fax: +52 55 50 80 60 01Email:[email protected]: www.deloitte.com/mx



Jorge Jiménez Cañizares, Deloitte Mexico, has been a lawyerand tax adviser of the financial sector since 1989. In the courseof his professional career he has specialised in consulting in gen-eral corporate taxation, VAT (national and international opera-tions), international taxation, double taxation treaty application,and customs law. He leads the firm’s practice dedicated to thetax consulting and defence services for financial and insuranceinstitutions, as well as regulatory aspects of the same. Additionalpractice areas include assistance regarding audits by tax author-ities, general tax litigation and amparo litigation. He is aDeloitte Mexico partner of the tax and legal practice and wasnamed insurance sector leader of the financial services industry.

Jorge is an active member of the Mexican Bar Associationand the Academy of Tax Studies of the Public Accounting Pro -fession. Chambers & Partners legal publishers included Jorge inthe list of Chambers Latin America’s leading lawyers for busi-ness, as a lawyer with a superb reputation for tax work withinsurance companies and financial institutions.

Mexico

Jorge Jimenez

Deloitte Mexico

Paseo de la Reforma 505Floor 23Mexico

Tel: +52 (55) 5080 6600Fax: +52 (55) 5080 6001Email:[email protected]: www.deloitte.com



Carl E Koller Lucio, Deloitte Mexico, joined in February 2014as a partner in the international tax area of the firm’s tax prac-tice, after 14 years’ practice as a partner in a leading Mexico Cityboutique tax law firm. He has accumulated close to 20 years ofpractice in the tax field and 26 years of overall legal practice.

Although Carl’s practice was previously focused on tax con-troversy and tax litigation, he now balances a combination ofcorporate and international tax consulting and planning with aselection of controversy and litigation cases. It draws on hisknowledge in tax and civil, commercial and corporate law toprovide, as circumstances may dictate, detail-driven, high-qual-ity risk mitigation advice, or for the design and implementationof required defensive strategies. A further and principal day-to-day commitment of his tax practice, particularly for Europeanand North American inbound investment, is to generate a clearunderstanding of the relevant legal-tax issues and potential sce-narios and solutions affecting clients. In tax controversy and lit-igation, Carl’s necessary un-delegable and personal involvementin each case is a key commitment, particularly in a more recent,highly adversarial controversy environment.

Carl has been lead litigation partner in cases deriving in the relevant jurisdictional prece-dent, including initial and favourable Supreme Court sentences. In addition, through theMexican Bar Association, he has participated in a number of successful lobbying efforts tocounter government initiatives at the constitutional and legal levels that would have signifi-cantly curtailed taxpayers’ rights. Carl is also knowledgeable in aspects of international law,having participated as counsel to arbiters in two NAFTA investment protection arbitrations,in which the main issues centred on a taxation background. He has participated with localcounsel in tax controversy matters in certain Latin American countries.

Carl received his law degree from ITAM in 1994 (cum laude) and his Master of Laws fromDuke University School of Law in 1995 (his master thesis was published in the subject matterrelevant journal, Duke Environmental Law and Policy Forum). He passed the New York StateBar exam in 1995. More recently, in 2011-2012, Carl took a sabbatical and obtained a full-time MBA degree (cum laude) from the leading Mannheim Business School in Germany, forwhich he was one of two recipients of the Wilhelm Müller Stiftung (Foundation) Award inAugust 2013.

Regarding professional associations, he is an active member of the Mexican Bar, Attorney’sCollege and the Tax Studies Academy for Public Accounting (sponsored by the MexicanInstitute of Public Accounting), and periodically publishes and lectures on relevant tax issues.

He has received peer and client acknowledgment in specialised international publicationsas a leading tax attorney in Mexico since 2008.

He is a native English and Spanish speaker.

Mexico

Carl E Koller Lucio

Deloitte Mexico

Paseo de la Reforma 505CuauhtémocC.P. 06500 Ciudad de MéxicoMexico

Tel: +52 (55) 5080-6660Email: [email protected]: www.deloitte.com



Jorge Libreros is the leading partner of the tax controversy prac-tice at EY Mexico.

Jorge is a law graduate from Escuela Libre de Derecho inMexico City and has more than 20 years’ experience in contro-versy and international taxation matters. He has been professorof several tax courses at Escuela Libre de Derecho. He is ofteninvited to speak at local and international tax forums.

Before joining EY, Jorge worked for more than 10 years atthe Mexico Tax Administration Service where he held variousoffices, including the international tax legal affairs departmentand the international audits department. He was Mexico’s del-egate for several OECD working groups and the Inter AmericanCenter of Tax Administrations.

Jorge’s experience at the Tax Administration Service com-promised of local legislation and tax treaty interpretation, ex -change of information in tax matters, customs, rulings, freetrade agreements, origin verification, legal proceedings, andinternational transactions.

Jorge specialises in tax law and international taxation focus-ing on controversy matters. He is also highly qualified in nation-al and international consulting, income tax, VAT, foreign trade,import duties, origin verification and the North American FreeTrade Agreement (NAFTA).

Mexico

Jorge Libreros

EY Mexico

Av. Ejército Nacional 843-BTorre A, Piso 5Del. Miguel Hidalgo, 11520Mexico CityMexico

Tel: +52 55 5283 1439Email: [email protected]: www.ey.com



Gonzalo Mani, Deloitte Mexico, is a partner and the nationalleader for tax litigation. He has been with Deloitte for 15 years.His principal area of expertise is tax litigation. He has 20 yearsof experience in trial law related to complex tax matters. He hashelped clients challenge tax laws which have set national judicialprecedents.

Gonzalo has been a professor at Iberoamericana University,La Salle, and Anahuac del Sur. He has also taught degree pro -gram mes at the Bank and Commercial School in Mexico Cityand in the Public Accountants School of the Public AccountantsInstitute in Nuevo León, Mexico.

Gonzalo has written several essays on tax topics, the vastmajority of which have been published in leading Mexican taxpublications. He has advised writers of the business section ofthe newspaper El Norte, one of the most prestigious newspapersin Mexico. He is a constant speaker in the most important taxlectures organised by universities and professional organisations.

Gonzalo studied law at the Anahuac University in MexicoCity. He later graduated with a master’s degree in tax law fromPanamericana University. He later completed another qualifica-tion in tax law at the Anahuac University and in Civil Law at the Escuela Libre de Derecho.Gonzalo also earned a degree in common law from the National Autonomous University ofMexico in Mexico City. Gonzalo is now pursuing a master’s degree in business and corporatelaw at the University of Monter rey (UDEM).

Gonzalo is a member of the Mexican Lawyers Bar Association and the National TaxSpecial ists Association (ANEFAC) Chapter Monterrey.

Mexico

Gonzalo Mani

Deloitte Mexico

Av Lazaro Cardenas 2321 Pte PBCol Residencial San AgustínMonterrey 66260Mexico

Tel: +52 81 81337360 (x7360)Email:[email protected]: www.deloitte.com



Mauricio Martinez-D’Meza, Deloitte Mexico, has been a busi-ness tax partner since October 2002. His areas of expertiseinclude domestic and international tax planning, tax controver-sy, and tax litigation.

He served for nine years in the Ministry of Finance. Beforejoining Deloitte, he worked as assistant chief counsel for largetaxpayers, assistant general director for international tax policyand treaty negotiations and assistant chief counsel for domestictaxes.

From 1999–2001 he was a partner at Baker & McKenzie inMonterrey. From 1995–1997 he served as a representative forthe Ministry of Finance before the US and Canadian govern-ments for tax and customs affairs, in Washington, DC.

Mauricio earned his bachelor’s degree in law 1993 from theInstituto Tecnológico Autónomo de México (ITAM). He holds apostgraduate degree from Harvard-ITAM (international taxa-tion programme).

Mauricio has taught at several universities including theInstituto Tecnológico de Estudios Superiores de Monterrey (2010–present): postgraduate degree in taxes–litigation and defenceprocesses; Universidad Anáhuac del Norte: tax law II (January–June 1999) and political his-tory (1998); Universidad Iberoamericana: tax law I (1998); Instituto Tecnológico Autónomode México: Mexican taxation (1995).

Mexico

Mauricio Martinez-D’Meza

Deloitte Mexico

Paseo de la Reforma 489, P 6 Col.Mexico CityMexico

Tel: +52 55 50807040Email:[email protected]: www.deloitte.com



Hugo Romero, Deloitte Mexico, is a partner in the tax litiga-tion department. He has been with Deloitte Mexico for eightyears. His principal area of expertise is tax litigation. He has 18years of experience in trial law related to complex tax matters.He has helped clients challenge the constitutionality of tax lawssetting national judicial precedents.

Hugo has been a speaker at many conferences regarding taxmatters, including the 8th Latin-American Congress of the Inter -national Fiscal Association, the Mexican Lawyers Bar Associa -tion, and the Public Accountants Association of Mexico.

Hugo has written several articles on tax and procedural top-ics, which have been published in leading Mexican tax publica-tions.

Hugo studied law at the Iberoamericana University inMexico City (the 8th semester was taken at the University ofNorth Carolina at Chapel Hill, US). He was later certified bythe Judicial Law School with a degree in constitutional matters.He graduated with a master’s degree in tax law from the Pan -americana University and later completed another qualificationfrom Sheltons SITTI in international taxation principles andplanning. Finally, he obtained a degree in financial administra-tion from the Panamericana University. He also has a degree in Mexican history.

Hugo is a member of the Mexican Lawyers Bar Association and the International FiscalAssociation Chapter Mexico.

Mexico

Hugo Romero

Deloitte Mexico

Paseo de la Reforma No. 505,piso 23Colonia CuauhtémocC.P. 06500, Mexico CityMexico

Tel: +52 (55) 5080 6331Fax: +52 (55) 5080 6001Email: [email protected]: www.deloitte.com



Manuel Solano is the partner in charge of the international taxservices group in Latin America for EY, as well as the managingpartner of EY’s tax practice in the Mexico and Central Americanregion.

Manuel has more than 20 years’ experience working inMexico and Latin America on planning, acquisitions and con-troversy matters. He has a BS from Youngstown State Univer -sity and a JD from Georgetown University Law Center. He alsostudied finance and economics at the Autonomous University ofCentral America.

As a member of the American Bar Association and the NewYork State Bar, Manuel has extensive experience in internationaltax consulting and planning matters. His experience encompass-es advising multinational enterprises on the tax and legal impli-cations of cross-border acquisitions and the establishment offoreign operations in Latin America, as well as controversy mat-ters.

Over the years, Manuel has also been involved on assistingmultinational clients on the defense of some of the larger supplychain, debt restructuring, IP migrations and transfer pricingrelated tax assessments in Mexico and other countries in LatinAmerica.

He has co-authored both the ‘Tax Management PortfolioDoing Business in Venezuela’ and ‘Tax Management Portfolio Doing Business in Mexico’,as well as the ‘Tax Management Portfolio on Transfer Pricing’. Manuel is a regular contrib-utor of tax articles to Tax Notes International, Bloomberg BNA and the Journal ofInternational Taxation.

Mexico

Manuel Solano

EY

Av. Ejército Nacional 843-B, TorreA, Piso 5, Del. Miguel Hidalgo, 11520,Mexico CityMexico

Tel: +52 55 1101 6437Email: [email protected]: www.ey.com



Simón Somohano, Deloitte Mexico, is a tax partner based inMexico City and Tijuana responsible for Deloitte’s transfer pric-ing practice in Latin America and the Caribbean Region.

He has more than 25 years of experience in the applicationof tax, economic and financial criteria in transfer pricing, anti-dumping/subsidy investigations, valuation analysis of intangi-bles, double tax treating issues, planning, business model opti-misation, structuring and economic consulting.

Under his leadership, Deloitte’s regional transfer pricingpractice has been consistently recognised as one of the leadingpractices in Latin America, including 2016 Mexico transfer pric-ing firm of the year by International Tax Review.

He has consistently been named as one of the world’s lead-ing transfer pricing advisers in the Transfer Pricing ExpertGuide published by Euromoney.

His clients include several Fortune 500 multinational enter-prises doing business in Mexico. He has extensive experienceand a successful track record leading the Mexican negotiationsof advanced pricing agreements (APA); mutual agreement pro-cedures (MAP) and transfer pricing examinations with Mexicanand foreign authorities, teaming with colleagues in Deloitte’s global transfer pricing network.In this venue, Simón led the technical and economic team that successfully obtained in 2016a hallmark resolution on a transfer pricing dispute through the recently introduced alternativedispute resolution procedure conclusive agreement.

Simón advises in a variety of industry sectors, mainly automotive, manufacturing andmaquiladoras, retail and consumer goods, real estate, technology, and the energy andresources market. He also provides specialised counselling to clients in several anti-dumpingand subsidy investigations.

Simón is a frequent guest speaker at international business forums in Mexico and abroad.He has written various articles on transfer pricing in specialised journals and is a co-author ofthe ‘Transfer Pricing International Handbook’. A ‘Country-by-Country Guide’ published bythe International Tax Institute and ‘Transfer Pricing, A Theoretical, Legal and PracticeFrame work’, published by the Institute of Chartered Accountants (Mexico).

His professional accreditations and affiliations include being a board member of the trans-fer pricing committee of the Institute of Chartered Accountants. In addition, as the leadtransfer pricing adviser to the National Export Manufacturing and Maquiladora Council(INDEX), Simón has lead the technical negotiations for the establishment of a transfer pric-ing methodology applicable to about 700 Maquiladora APA requests with the Mexican andUS tax authorities. He has also been certified as a financial consultant from Mexico’s Sec -urities and Banking Commission.

Mexico

Simón Somohano

Deloitte Mexico

Río Lerma No. 232 Piso 9C.P. 06500Ciudad de MexicoMexico

Tel: +52 (664) 622-7872Email:[email protected]: www.deloitte.com



Hernaldo Vega, Deloitte Mexico, is a tax director and is activelyengaged in assisting clients with tax audits, lobbying activitiesbefore the tax authorities and to selective litigation. He hasachieved experience in domestic and international tax planning,tax controversy, and tax litigation.

Hernaldo has 14 years of experience in regulatory and dis-pute areas of the Tax Administration Service of the MexicanMinistry of Finance, initiating as a technical supervisor and con-cluding as an assisting director in the large taxpayers’ adminis-tration. He has specialised in tax controversy for more than nineyears at Deloitte Mexico where he has attended a range of highprofile clients in relation to the tax authorities audit activity andformal taxation disputes.

Hernaldo obtained his bachelor’s degree in law in 1994 fromthe Autonomous University of Chihuahua, Mexico, and he alsoearned a bachelors degree in accounting from the same univer-sity in 2005. He is an active member of the Mexican Bar, Law -yers College, and the College of Public Accountants of Mexico.More recently, he finished his master’s in financial strategy atthe Panamerican University in 2015.

Hernaldo has taught at several universities including the Monterrey Institute of Techno -logy and Higher Education (2014–15) on a postgraduate degree in taxes (Mexican tax reg-ulatory frame) and the Escuela Bancaria y Comercial (2011–present) on tax law and the taxreview process.

Mexico

Hernaldo Vega

Deloitte Mexico

Rio Lerma 232, 9th FloorCol. Cuauhtémoc, 06500Ciudad de México.Mexico

Tel: +52 (55) 5080 6258Email: [email protected]: www.deloitte.com



Mexico

Alejandro BarreraBasham Ringe y Correa

Fred BarrettPwC

Jorge CabelloTuranzas, Bravo & Ambrosi

Adolfo CalatayudPwC

Mariano CalderónSantamarina y Steta

Luis CarbajoBaker & McKenzie

César CastañedaKroy Abogados

Ulises CastillaBaker & McKenzie

Pablo Fernández de CevallosTuranzas, Bravo & Ambrosi

Roxana GómezBaker & McKenzie

Manuel GonzalezEY

Edgar KleeHaynes and Boone

Manuel LlacaKPMG

Miguel LlacaLB Y Cia

Fernando LorenzoPwC

Nora MoralesEY

Jorge NarvaezBaker & McKenzie

Gabriel Ortiz GomezOSE

Luis Ortiz HidalgoOrtiz Hernandez y Orendain



Mexico

Sergio Perez CruzPwC

Arturo Pérez-RoblesOSE

Antonio RamirezKPMG

Enrique RamirezEY

Ricardo León SantacruzSánchez DeVanny

Arturo TiburcioHogan Lovells

Juan Carlos VallesBaker & McKenzie



Frits Barnard, Deloitte Netherlands, is an international tax part-ner in the Amsterdam office. He specialises in international cor-porate tax, controversy and tax litigation.

Frits became a partner with a Big 4 firm in 1993 and Del -oitte in 2002.

Frits has been responsible for international mergers andacquisi tions and re-leverage and corporate tax reduction pro-grammes, mainly for Dutch, UK and US multinationals. Hedeveloped structures aimed at income repatriation and demerg-ing international business units.

Frits has substantial experience in handling tax audits, con-ducting negotiations with Dutch revenue authorities, and taxlitigation. In the latter capacity he has handled a number ofbench mark Supreme Court cases. He has also negotiated/rene-gotiated a number of rulings for large multinationals on theirDutch tax base, for example on the allocation of income on thebasis of informal capital concepts.

Presently his role is to act as a trouble-shooter in a variety ofsituations where clients of Deloitte Netherlands need assistancewith dispute resolution. Experience teaches that addressing adis pute often leads to opportunities to improve the tax position.

Frits has contributed to a number of articles on the valuation of financial products for taxpurposes.

He is a graduate of Leiden University (1983) and holds a master’s degree in tax law.

Netherlands

Frits Barnard

Deloitte Netherlands

Gustav Mahlerlaan 2970NL-1081 LAAmsterdam The Netherlands

Tel: +31 (0)88 2886857Fax: +31 (0)88 2889758Email: [email protected]: www.deloitte.com



Johan Hollebeek, Deloitte Netherlands, is a tax partner with thecustoms and global trade service line. He has been with DeloitteNetherlands since 2002. Before joining Deloitte, Johan waswith Arthur Andersen for four years.

Johan specialises in customs duties, VAT and excise duties.Johan’s practices focus on customs valuation, tariff classificationmatters and processing regimes. Johan uses mediation tech-niques to resolve disputes at an early stage but also has extensiveexperience in litigation before Dutch and EU courts on customsduties, VAT and excise duty related matters. He is also a mem-ber of the customs working group of VNO-NCW (The Con -federa tion of Netherlands Industry and Employers). Johan is apermanent contributor to the journal Douanerechtspraak (cus-toms jurisprudence).

Johan is a graduate of Leiden University (indirect taxation)and also completed a post-graduate course in appropriate dis-pute resolution at the Amsterdam ADR Institute.

Netherlands

Johan Hollebeek


Orlyplein 101043 DP AmsterdamNetherlands

Tel: +31 88 288 1992Mobile: +31 6 5151 6811Email: [email protected]: www.deloitte.com/nl



Pascal Schrijver, Deloitte Netherlands, is an indirect tax partnerand leader of the DTTL technology, media and telecommu ni -cations (TMT)/indirect tax industry group.

Pascal advises domestic and foreign clients operating in theTMT industry on indirect tax aspects of business transactions,compliance issues and mergers and acquisitions. Over the last 17years, Pascal has been involved in many restructuring projects foroperators and technology equipment manufacturers, onlinegaming companies and various content providers, among others.

Pascal holds a degree in tax law from University Groningenand is a board member of the indirect tax department of theDutch Association of Tax Lawyers. Pascal also lectures on VATat the University of Leiden in the Netherlands.

Netherlands

Pascal Schrijver


Orlyplein 101043 DP AmsterdamNetherlands

Tel: +31 882884614Mob: +31 650507849Fax : +31 88 288 9763Email: [email protected]: www.deloitte.com/nl



Stef van Weeghel is a tax partner with PwC Netherlands. Stef isPwC’s global tax policy leader as well as member (and formerchairman) of the Dutch AEX-Midkap Group. He is also profes-sor of international tax law at the University of Amsterdam.

Stef’s primary focus is on tax policy and his practice includesstrategic tax advice and tax controversy. He was involved inmajor international transactions, structuring and tax controver-sy/litigation. He regularly renders advice and second opinionsto clients and to other advisers on corporate income tax and taxtreaty matters and is also consulted by the Dutch governmenton a regular basis. On several occasions he has acted as expertwitness in tax matters before Dutch and foreign courts and inBIT-arbitration.

Stef graduated from the University of Leiden in business law(1983) and tax law (1987) and obtained an LLM in taxationfrom New York University in 1990. In 1997, he received a doc-torate in law from the University of Amsterdam (PhD thesis:‘Improper Use of Tax Treaties’). He was admitted to theAmster dam Bar in 1987. In 2000, he was appointed as tenuredprofessor of international tax law at the University of Amster -dam. He authored and co-authored several books and numerous articles on Dutch and inter-national taxation and has lectured extensively in the Netherlands and internationally.

Before joining PwC, Stef was a partner at Linklaters (2007-2009) and a partner at Stibbe(1992-2007) where his roles included membership of the executive committee, head of taxand resident partner in the New York office.

He is a former chairman of the Dutch branch of the International Fiscal Association(IFA), and now chairman of IFA’s permanent scientific committee and chairman of the boardof trustees of the International Bureau for Fiscal Documentation. In 2010, he was the generalreporter for Subject 1 (Tax treaties and tax avoidance: Application of anti-avoidance provi-sions) at the IFA Congress in Rome.

In 2009, Stef was appointed by the Minister and Secretary of Finance as chairman of thestudy group tax system, a committee that advised the Dutch government on comprehensivetax reform in 2010. In 2000, he was a member of the Van Rooy-committee that advised theDutch government on corporate income tax reform.

Netherlands

Stef van Weeghel

PwC

Thomas R Malthusstreet 51066 JR, AmsterdamNetherlands




Edwin Visser became a tax partner at PwC in the Netherlandson January 1 2015. He is the tax policy leader of the EMEAregion, a member of the global tax policy core team, leader ofPwC’s tax controversy and dispute resolution network leader forthe Netherlands, and member of the global leadership team ofPwC’s tax controversy and dispute resolution (TCDR) network.He is based in the AEX-team in Amsterdam.

Edwin’s practice includes boardroom consulting, strategictax advice, tax controversy, tax administration consulting andrepresenting PwC in tax policy matters. Edwin is co-leading aglobal PwC team of around 20 former competent authoritiesand other specialists in mutual agreement procedures.

Edwin graduated from Tilburg University in 1995. He is amember of the editorial board of a renowned tax encyclopaediain the Netherlands, author of a handbook on transfer pricing(published in 2005), co-author of the Netherlands report to theIFA in 2007 on the treatment of intangibles. He has broadexperience in teaching LLM International Taxation at LeidenUniversity, IBFD and the Tax Assurance Academy at NyenrodeBusiness University.

Before joining PwC, he was deputy director-general for tax and customs policy and legis-lation and director for direct taxes at the Dutch Ministry of Finance. He represented theNetherlands in the bureau of the OECD’s committee on fiscal affairs from 2012 to 2014 andhe co-chaired the OECD informal taskforce on tax and development (2010-2014).

Edwin was director for international tax policy and legislation from January 1 2009 toMarch 1 2012. In that capacity he also acted as Competent Authority. From 2004 to 2008,he was responsible for a coordinated treatment of the 2,000 largest companies in theNetherlands by the Netherlands’ Tax and Customs Administration (NTCA). The main chal-lenge was the implementation of the cooperative compliance approach. From 2000 to 2004,he was head of the transfer pricing division of the Dutch tax administration and in that capac-ity he was involved in many mutual agreement procedures.

Netherlands

Edwin Visser

PwC Netherlands

Thomas R Malthusstraat 51066 JR, PO Box 903511006 BJ, AmsterdamNetherlands

Tel: +31 (0) 88 792 6577Email: [email protected]:www.pwc.com/taxcontroversy



Eric Vroemen is a partner in PwC’s Dutch tax and humanresource services (HRS) practice with more than 20 years of rel-evant experience. He is specialised in transfer pricing.

From 1989 until 1996, Eric worked with the Dutch taxauth orities as a state auditor and between 1996 and 2010, heworked with Deloitte in the Netherlands. In 2001, he was sec-onded to New York, and from 2003 until 2006 he was locatedin Chicago as the managing partner of Deloite’s Dutch desks.He moved to PwC in November 2010. Since 1999, Eric hasfocused on transfer pricing and business restructurings, and wasinvolved in planning and controversy management for a largenumber of well-known and complex multinationals. As such,Eric has obtained an in-depth understanding of business opera-tions in a wide variety of industries as well as being familiar withthe tax systems and the methods of working of the tax adminis-trations and competent authorities in the main economies.

Eric is a frequent speaker on transfer pricing and a guest lec-turer at the Leiden University, the IBFD and the PwC TaxAcademy.

Netherlands

Eric Vroemen

PwC

Fascinatio Boulevard 3503065 WB, Postbus 88003009 AV Rotterdam?Netherlands

Tel: + 31 (0) 88 79 25 038Mobile: + 31 (0) 6 13 48 12 42Email: [email protected]:www.pwc.com/taxcontroversy



Netherlands

Dick BarmentloJaegers & Soons Advocaten

Ruud BerendseKPMG Meijburg & Co

Arnaud BooijBooij Bikkers Lawyers

Guido de BontDe Bont Advocaten

Fred de HossonBaker & McKenzie

Paul HalprinBaker & McKenzie

Roel KerckhoffsHertoghs Advocaten

Xandra Kleine-van DijkTax-Insight

Ivo KuipersAtlas

Machiel LambooijFreshfields Bruckhaus Deringer

Charles LangereisWintertaling

Marten MeesLoyens & Loeff

Lars MollerWladimiroff Advocaten

Martien PelinckDe Bont Advocaten

Erik ScheerBaker & McKenzie

Frans SijbersWladimiroff Advocaten

Marc TemmeKPMG Meijburg & Co

Agata UcedaKPMG Meijburg & Co

Job van der PolFreshfields Bruckhaus Deringer



Netherlands

Arjo van EijsdenEY

Peter van HagenHertoghs Advocaten

Monique van HerksenEY

Roelof VosHertoghs Advocaten



Patrick McCalman, Deloitte New Zealand, is a tax partner in theWellington office. He specialises in corporate tax, tax policy andtax disputes with specific focus on the management of InlandRevenue audits and disputes, and the pre-trial dispute resolution.

Before joining Deloitte, Patrick led the New Zealand taxfunctions for two of New Zealand’s largest financial institutions.In those roles Patrick was responsible for the management ofmaterial tax disputes including an industry-wide settlement.

Patrick’s in-house experience is supplemented by his experi-ence with Deloitte, where he has been involved in the successfulresolution of a number of disputes with the Inland Revenuepre-trial process across a variety of issues and industries, includ-ing resolution of cases involving allegations of tax avoidance.Patrick’s practice also includes a focus on tax governance, witha particular emphasis on transaction management and imple-mentation.

With more than 20 years’ tax experience, Patrick’s mix ofcorp orate and professional services experience brings a balancedunderstanding of clients’ tax issues, within a broader commer-cial context.

New Zealand

Patrick McCalman

Deloitte New Zealand

Level 16Deloitte House10 Brandon StreetWellington, 6011New Zealand

Tel: +64 21 978 3737/+64 4 495 3918

Email: [email protected]: www.deloitte.com/nz



Campbell Rose, Deloitte New Zealand, is a tax partner with sig-nificant experience in transaction services, financial services, andtax controversy. He has been mentioned in Chambers for hisresponsiveness and astute advice as well as being listed in Inter -national Tax Review’s Tax Controversy Leaders guide, WorldTax, and in Euromoney’s Tax Advisers Expert Guide and Trans -fer Pricing Expert Guide. Before joining Deloitte, Campbell wasbased at a leading New Zealand law firm for more than 13 years,including six and a half years as a partner.

Over his career, Campbell has advised clients on mergers andacquisitions, corporate restructures and managed funds relativeto a wide variety of domestic and cross-border transactions. Hehas regularly represented clients at all stages of the Inland Rev -enue investigation and dispute process, including litigation sup-port and negotiating settlements. Campbell also worked inLondon for two years, advising clients on the tax aspects ofsecuritisation, structured funding and property-based transac-tions.

New Zealand

Campbell Rose

Deloitte New Zealand

Level 18Deloitte Centre80 Queen StreetAuckland, 1010New Zealand

Tel: +64 93030990Email: [email protected]: www.deloitte.com/nz



New Zealand

Brendan BrownRussell McVeagh

Geoffrey ClewsGeoffrey Clews

Shaun ConnollyRussell McVeagh

Paul DunneKPMG

Geoff HarleyHarleys Chambers

Kirsty KeatingEY

Mike LennardStout Street Chambers

Lindsay McKayThorndon Chambers

David McLayIndependent barrister

Aaron QuintalEY

Fred WardRussell McVeagh



Morten Beck is an advocate and director at PwC in Norway.Morten is the country transfer pricing leader.

Morten has a career spanning 35 years starting as tax con-sultant and head of division at the Directorate of Taxes inNorway, as tax partner with Arthur Andersen & Co and since1994 to 2013 as an international tax and transfer pricing part-ner at PwC in Norway.

Morten has substantial experience in advising multinationalenterprises on international tax matters, and assisting companiesin their efforts to efficiently manage and resolve tax audits.Morten has assisted clients in concluding non-binding advanceagreements with the Norwegian tax authorities with respect tointra-group sale of IP and other assets as well as change of busi-ness model.

Morten has for many years been described as a leading taxexpert in Norway by International Tax Review and Chambers.Morten is admitted to practice before the courts in Norway.

Norway

Morten Beck

Advokatfirmaet PwC AS

PwC Bygget, BjørvikaDronning Eufemias gate 8N-0191 OSLONorway

Tel: +4795260650Email: [email protected]:www.pwc.com/taxcontroversy



Finn Eide, Deloitte Norway, is a partner based in Stavanger.Finn has more than 25 years of experience in the field of corpo-rate tax/direct taxes, M&A, international taxation, transfer pric-ing and tax disputes, including litigation. His client portfolioincludes leading national and international companies in oilfieldservices, finance and energy.

Finn’s key areas of expertise include inbound and outboundstructuring, mitigation of tax risks, tax disputes and litigation.He is admitted to the Norwegian Supreme Court as an attor-ney- at-law.

In addition to advising clients, Finn is a member of the Nor -wegian Bar Association’s law committee for direct taxes. He isalso a lecturer for a number of tax courses and seminars, and asa writer he contributes regularly to tax journals and Finans -avisen (The Norwegian Financial Daily).

Norway

Finn Eide

Deloitte Norway

Strandsvingen 14AStavanger 4032Norway

Tel: +47 51 81 56 40Email: [email protected]: www.deloitte.comzWebsite: www.deloitte.com/no



Hans Martin Jørgensen, Deloitte Norway, is the head of busi-ness tax and transfer pricing. He has extensive experience withaudit defence, primarily within transfer pricing and internationaltax. He covers all aspects of tax including optimisation and plan-ning.

Hans Martin’s experience covers a wide range of sectors andindustries, serving several of the largest multinational enterpris-es in Norway. Hans-Martin joined Deloitte in 2004 and becamea partner in 2008. Before that, he worked with another Big 4firm. Throughout his career, Hans-Martin has represented busi-nesses in all stages of a tax controversy, including litigation pro-ceedings. He is widely recognised as a leading individual by,among others, International Tax Review and Legal 500.

Hans Martin regularly lectures to various organisations,businesses and governmental bodies. He has also published sev-eral articles on transfer pricing and international tax in bothdomestic and international magazines.

He holds a law degree from the University of Oslo, a degreein business finance, and is admitted to the Bar.

Norway

Hans Martin Jørgensen

Deloitte Norway

Dronning Eufemias gate 140191 OsloPostboks 2210103 OsloNorge

Tel: +47 994 46 061Email: [email protected]: www.deloitte.com/no



Norway

Erik Hillestad AasKPMG

Einar BakkoSelmer

Joachim BjerkeBAHR

Ole Henning MathisenKPMG

Arild VestengenEY

Peru

Alberto AraozBaker & McKenzie

Rocio BancesKPMG

David de la TorreEY

Luis Hernandez BerenguelHernandez y Cia

Rolando Ramirez GastonBaker & McKenzie

Jose TalledoBaker & McKenzie

Fernando ZuzunagaZuzunaga & Assereto Abogados



Richard, Deloitte Philippines, is a tax partner with 20 years ofprofessional experience in audit, tax, and corporate services.

Richard leads tax due diligence reviews for merger andacquisitions and advises on the Philippines tax consequences ofacquisition structures. He handles tax compliance reviews foraudit and non-audit clients. He also advises clients on tax plan-ning and restructuring post-merger and acquisition. He repre-sents clients with the tax authorities in contesting tax assess-ments and claiming tax refunds. He also advises and supervisesregistration and entities investing in the Philippines with thePhilippine Securities and Exchange Commission (SEC), Bureauof Internal Revenue (BIR) and those entities availing of tax andfiscal incentives with the Philippine Economic Zone Authority(PEZA), Board of Investments (BOI), and other governmentagencies. He also heads the indirect tax and customs practice ofDeloitte in the Philippines.

Richard earned a bachelor of science degree in accountancyfrom the University of St La-Salle, Philippines, and was placed16th overall in the October 1994 CPA board examinations inthe Philippines. He also completed the strategic business eco-nomics programme (SBEP) at the University of Asia and the Pacific, School of Economics inthe Philippines.

Richard is a member of the Philippine Institute of Certified Public Accountant (PICPA),Association of CPAs in Public Practice (ACPAPP) and the Tax Management Association ofthe Philippines (TMAP).

Philippines

Richard Lapres

Deloitte Philippines

19th Floor Net Lima Plaza5th Ave. corner 26th St.Bonifacio Global City, 1634 TaguigPhilippines

Tel: +63 (2) 581 9044Fax: +63 (2) 869 3676Email: [email protected] Website: www.deloitte.com



Walter Abela, Jr, Deloitte Philippines, is a tax and corporateservices partner with over 19 years of tax and professional serv-ices experience. His experience covers tax assessments, due dili-gence, tax rulings, and government regulatory consulting formultinational enterprises engaged in the consumer business andtransportation, energy and resources, manufacturing, services,and technology, and media and telecommunications industries.He addresses queries on tax and other corporate concerns, andprovides regular tax consultation work. Walter also handles reg-istration matters and other requirements for doing business inthe Philippines, and participates in tax planning work and taxrestructuring focused on tax-saving measures to internationalclients.

Walter heads the Japanese service group (JSG) and the merg-er and acquisitions (M&A) group of the firm’s tax and corpo-rate services. He is a member of the young leaders advisorycouncil (YLAC) of Deloitte Southeast Asia for the fiscal year2014–15.

Walter is a lawyer and a certified public accountant. He isalso an accredited tax practitioner of the Bureau of InternalRevenue and is a member of the Philippine Institute of CPAs, Association of CPAs in PublicPractice, Association of CPAs in Commerce and Industry, Integrated Bar of the Philippines,and Tax Management Association of the Philippines.

Walter received his Bachelor of Laws from the School of Law of Arellano University andBachelor of Science in accountancy from San Beda College. He has also completed the strate-gic business economics program at the University of Asia and the Pacific, Philippines.

Philippines

Walter Abela, Jr

Deloitte Philippines

19th Floor Net Lima Plaza5th Ave. corner 26th St.Bonifacio Global City, 1634 TaguigPhilippines

Tel: +63 (2) 581 9034Fax: +63 (2) 869 3676Email: [email protected] Website: www.deloitte.com



Philippines

Carlos BaniquedBaniqued & Baniqued

Terence Conrad H BelloBaniqued & Baniqued

Mario Rosario L BernardoSalvador & Associates

Ronald BernasBaker & McKenzie/Quisumbing Torres

Dennis DimagibaBaker & McKenzie/Quisumbing Torres

Fidela T Isip-ReyesEY (SGV & Co)

Herminigildo MurakamiKPMG

Cirilo P NoelEY

Mary Karen QuizonKPMG

Wilfredo U VillanuevaEY



Karina Furga-Dąbrowska is head of the tax advisory group atDentons in Poland, the largest international tax practice on thePolish legal market.

She advises on tax aspects of mergers, acquisitions and cor-porate restructurings, as well as cross-border tax planning. Sheprovides advice in relation to day-to-day tax affairs. Working inclose cooperation with the firm’s other practice groups, Karinaoffers a highly-specialised skillset in life sciences and healthcare,real estate and energy.

Poland

Karina Furga-Dąbrowska

Dentons

Rondo ONZ 100-124 Warsaw Poland

Tel: +48 22 242 57 63Email: [email protected]: www.dentons.com



Iwona Georgijew, Deloitte Poland, is a partner and leads Del -oitte’s transfer pricing team in Poland and Deloitte’s regionaltransfer pricing group for central and eastern Europe. She is amember of Deloitte’s global transfer pricing controversy counciland member of Deloitte’s EMEA TP leadership.

She has more than 20 years of professional experience andhas become the leading Polish transfer pricing adviser. She hasbeen leading controversy cases for multinationals operating invarious industries, including telecommunications, consumergoods, IT and e-commerce.

Iwona is a Ministry of Finance tax advisory council member,a member of the International Fiscal Association, and a memberof the transfer pricing forum editorial board of Bloomberg BNA.She is a non-government member of the European Union jointtransfer pricing forum, being the only adviser from Central andEastern Europe holding this role.

Iwona is regularly acknowledged as a leading transfer pricingadviser in Euromoney’s Transfer Pricing Expert Guide andWomen in Business Law Expert Guide. The transfer pricing teamled by Iwona won the 2014 International Tax Review award for‘Transfer Pricing Firm of the Year – Poland’.

Iwona is the Deloitte diversity leader in Poland and Central Europe. Iwona is also the co-founder and leader of Deloitte SheXO Club, which has operated since 2011 and is targetedtowards women holding managerial and executive positions. The club supports personal andprofessional development of business women. It also provides an opportunity to regularlyexchange thoughts, develop leadership skills and network.

Iwona has a master’s degree in foreign trade from the Warsaw School of Economics anda practitioner diploma in executive coaching from the Academy of Executive Coaching. Sheis a certified Polish tax adviser.

Poland

Iwona Georgijew

Deloitte Poland

Al. Jana Pawla II 19Warsaw, 00-854Poland

Tel: +48 22 511 04 08Mobile: +48 691 951 136Email:[email protected]: www.deloitte.pl



Poland

Tomasz BaranczykPwC

Slawomir BorucBaker & McKenzie

Tomasz ChentoszBaker & McKenzie

Piotr KarwatRadzikowski, Szubielska i Wspólnicy

Peter KayKPMG

Robert KrasnodębskiWeil, Gotshal & Manges

Piotr MaksymiukBaker & McKenzie

Dariusz MalinowskiKPMG

Mariusz MareckiPwC

Agnieszka TalasiewiczEY

Piotr WysockiBaker & McKenzie



Jaime Carvalho Esteves is partner of PwC Portugal and is thehead of tax at PwC Angola, Cape Verde and Portugal. He isPwC’s government and public sector leader and is an arbitratorat the Portuguese Court of Tax Arbitration (CAAD), being reg-ularly involved in decisions in tax matters. He is a member ofthe Governing Board of the Forum for Competitiveness(Forum para a Competitividade).

During his career, Jaime was partner of two prestigious lawfirms, being in charge of the Epson (STA) and Norvalor (STA)cases.

He is specialist in national and international tax planning(both individual and corporate), transfer pricing, mergers andacquisitions, corporate reorganisations, high-net worth individ-uals and family business, including family offices.

He has significant experience in the areas of oil and gas,automotive, civil construction and public works, retail, hospital-ity and leisure, industrial and consumer products, real estate,services and telecommunications.

Jaime teaches tax matters at several universities in Portugal(IPCA, ISAG, PBS, UCP Lisbon, and UCP Oporto) and par-ticipates regularly as a speaker in several courses, seminars andconferences, both domestically and internationally, dealing with subjects such as foreigninvestment and public policy, as well as tax topics. He also collaborates regularly with severaltelevision stations, radio broadcasters and periodicals on the same topics.

Jaime has written numerous articles and published several studies including: ‘Notes aboutthe Epson Case’ in Court Decisions, Almedina; ‘Partial Amortization of Shares without sharecapital reduction’ and ‘Harmonization of Direct Taxation and the Gift and Inheritance Tax’in ‘Fisco’ n. 46, 1992 and n. 72/73, 1995; ‘The Relevance of TNMM in Transfer Pricing’,AAVV, Vida Económica, September 2006; ‘Portugal’ in ‘The Determination of CorporateTax able Income in the Member States’, Kluwer Law International, 2007; ‘Budget Act Pro -posal 2009’ in ‘Practical European Tax Strategies’ (Vol. 10, In. 10 – Portugal); ‘Effective tax -ation of distributed profits’, ‘Dealings’, and ‘Profits and losses arising from mergers and spin-offs’, respectively in Minutes of the I, II and III Tax Congress of the Law Faculty of theOporto University (2011, 2012, 2013); ‘Fat Capitalization’ in Studies in Tribute to Profes sorSaldanha Sanches (2012) and ‘Permanent establishments and business conversions’ in TPStudies (2013); co-authorship with Rosa Areias of CIT – Practice Notes; ‘Resolving Inter -national Tax Disputes: The Emerging Role of Arbitration and the Portuguese Example’, co-authorship with C David Swenson and Crystal A Thorpe, in ‘The Portuguese Tax ArbitrationRegime’, 2015, Almedina, CAAD.

Portugal

Jaime Carvalho Esteves

PwC Portugal

Palácio SottomayorRua Sousa Martins, 1 – 3º1069-316 LisbonPortugal

Tel: +351 213599601Email:[email protected] Website:www.pwc.com/taxcontroversy



Portugal

Gustavo AmaralKPMG

Antonio Américo CoelhoKPMG

Rosa AreiasPwC

Pedro BrazGarrigues - Taxand

Susana CaetanoPwC

Susana ClaroPwC

Francisco de Sousa da CâmaraMorais Leitao, Galvao Teles, Soares da Silva & Associados

Clara DithmerPwC

João EspanhaEspanha e Associados

Samuel Fernandes de AlmeidaVieira de Almeida & Associados

Rogério Fernandes FerreiraRogerio Fernandes Ferreira & Associados

Jorge FigueiredoPwC

Conceição GamitoVieira de Almeida & Associados

Andre GoncalvesAAA Advogados

Catarina GoncalvesPwC

Mariana GouveiaMiranda Correia Amendoeira

Joaquim Pedro LampreiaVieira de Almeida & Associados

Antonio Lobo XavierMorais Leitao, Galvao Teles, Soares da Silva & Associados

Marta Machado de AlmeidaRogerio Fernandes Ferreira & Associados



Portugal

Luis MagalhaesKPMG

Tiago Marreiros MoreiraVieira de Almeida

Alexandra MartinsKPMG

Paulo MendonçaEY

Ana Moutinho NascimentoServulo

Serena NetoPLMJ

Diogo Ortigão RamosCuatrecasas Goncalves Pereira

Cláudia Reis DuarteUria Menendez Proença de Carvalho

Monica Respício GonçalvesRogerio Fernandes Ferreira & Associados

Antonio Rocha MendesCampos Ferreira, Sa Carneiro

Filipe RomãoUria Menendez Proença de Carvalho

Hugo Salgueirinho MaiaPwC

Miguel Teixeira de AbreuAbreu Advogados

Manuel Anselmo TorresGalhardo Vilão, Torres - Sociedade de Advogados

Maria TorresPwC

Leendert VerschoorPwC

Puerto Rico

Rolando LopezKPMG



Andreea Artenie, Deloitte Romania, is an attorney at law andheads the Reff & Associates litigation practice. She has morethan 13 years of experience in administrative and tax practice,coordinating a large number of administrative litigations againstnational authorities and particularly tax disputes initiatedagainst the tax authority.

Her high rate of success has made Andreea one of the re -nowned specialists in fiscal procedural law.

In addition to her in-depth specialisation in tax controversy,Andreea has gathered comprehensive experience in competitionlitigation by coordinating numerous successful litigationsagainst the Competition Council’s decisions.

The team under Andreea’s supervision also offers advice andrepresentation before national courts for an important portfolioof commercial litigation and enforcement proceedings.

Romania

Andreea Artenie

Deloitte RomaniaReff & Associates SCAThe law firm representingDeloitte Legal in Romania

4-8 Nicolae Titulescu RoadEast Entrance, 3rd Floor Sector 1011141, BucharestRomania

Tel: +40 (21) 2075 435Email: aartenie@

reff-associates.ro Website: www.reff-associates.ro



Vlad-Constantin Boeriu, Deloitte Romania, is a partner withinthe indirect tax department. With over 12 years of experience inthe field of indirect taxation, Vlad is a tax specialist with signif-icant international exposure to indirect tax issues.

His broad knowledge in VAT that stems from managinginternational projects within different jurisdictions and legisla-tions, as well as assisting various multinationals.

Vlad has experience in VAT planning. He assisted variouscompanies in streamlining their activities in Romania in themost efficient manner. Vlad also specialises in providing assis-tance and innovative ideas of VAT optimisation, enabling com-panies carrying on activities in Romania to obtain savings andmanage their business flow in a cost effective way.

VAT compliance projects are also among Vlad’s area ofexpertise. He has provided VAT compliance services both toRomanian established entities and to non-resident companies.

Vlad has extensive experience in due diligence project. Hehas assisted companies, both on the buyers and sellers side, pro-viding high quality advice, identifying, and quantifying thepotential liabilities/assets for the companies involved.

Also, as part of the tax litigation team, Vlad is involved in assisting clients in front of taxauthorities during audits and appeals.

Romania

Vlad-Constantin Boeriu

Deloitte Romania

Nicolae Titulescu Road4-8, America House BuildingEast Wing, 2nd floorRomania

Tel: +40 (21) 2075 341Email: [email protected]: www.deloitte.com



Dan Dascalu graduated in law from the Bucharest University in1997. He is a member of the Bucharest Bar and subsequentlyobtained a postgraduate diploma from The Hague Academy ofInter national Law in the Netherlands. Dan has a PhD degree intax contentious matters from the Law Faculty of the BucharestUni versity (2013). He has been working with David & Baias –the associated legal firm with PwC Romania – and PwCRomania, since February 2001.

Dan is active in litigation (with a special focus on tax, as theCEE leader of the PwC tax controversy and dispute resolutionnetwork) and employment matters. His practice includes assis-tance to clients in front of the tax authorities (during tax inspec-tion and administrative procedures, drafting contestations andcomplaints, among others) as well as representing clients infront of courts in the field of tax law, competition law, commer-cial law, labour law and civil law.

Dan’s major litigation projects include a series of approxi-mately 20 cases for Steaua Romana (Romanian refinery) seekingannulment of various tax deeds of the tax administration thathelped the client recover from the state the VAT unlawfullydenied for reimbursement (an amount of approximately €12 million ($13.5 million)), plusinterest (more than €3.5 million); and one case at the European Court of Justice (C-431/12). Various litigation cases for: major Romanian leasing companies (including assistancewith the European Court of Justice in case no. C-483/13, that resulted in the annulment oftax decisions of around €20 million); grain trading companies (reimbursed taxes and interestin excess of €20 million); Asian major electronic producer; major international steel compa-ny; major German cement producer, etc.

He also has vast experience assisting clients in preparing documentation for the com-mencement of infringement proceedings by the European Commission against the Romanianstate for breaching EU law, which ultimately led in 2013 to the repeal of the relevantRomanian law provisions.

Since 2003, Dan has been involved in the process of enactment of the Tax ProcedureCode, as well as of its various subsequent amendments. Similarly, he is the coordinator of thetax procedure taskforce delegated by Coalitia pentru Dezvoltarea Romania to discuss withthe Romanian government the project of the new Tax Procedure Code (which entered intoforce in 2016) and the changes to be brought in 2016 to this Code.

Dan is the author of The Handbook on Tax Contentious Matters and of The extraterritorialenforcement of tax receivables, co-author of a reference book on the Romanian Tax ProcedureCode, as well as of various papers on civil and commercial law published by Romanian lawjournals.

Romania

Dan Dascalu

D&B David si Baias/PwC

Barbu Vacarescu 301-311BucharestRomania




Romania

Jean-Marc CambienEY

Niculae DoneKPMG



Raisa Alexakhina, Deloitte Russia, is a partner and the leader oftax dispute resolution and legal services in the CIS. She hasbeen providing tax and legal services since 1994 combiningboth industry and experience from the Big 4 firms. She is a fre-quent speaker on various tax controversy topics.

Over the course of her career, Raisa has led an extensive num-ber of complicated tax litigation projects in a variety of industries.She has represented clients in more than 500 tax disputes at alllevels, including Russian Supreme and Supreme CommercialCourts and achieved an exceedingly high rate of success in theprocess. Raisa has also chaired Deloitte Russia’s internal technicalgroup responsible for developing legal positions.

Raisa has earned a master’s degree in law from Moscow StateLaw Academy and a PhD in financial law.

Russia

Raisa Alexakhina

Deloitte Russia

Business Center White Square, 5Lesnaya St, Bldg B, Moscow,Moscow, 125047Russia

Tel: +7 (495) 787 06 00 ext. 2950Fax: +7 (495) 787 06 01Email: [email protected]: www.deloitte.ru



Kristina Baleva is an associate of Dentons’ Russian tax and cus-toms group. Kristina specialises in advising Russian and interna-tional companies in customs regulation, namely, analysis offuture transactions and contracts (both concluded and in theprocess of being concluded) from the perspective of possiblecustoms risks, and the efficiency of using the permissible cus-toms tools, preparation of recommendations on how to applycustoms procedures (temporary import, processing in/outsideof the customs territory, customs warehouse, customs transit,etc.), measures of customs tariff and non-tariff regulation of for-eign trade, assistance in challenging decisions of the customsauthorities (customs value, classification code) and in obtainingpreliminary decisions on the classification of goods.

Russia

Kristina Baleva

Dentons

White Gardens Business CenterLesnaya ulitsa, 7Moscow, 125047Russian Federation




Vladislav Bozhenkov is a senior associate in PwC’s tax disputeresolution practice. With more than 16 years of experience inRussian tax law, he has helped clients resolve more than 100 taxdisputes. Vladislav has represented major Russian and multina-tional enterprises, including automotive companies, electronicsproducers, and oil and gas companies, in a broad range of taxcases, from pre-trial dispute resolution all the way through totax litigation. His professional expertise covers transfer pricingclaims, multi-episode disputes involving challenges to claimexpenses, VAT and profits tax disputes, and many other practicalaspects of tax law.

Vladislav participates in high profile trials. Vladislav fre-quently participates in external and internal tax dispute resolu-tion seminars as an expert and speaker.

Russia

Vladislav Bozhenkov

PwC Legal

White Square Office Center10 Butyrsky Val125047 MoscowRussia




Boris Bruk is of counsel in Dentons’ Moscow office. He spe-cialises in general corporate and international tax law and hasconsiderable experience in advising on tax aspects of corporaterestructurings. In particular, Boris advises clients on tax struc-turing in connection with financing joint ventures in Russia,cross border transactions, and inbound and outbound invest-ments. His work has involved the development of tax-efficientpersonal and corporate holding structures and the structuringof financing and IP holding activities, as well as counselling withregard to the mitigation of identified tax exposures. Boris’ back-ground also includes IPO-related tax consulting services.

Russia

Boris Bruk

Dentons





Galina Dontsova is of counsel in the Russian tax and customsgroup, focussing on customs issues. Galina has more than 20years of experience advising on all aspects of customs regulation,including assisting during customs audits, structuring foreigntrade deals for import or export of goods, reviewing contracts,advising on the classification of goods, customs value, countryof origin and customs procedures, applying customs prefer-ences, negotiating with customs authorities, appealing the deci-sions of customs authorities, drafting customs clearance docu-ments and advising on other customs issues.

Galina has extensive experience working with Russian gov-ernment authorities. As a member of expert councils and work-ing groups she has participated in drafting legislation, includingthe Customs Union Customs Code, the Customs RegulationLaw, resolutions of the Government of Russia and regulatoryacts of the Federal Customs Service. She is a member of thecoordinating council for foreign freight traffic optimisationunder the State Duma committee for transport, and the work-ing group for improvement in customs administration of theAgency for Strategic Initiatives.

Russia

Galina Dontsova

Dentons


Tel: +7 495 644 [email protected]: www.dentons.com



Dzhangar Dzhalchinov is a partner in Dentons’ Moscow officeand head of the Russia tax and customs practice. He primarilyfocuses on tax litigation.

Between 2007 and 2014, Dzhangar handled over 700 courtcases, including many before the Supreme Arbitration Court. Inaddition, Dzhangar provided full support in a considerablenumber of tax disputes settled at pre-trial stages.

Dzhangar also advises on various aspects of taxation, includ-ing drafting internal policies to prevent tax risks (regarding sup-pliers, marketing, and others), analysing contracts for tax risks,and verifying tax accounting in order to reveal potential taxassess ments and overpayments.

Russia

Dzhangar Dzhalchinov

Dentons





Maria Mikhaylova is a senior associate in PwC’s tax dispute res-olution group.

She has extensive experience in tax matters and has repre-sented clients in more than 50 cases over the past three years.She has represented major Russian and multinational enterprisesin a broad range of tax cases, from pre-trial dispute resolutionthrough to all tax litigation stages. Maria’s professional expert-ise also includes transfer pricing claims, VAT and profits tax dis-putes, customs disputes and many other practical aspects of taxand customs law.

She provided complex tax and legal support to a leadingRussian food retailer for the creation of one of Russia’s largestconsolidated taxpayer groups.

Maria regularly participates in external and internal tax dis-pute resolution seminars as an expert and speaker.

Russia

Maria Mikhaylova

PwC Legal

White Square Office CenterButyrsky Val 10125047 MoscowRussia




Kirill Roubalsky is an associate in Dentons’ Moscow office. Hefocuses on tax litigation, general corporate and international taxlaw and has extensive experience advising on transfer pricingissues. Kirill has wide-ranging experience advising major Russianand international companies on a broad range of tax law issues,including taxation of non-residents, application of VAT deduc-tions in the construction industry, tax aspects of real estate andsecurities transactions, as well as M&A transactions. His experi-ence also includes successfully representing clients in complextax disputes and assisting with desk and field tax audits.

Russia

Kirill Roubalsky

Dentons





Denis Schekin is a managing partner at Schekin & Partners inMoscow.

He works on tax disputes and tax audit support, tax structur-ing and risk assessment, and transfer pricing. Denis specialises intax law, including tax disputes and tax consulting.

Denis has advised companies and handled tax disputes since1995. He has represented Russian and multinational clients incourt, challenging additional tax assessments worth hundreds ofbillions of rubles.

According to the Best Lawyers, Chambers Europe, the GlobalLegal Experts, Tax Directors Handbook, European Legal Experts,and others, Denis is ranked as one of the top Russian tax spe-cialists.

Denis is the author of books and publications on tax and isone of the most prominent speakers on tax topics.

Denis graduated from the Law Department of KrasnoyarskState University in 1997, and further in 2001 became a PhD ofJudicial Sciences. Denis is also a member of the Federal Cham -ber of Lawyers of the Russian Federation.

Schekin & Partners specialises in tax, commercial law and various types of litigation, pro-viding superior services with depth of knowledge and wealth of experience. The firm offerslegal advice to leading Russian and multinational enterprises in oil and gas, metals, food prod-ucts, automotive, construction, transportation, IT, banking, wholesale and retail and otherindustries. The professionals of Schekin & Partners follow a rigorous programme of profes-sional study, read all key publications on tax, civil law, court rulings and official guidance. Thefirm leverages its established connections with leading Russian universities to obtain expertopinion on the most complex problems relating to any branch of law.

Russia

Denis Schekin

Schekin and Partners

Nizhniy Kislovskiy lane, 6, bldg 2125009 MoscowRussia

Tel: +7 495 984-63-01Email: [email protected]: www.schekinlaw.ru



Gennady Timonichev is an associate in Dentons’ Russian taxand customs group. He specialises in advising on general corpo-rate and international tax law, transfer pricing, and in resolutionof tax disputes. Gennady has extensive experience advising majorRussian and international companies on a wide range of issuesof applying tax law, including in the area of transfer pricing,intra group transactions, securities transactions and forward fin -ancial instruments, as well as M&A transactions. His experiencealso includes successfully representing clients in complex tax dis-putes and assisting during office and field tax audits. He is theauthor of a number of publications in the field of tax law.

Russia

Gennady Timonichev

Dentons





Anna Zvereva is of counsel in Dentons’ Moscow office. Herparticular areas of tax specialisation include tax accounting, taxdue diligence reviews, tax audits, tax compliance projects,accounting and payroll outsourcing; accounting in accordancewith Russian accounting standards and IAS; audits in accor-dance with RAS (production, drugstores, retail and wholesaletrade, services, mass media, hotels, logistic companies), andconsulting in the fields of taxation and accounting (VAT, profittax, payroll taxes, withholding VAT and income tax, import andexport operations, trading within the CIS, application of DTAprovisions). Anna is also experienced in representing clients incourt proceedings involving the Russian tax inspectorate.

Russia

Anna Zvereva

Dentons





Russia

Rustem AhmetshinPepeliaev Group

Alexander BychkovBaker & McKenzie

Alexander ChmelevBaker & McKenzie

Irina DmitrievaWhite & Case

Andrey GrachevKPMG

Oleg KonnovHerbert Smith Freehills

Maria KostenkoBaker & McKenzie

Alexandra LobovaEY

Andrey NikonovPepeliaev Group

Mikhail OrlovKPMG

Irina PaninaKPMG

Sergey PepeliaevPepeliaev Group

Ilya RybalkinAkin Gump Strauss Hauer & Feld

Arseny SeidovBaker & McKenzie

Evgeny TimofeevGoltsblat BLP

Sergei ZhestkovBaker & McKenzie

Anton ZykovKPMG



Sui Fun Chai is a partner with global structuring at PwC Singa -pore. She joined PwC Singapore in July 2013. Sui Fun focuseson the transfer pricing practice of the firm and plays a leadingrole in the tax controversy and dispute resolution space.

Sui Fun has 30 years of tax experience as a senior tax admin-istrator, external tax adviser and in-house global tax director.

Before joining PwC Singapore, Sui Fun was the assistantcommissioner for tax policy and international tax at the InlandRevenue Authority of Singapore and served as a CompetentAuthority of Singapore. In this role, Sui Fun actively supportedthe Singapore’s Ministry of Finance and worked closely witheconomic agencies such as the Singapore Economic Develop -ment Board and IE Singapore to formulate and implement taxpolicies, tax changes and tax-related economic and social pro-grams. She was responsible for interpreting and clarifying theapplication of tax laws for taxpayers, including corporates. Inher capacity as Competent Authority of Singapore, Sui Fun rep-resented the Singapore government in tax treaty negotiations/other international tax matters. She also helped lead and suc-cessfully resolve more than 40 bilateral/multilateral advancepricing arrangements (APAs) and mutual agreement procedure (MAP) cases, which providedsignificant tax certainty and relief from double taxation for the multinational enterprises con-cerned. These include bilateral APAs and double taxation cases between Singapore and Japan,Australia, China, UK and several other jurisdictions.

Sui Fun has extensive experience in supporting multinational enterprises in managingcomplex cross-border tax controversies and mitigating the related tax exposures. Since join-ing PwC Singapore, she has worked closely with several multinational clients on addressingbusiness transformation (including transfer pricing) issues and establishing robust transferpricing policies/documentation practices. She has also advised them on tax defence strategiesfor both domestic and cross-border tax matters and assisted multinational groups to securetax certainty through APAs and relief from double taxation through the MAP process.Together with her tax administration and in-house tax experience, Sui Fun is able to providea balanced and pragmatic perspective to clients in managing their tax exposures.

Sui Fun has a master’s degree in public administration/international tax programme fromHarvard University and a bachelor’s degree in accountancy, with honours, from the NationalUniversity of Singapore.

Singapore

Sui Fun Chai

PwC Singapore

8 Cross Street #17-00PWC BuildingSingapore 048424Singapore




Low Hwee Chua, Deloitte Singapore, is a tax partner and hasmore than 20 years of experience in taxation services includingtwo years with the Inland Revenue Authority of Singapore. Heis also the regional managing partner for the tax practice inDeloitte Singapore and Deloitte Southeast Asia.

Hwee Chua specialises in corporate income tax and interna-tional tax, working with clients to confirm their businesses’ taxaffairs are managed efficiently and cost effectively. Hwee Chuahas extensive experience in the areas of tax compliance and taxconsultancy work for local and multinational enterprises. He hasalso been extensively involved in providing tax advice on a widevariety of corporate tax consulting projects including restructur-ing, mergers and acquisitions, tax due diligence, and structuringof inbound and outbound investments. Hwee Chua has alsoassisted various multinational enterprises to understand what taxincentives and grants are available and the qualification criteria.

Hwee Chua is an accredited tax adviser (income tax) withthe Singapore Institute of Accredited Tax Professionals (SIATP),an accreditation body for tax professionals in Singapore and isalso a board member of the SIATP.

Singapore

Low Hwee Chua

Deloitte Singapore

Deloitte & Touche LLP6 Shenton Way, OUE Downtown 2#33-00Singapore 068809Singapore

Tel: +65 6216 3290Email: [email protected]: www2.deloitte.com/sg



Nicole Fung is a tax partner and has led the transfer pricingpractice in PwC Singapore for 12 years. She has over 25 years ofexperience advising on international tax and transfer pricing. Inaddition, she has been the regional relationship partner forEuro pean multinationals, responsible for all their tax matters inthe Asia-Pacific region and working closely with the PwC networkto ensure alignment and consistency in any advice provided.

She has led major transfer pricing strategy and dispute reso-lution projects for multinational enterprises and negotiationswith government authorities both in Singapore as well as othercountries in the region. In this respect, Nicole has been involvedin cross-border transfer pricing resolution cases since 2003 andhas been involved in the bilateral APAs between Singapore andJapan, China, Taiwan, Australia, UK, South Korea, Denmark,Switzer land and France, many of which are first bilateral agree-ments between the countries.

Nicole has worked with MNEs in structuring, implementingtransfer pricing and supply chain transformation involving therestructuring of their customer service and other operations inthe most tax efficient manner. This includes discussions withgovernment authorities on appropriate incentives in Singapore and other region.

Nicole is a frequent speaker on transfer pricing related topics and has spoken at severalworkshops and seminars for clients across various levels and tax authorities in Singapore andVietnam.

Nicole holds bachelor degrees in law economics. She is also admitted to the Bar in bothAustralia and Malaysia.

Singapore

Nicole Fung

PwC Singapore

8 Cross Street#17-00 PwC BuildingSingapore 048424Singapore




Daniel Ho, Deloitte Singapore, is a partner with more than 17years of tax experience in serving local and listed companies inSingapore, as well as multinational enterprises in industries suchas real estate, fund management, technology, consumer prod-ucts, shipping, and energy and resources.

He has extensive experience in Singapore and internationaltax consultancy and planning in the areas of corporate restruc-turing, supply-chain planning, permanent establishment issues,and dispute resolution. Daniel has represented clients in varioussectors such as real estate, engineering, and shipping sectors intax controversy discussions with the Inland Revenue Authorityof Singapore (IRAS). He is also involved in numerous mergersand acquisitions, tax structuring and due diligence assignmentsfor corporates and private equity funds. He is well versed inSingapore’s tax incentive regimes including headquarter, trad-ing, fund management and shipping incentives and has assistedclients in the application for such incentives. Daniel has writtenan article on R&D tax incentives in Singapore, which was pub-lished in the 2015 International Fiscal Association (IFA) cahiers.

Daniel was previously a facilitator at the Singapore TaxAcademy. He is a faculty member of the Deloitte International Corporate Tax School and aformer part-time lecturer for the subject ‘principles of taxation’ at the Nanyang Techno -logical University.

Daniel graduated from Nanyang Technological University with a bachelor’s degree, withhonours, in accountancy and has completed the CFA programme. He is a non-practisingchartered accountant and an accredited tax adviser (income tax) with the Singapore Instituteof Accredited Tax Professionals (SIATP). Daniel is also a member of the Tax Academy’s cur-riculum and examination development (CED) committee and the Singapore ShippingAssocia tion tax sub-committee.

Singapore

Daniel Ho

Deloitte Singapore

6 Shenton WayOUE Downtown 2, #33-00Singapore 068809Singapore

Tel: +65 6216 3189Fax: +65 6538 6166Email: [email protected]: www2.deloitte.com/sg



Lee Tiong Heng, Deloitte Singapore, has more than 19 years oftax advisory and compliance experience serving local, multina-tional and listed companies, as well as private equity firmsincluding four years with the Inland Revenue Authority ofSingapore (IRAS).

He has extensive experience in tax consultancy and planningservices including tax M&A work, corporate restructuring,cross-border transactions, tax ruling requests, taxation negotia-tion with the IRAS and Singapore tax incentives and grantsapplications from the Singapore government authorities.

Tiong Heng leads the RDGI (development, R&D and gov-ernment incentives) service line of Deloitte Singapore andSoutheast Asia. He is also Deloitte Singapore’s leader for tech-nology, media and telecommunications (TMT), manufacturing,and the middle market/growth enterprise leader for tax.

Tiong Heng has served clients in various industries includingaviation and transportation, business services, consumer busi-ness, energy and resources, manufacturing, real estate andTMT.

He is a fellow member of the Institute of Chartered Accountants of Singapore and he isalso an accredited tax adviser with the Singapore Institute of Accredited Tax Professionals.

Singapore

Lee Tiong Heng

Deloitte Singapore

6 Shenton Way #33-00OUE Downtown 2Singapore 068809Singapore

Tel: +65 6216 3262Email: [email protected] Website: www2.deloitte.com/sg



See Jee Chang, Deloitte Singapore, is a partner with more than18 years of experience in taxation.

Before joining Deloitte, Jee Chang worked for the InlandRevenue Authority of Singapore (IRAS) for more than 10 years.In his role as tax director of the tax policy and international taxdivision, he served as Singapore’s Competent Authority,responsible for the negotiation of advance pricing agreements(APAs) and settlement of transfer pricing disputes, and con-ducted tax treaty negotiations. He was significantly involved indeveloping the Singapore transfer pricing guidelines issued in2006, and served as the key technical IRAS resource with regardto transfer pricing matters. He was also responsible for issuingtax rulings and IRAS circulars, supporting tax policy formula-tion and drafting new tax legislation, as well as collaboratingwith various Sin ga pore government economic agencies on taxincentive design and implementation.

Jee Chang advises and serves major multinational clients,many of whom have Singapore-based regional head- quarters.He has substantial experience advising his clients on interna-tional and Asia Pacific tax and transfer pricing planning, in and outbound investment, struc-turing, as well as supply chain and business model optimisation. He has also successfullyhelped his clients resolve complex tax and transfer pricing issues with the IRAS, and obtainedfavourable tax incentives from the Singapore government, as well as strategic tax rulings andAPAs.

Jee Chang earned a bachelor of accountancy degree from the Nanyang TechnologicalUniversity and a master of business administration (MBA) degree from INSEAD businessschool. He is a regular speaker at seminars and he lectures at the Singapore Tax Academy andthe IRAS internal specialist training programmes.

Jee Chang is a CPA with the Institute of Certified Public Accountants of Singapore, andan accredited tax adviser with the Singapore Institute of Accredited Tax Practitioners.

Singapore

See Jee Chang

Deloitte Singapore

6 Shelton Way #33-00OUE Downtown 2Singapore, 068809Singapore




Michael Velten, Deloitte Singapore, is a financial services taxpartner and a financial services tax leader for Deloitte in AsiaPacific.

Michael joined Deloitte Singapore in 2013 as the SoutheastAsia financial services tax leader. He has over 30 years of taxexperience, 25 years of which have been spent working in Asia,based in Kuala Lumpur, Hong Kong and Singapore.

Michael advises on all areas of Singapore financial services taxincluding indirect tax, information reporting and transfer pric-ing, and coordinates the delivery of Asia regional tax services forclients. Michael regularly assists with tax audits and disputes,both in Singapore and elsewhere in the region. He has conduct-ed tax appeals in Hong Kong, India, South Korea and Taiwan.

Prior to joining Deloitte Singapore, Michael was group headof tax at a leading brokerage and investment house, and beforethat, he headed the Asia ex-Japan tax department of a leadingglobal investment bank. He was also a tax partner in a Big 4firm in Singapore and a tax partner in the Singapore office of aleading international law firm. Michael commenced his career intax practice in Melbourne and was a senior associate with a leading Australian law firm, witha focus on tax litigation in the Federal Court of Australia.

Michael holds a bachelors degree in commerce, Bachelor of Laws and Master of Taxationdegrees from the University of Melbourne. He has a Master of Laws degree from theNational University of Singapore and a Master of Business Administration degree from theUniversity of New England. Michael is qualified as both a solicitor and CPA (Australia). Heis an accredited tax adviser: income tax and GST (Singapore), a certified tax adviser (HongKong) and an associate of the Chartered Tax Institute of Malaysia.

Michael has previously held appointments as an adjunct associate professor of law at theNational University of Singapore and as a visiting fellow to the University of Melbourne.

Singapore

Michael Velten

Deloitte Singapore

6 Shenton WayOUE Downtown 2, #33-00,Singapore 068809Singapore




Singapore

Rick AsquiniKPMG

Ong Sim HoOng Sim Ho

Eugene LimBaker & McKenzie

Oi Leng MakKPMG

Ken Loon OngDrew & Napier

Dawn QuekBaker & McKenzie

Siew Moon SimEY

Allen TanBaker & McKenzie

Peter TanBaker & McKenzie



Luke Barlow, Deloitte South Africa, is a corporate tax partnerand the leader of the tax practice in Cape Town. He has 30 yearsof experience consulting in the field of taxation. Luke has exten-sive experience advising multinational and national enterpriseswith particular emphasis on the financial services and energyand resources sectors.

In addition to his involvement with tax dispute resolutionmatters he has been involved in a number of acquisitions andrestructures where he has advised on the efficient structuring ofthe transactions. Luke also has extensive practical experience inadvising on the taxation aspects of private equity investmentsand management buyouts (MBOs) and leveraged buyouts(LBOs). He has been involved in due diligence reviews of,among others, large companies in the hospitality, retail, energyand resources and life insurance industries.

Luke has advised on, inter alia, a number of structuredfinance transactions, hybrid capital structures and securitiseddebt issues.

Luke studied at the University of Cape Town where he grad-uated with degrees in taxation, accounting and law. He is a South Africa chartered accountantand is an advocate of the High Court.

South Africa

Luke Barlow

Deloitte South Africa

27 Somerset RoadGreen PointCape Town, ZA 7708South Africa

Tel: +27 214275480Email: [email protected] Website: www.deloitte.com



Bernard du Plessis is an executive at ENSafrica and joint head ofthe firm’s tax department.

He is a chartered accountant with 20 years of experience ininternational tax and tax controversy. Prior to joining ENS -africa, Bernard was a senior partner and head of internationaltax in Johannesburg for an international accounting firm. Healso serves as a non-executive director on a number of interna-tional and local boards of companies.

Bernard combines his commercial and leadership experiencewith legal, financial advisory and tax controversy expertise to assistmultinational enterprises in devising sustainable tax strategies.

Bernard specialises in advising multinational enterprises onplanning international transactions and investments, corporatestructures, investment funds and the digital economy. He is alsoa leading specialist in tax controversy and leads defence teamson complex international tax and transfer pricing disputes. Inad dition, Bernard advises on transactions, corporate structuringand tax dispute matters in Africa. His extensive experience inplanning and defending international transactions and corpo-rate structures places him in an ideal position to provide adviceon establishing a sustainable and resilient corporate tax strategy.

Further, it is important to note that South Africa is a member of BRICS and a leadingmember of the African Tax Administration Forum (ATAF). As such, the country plays a cen-tral role in driving an increasingly aggressive approach to the taxation of multinationals, espe-cially in Africa. Understanding the changing global dynamics and tax policies, the perspectiveof developing countries and the local realities of jurisdictions in which multinationals do busi-ness is key to managing global tax risk. Tax has been catapulted to centre stage in the globalcommercial world, and is a key consideration in managing corporate, reputational and com-mercial risk. It is essential for boards of directors and key executive decision makers to under-stand the dynamic change in the fiscal world and to incorporate the lessons learnt from thedefence of structures into the planning of resilient future transactions and business models.Due to his thorough understanding of these critical issues and his significant experience,Bernard is able to assist clients with all of their international tax and tax controversy needs.

South Africa

Bernard du Plessis

ENSafrica

150 West StreetSandtonJohannesburg2196South Africa

Tel: +27 83 458 2161Email:[email protected] Website: www.ENSafrica.com



Louise Vosloo, Deloitte South Africa, is a lead director of inter-national tax based in the Woodlands office. She has more than21 years of experience at Deloitte in taxation. She specialises inassisting a variety of listed companies and their subsidiaries, aswell as multinational enterprises with a wide variety of tax mat-ters. She has experience in financing schemes, mergers andacquisitions, restructuring and structuring of inbound and out-bound investments and dispute resolutions.

She is the lead tax director for major listed groups, many ofthem being JSE Top 100 companies.

Prior to joining Deloitte South Africa in the tax department,Louise gained valuable tax experience during the course of heremployment as a tax advocate appearing for the Commissionerfor the South African Revenue Service (SARS) against seniorcounsel. She continues to assist clients with disputes involvingSARS.

South Africa

Louise Vosloo

Deloitte South Africa

Deloitte Place, Building 5The Woodlands20 Woodlands DriveWoodmead, 2052South Africa

Tel: +27 (0) 11 806 5360Main: +27 (0) 11 806 5000 Mobile: +27 (0) 83 632 1835Email: [email protected]: www.deloitte.com



South Africa

Emil BrinckerCliffe Dekker Hofmeyr

Christel BritsEY

Paul de ChalainPwC

Andre MeyburghKPMG

Muhammad SaloojeeKPMG

Johan van der WaltKPMG



Sang Hoon Baek, Deloitte Korea, is a tax partner based inSeoul. He has broad experience in advising international anddomestic companies. His US tax experience obtained whileworking in New York and studying US tax law at Duke Uni -versity, combined with in-depth experience gained from work-ing with multinational enterprises and tax practices at the lawoffice of Kim & Chang, allows him to offer foreign and domes-tic clients reliable and business-oriented tax advice.

Sang Hoon’s major works in recent years include advising onprivate equity fund investments, structuring of tax-free reorgan-isations, international inbound/outbound tax planning, andfinancial products. Sang Hoon has made a significant contribu-tion to winning the largest tax dispute in Korea (the potentialtax assessment at stake was $1 billion) in 2008. He is a lead taxpartner for Hyundai/Kia Motors Group.

South Korea

Sang Hoon Baek

Deloitte Korea

4F., One IFC10, Gukjegeumyung-roYoungdeungpo-gu, Seoul, 07326Korea




Sunyoung (Sunny) Kim, Deloitte Korea, is a senior tax partnerat Deloitte Anjin, leading the global tax practice. Sunyoung,who has close to 20 years of experience at both accounting andlaw firms, has provided various types of tax consulting servicesfor many multinational enterprises in Korea, as well as US andEuropean multinational enterprises. She specialises in interna-tional tax issues, tax efficient restructuring, cross border M&Asand tax audit defence and appeal, taking an active leading rolein the assignments that require long hours, tight deadlines,effective teamwork and liaison with client and other professionaladvisers. She also has extensive experience dealing with complextax controversy issues from corporate restructuring transactionsof multinational enterprises and controversy issues for high-networth individuals.

She has served as a committee member at the Ministry ofStrategy and Finance (MOSF), advising on legislation for part-nership taxation, the consolidated tax return system, and tax-free reorganisations since 2005. She is a member of the MOSFnational tax ruling committee and tax development committee.She has earned a PhD at Seoul National University School ofLaw and a LLM in taxation from the NYU School of Law. She is also a licensed CPA.

South Korea

Sunyoung Kim

Deloitte Korea

4F., One IFC10, Gukjegeumyung-roYoungdeungpo-gu, Seoul, 07326Korea

Tel: 82 2 6676 2471Fax: 82 2 6674 2510Email: [email protected]: www.deloitte.com



Dr Tae-Hyung Kim, Deloitte Korea, is a senior partner and themanaging partner in charge of clients and industries pro-grammes. For more than eight years, Tae Hyung has held thenational leadership position in the area of transfer pricing atDeloitte Korea. For almost 20 years, he has advised multina-tional enterprises in various industries on their global transferpricing and value chain management strategies. In so doing, hehas handled complex transfer pricing disputes and negotiationswith both Korean and foreign tax authorities.

Tae Hyung has contributed articles to professional journalssuch as International Tax Review, IBFD International TransferPricing Journal, Bloomberg BNA International Transfer PricingForum, Bloomberg BNA Tax Management Transfer Pricing Re -port, and Euromoney’s Transfer Pricing Review. His econo micspublications also appear in the Canadian Journal of Econo micsand Review of International Economics.

He holds a PhD in economics from the University of Wash -ing ton and is also a graduate of the advanced management pro-gramme of Harvard Business School. He graduated from KoreaUniversity with a BA in economics.

South Korea

Dr Tae Hyung Kim

Deloitte Korea

9F, One IFC Bldg, 23 Yoi-dongYoungdeungpo-guSeoul 150-876Korea

Tel: +82 2 6676 2410Email:[email protected] Website: www.deloitte.com



Jee Won Kwon, Deloitte Korea, is a tax partner at the Seouloffice. He has almost 18 years’ experience providing tax con-sulting services to local and foreign multinational companies inthe telecommunications, energy and manufacturing industries.

Jee Won has extensive experience assisting with the introduc-tion of legislation concerning new tax incentive programs, forexample, the new tax incentives applicable to photovoltaicindustries, 2012 EXPO events, among others. Jee Won also hasextensive experience dealing with complex tax controversyissues arising from corporate restructuring transactions (forexample, spin-offs and mergers) executed by domestic compa-nies. He has recently assisted with resolving significant tax con-troversy issues challenged by the Korean tax authorities in con-junction with a qualified vertical spin-off transaction and amerger.

Jee Won received his undergraduate degree in businessadministration from Seoul National University in 1995, and healso studied business at the Seoul National University graduateprogramme for two years. He has recently served as a memberof the national tax research committee of the Korean Instituteof Certified Public Accountants.

South Korea

Jee Won Kwon

Deloitte Korea

4F, One IFC Bldg, 10Gukjegeumyung-ro,Youngdeungpo-guSeoul 150-876Korea




Nam Hyuk Park, Deloitte Korea, has a combined 20-plus yearsof tax related experience in public offices including the NationalTax Service, National Tax Tribunal, and the Tax Systems Officein the Ministry of Strategy and Finance. His specialised experi-ence includes working in tax appeals with the Seoul High Courtof Justice and National Tax Tribunal.

He has advised a number of clients across multiple industriesover the years.

He is a graduate of the Sungkyunkwan University and Uni -ver sity of Colorado at Denver, and passed the civil administra-tion exam ination (29th) in 1985.

South Korea

Nam Hyuk Park

Deloitte Korea

4F, One IFC Bldg, 23, Yoido-dong,Youngdeungpo-guSeoul, Seoul 150-876Korea




Jeong Soo Tak, Deloitte Korea, is a tax partner who is an expertin M&A transaction services and international tax issues. He hasrendered consulting services to various multinational enterprisesand domestic companies. His experience includes tax consulta-tions on foreign investment (including investments in realestate), M&A, cross-border transactions, tax compliance, taxaudit support, due diligence, tax exemption applications, and allother Korean tax matters affecting international companiesfrom establishment to exit. He also completed a one-year inter-national tax assignment with Arthur Andersen in New Yorkwhen he was working with the law firm.

As a member of the global special acquisition service group,Jeong Soo has been involved in many of the private equityinvestments made by foreign multinationals, including the pur-chase of Haitai Confectionary by the JPMP Consortium,Himart by Affinity Equity Partners, Mando Climate Control bythe UBS Consortium, Ssangyong by Morgan Stanley, OB Beerby KKR and Affinity Equity Partners.

He also has extensive experience of successful resolutions fortax controversies in conjunction with investment restructuringmade by multinational enterprises and showed significantachieve ments in the area of tax controversies involving capital gains tax and beneficial own-ership issues for the private equity firms’ investment in Korea during the last decade.

Jeong Soo graduated with a degree in business administration from Korea University. Heis a member of the Korean Institute of Certified Public Accountants and passed the AICPAexamination in the State of Maine.

South Korea

Jeong Soo Tak

Deloitte Korea

5F, One IFC10, Gukjegeummyung-roYoungdeunpo-guSeoul, 07326Korea




South Korea

Henry AnPwC

Jeong Wook ChoiKPMG

Dong Chul KimEY

Min Yong KwonEY

Michael QuigleyKim & Chang



José Manuel de Bunes, Deloitte Spain, joined in 2014, as a part-ner in the VAT, duty and indirect tax sector, enhancing at thesame time the company’s advisory services in the Valencia com-munity.

A graduate in law from the Complutense University ofMadrid, José Manuel is a state tax inspector.

He formerly developed his career at the tax governmentbetween 1984 and 2008, where he held several important posi-tions such as the deputy director of VAT (2000-04), becomingthe director general for taxation (2004-08). He subsequentlyentered Arco Abogados y Asesores Tributarios law firm as a taxpartner, where he developed a successful career in tax advisory.

He has broad teaching experience in centres like the PublicFinance Minister School (Escuela de la Hacienda Pública),University Studies Centre (Centro de Estudios Universitarios),and two postgraduate centres affiliated with the University ofValencia (Fundación Universidad – Empresa de la Universidadde Valencia and Estema). He has also written numerous booksconcerning tax law.

Spain

José Manuel de Bunes

Deloitte Spain

Torre Picasso, Plaza Ruiz Picasso 128020, MadridSpain

Tel: +34 915368037Fax: +34 914381004Email: [email protected]: www.deloitte.com



Juan Ignacio De Molina (also named, Willy), Deloitte Spain,joined in 2009 as transfer pricing partner in the international taxgroup. He has over 18 years of experience working with largemultinationals in the transfer pricing and international tax fields.From 1997 to 2009, he worked at another Big 4 firm in theirBarcelona and New York offices. As leader of the transfer pric-ing practice, Willy manages a team of 60 professionals in fiveoffices (Barcelona, Madrid, Sevilla, Bilbao, and Vigo).

He is specialised in tax efficient supply chain managementstructures, global transfer pricing projects, valuation of intangi-bles, business restructuring, financing structures, R&D and ITlicensing. He also specialises in advisory services in the contextof tax audits, advance pricing agreements (APAs), and mutualagreement procedures (MAPs). Willy has experience, amongstothers, in the following fields for transfer pricing projects: bank-ing, insurance, pharmaceutical industry, real estate, chemicalindustry, auto industry, software, energy (including renewable),manufacturing and consumer products.

His practice was listed by International Tax Review as thebest transfer pricing practice in Spain for 2009, 2010, 2011, and2016, and has been included in ‘Best Lawyers’ Spain in 2014.

Willy studied economics at the University of Barcelona. He has an MBA from the PompeuFabra University, a postgraduate course in business valuation from NYU (New York) and amanagement development programme from IESE.

Spain

Juan I (Willy) De Molina

Deloitte Spain

Av. Diagonal 654, 08034BarcelonaEspaña

Tel: +34 932304804Mobile: +34 608624064 Email: [email protected]:www.deloitteabogados.es



Ricardo Gómez-Acebo, Deloitte Spain, has been a partner since2005. He is a lawyer and economist (Spanish universities) andhas an MPA from Harvard University. Previously he was withthe Ministry of Economy and Finance, where he held the posi-tion of finance inspector.

Ricardo is in charge of the tax professional committee andadvises his clients, mainly in the corporate and international tax-ation areas, as well as on litigation and procedures before the taxadministration. His main clients are large companies in the ener-gy, infrastructure, real estate and services industries.

Ricardo is a member of the: Tax Commission of the SpanishConfederation of Business Organisation; Board of the Impuestosy Competitividad foundation, promoted by the eight largestSpanish tax firms; Madrid Economists Association and SpanishOfficial Auditors Register (ROAC).

He is very active in terms of publications and teaching. Inthis sense, he is co-director of the four editions of the book‘Juris prudencia Tributaria Básica’. Additionally, he is a lecturerin the master’s programme in taxation at ICADE and, formerly,at CEU and the Institute for Fiscal Studies. He is also a regular speaker at seminars organisedby different institutions including: the European Commission; the World Bank; the Inter-American Bank for Develop ment; the Institute for Fiscal Studies; and APD or Expansion.

Spain

Ricardo Gómez-Acebo

Deloitte Spain

Plaza Pablo Ruiz Picasso1 – Torre PicassoMadrid 28020Spain

Tel: +34 914432000Email: [email protected]: www.deloitte.com



Juan Manuel Herrero de Egaña, Deloitte Spain, joined the taxand legal department as a partner in 2015. He specialises in taxand judicial review proceedings.

Before joining the firm, he held various positions as a gov-ernment lawyer with the law courts and the tax authorities. Hewas head of the state legal service at the Superior Court ofNavarra (1988), Catalonia (1992) and at the Court of Auditors(1996). Since 2002, he has worked as a government lawyer forthe tax authorities, holding the positions of chief governmentlawyer at the Madrid Tax Office (2002), chief governmentlawyer at the Central Delegation of Large Taxpayers (2006),and director of the State Tax Administration Agency (2010–15).

Juan Manuel has written various scientific publications onadministrative law and tax matters. He has also been an associateprofessor at Autonomous University of Barcelona and RealCentro Universitario María Cristina. He has been a teacher onthe IE Business School’s master’s degree course on tax coun-selling.

Juan Manuel holds a law degree from Universidad Comp -lutense de Madrid (1986) and is a non-resident member of theSpanish Royal Academy of Jurisprudence and Legislation.

Spain

Juan Manuel Herrero de Egaña

Deloitte Spain

Torre Picasso – Plaza Pablo RuizPicasso 128020 MadridSpain

Tel: +34 915820900Fax: +34 914381004Email:[email protected] Website: www.deloitte.com



Ramón López de Haro, Deloitte Spain, is a transfer pricingpartner, leading the practice in the Madrid office. Ramón hasover 20 years of experience working with multinational enter-prises on complex international tax, transfer pricing, and supplychain management processes. He has coordinated and directedlarge international and transfer pricing projects in large multina-tionals belonging to different industries, including telecom,energy and resources and hospitality and leisure.

Ramón is specialised in transfer pricing controversy, coordi-nating professionals with a tax and a financial background work-ing together in the defence of complex transfer pricing mattersand business restructurings vis-à-vis the tax authorities and judi-cial courts. He has also great experience in the negotiation ofbilateral and multilateral APAs and the resolution of MAPs. Heis fluent in Spanish, French, English, and German.

During the past two consecutive years, Ramon has beenawarded with the prestigious prize of ‘Best Lawyers’ in Spain onthe category of tax and transfer pricing. He is a frequent speakerin expert forums, including the Spanish Association of TaxAdvisers (AEDAF), the Brands of Spain Association (AEMR)and the Association of Business Organisations (CEOE). In the international field, he partic-ipated in the first discussions of the EU joint transfer pricing forum and has lectured, amongothers, at the International Fiscal Association and the American Bar Association.

Spain

Ramón López de Haro

Deloitte Spain

Plaza de Pablo Ruiz Picasso 1Torre PicassoMadrid 28020Spain

Tel: +34 606413842+34 915820900

Email: [email protected]: www.deloitte.com



Alejandra Puig, Deloitte Spain, is a lawyer and member of theMadrid Bar Association. She specialises in representing clientsbefore the Spanish tax authorities and in coordinating complextax audits for multinational corporations. Alejandra also has sig-nificant experience in handling negotiation for complex tax dis-putes.

Alejandra regularly represents clients at all stages of the dis-pute process, including litigation before the Spanish SupremeCourt and supporting and negotiating settlements.

She helps clients to efficiently resolve their tax dispute, assist-ing to negotiate favourable settlements with the tax authoritiesor, when necessary, by bringing appeals to the courts.

For more than 20 years, Alejandra has represented clients ina variety of industries, including financial services, manufactur-ing, pharmaceuticals, consumer products, media, and retail.

Alejandra also has significant experience in Spanish penaltyprocedures and has both spoken and written extensively withrespect to numerous Spanish procedural issues.

Alejandra has a master’s in European law from Granada Uni -versity and she is a professor in several Spanish master’s programmes for new tax lawyers.

Spain

Alejandra Puig

Deloitte Spain

Plaza Pablo Ruiz Picasso, 1Madrid 28020Spain

Tel: +34 915820900 ext. 1662Email: [email protected] Website: www.deloitte.com



Luis Enrique, Deloitte Spain, has been a partner since 2012. Hecoordinates the tax controversy and litigation specialised areafor the northwest region of Spain.

As a lawyer and a member of the Vigo Bar Association formore than 15 years, Luis Enrique’s professional career hasincluded his participation in and coordination of tax audits, taxlitigation and judicial proceedings, tax due diligence, tax plan-ning acquisitions and advising on family businesses’ tax projects.His clients operate in a wide range of industries and sectors,including automotive, fishery, construction, textiles, finance andmedia.

Luis Enrique holds a law degree from the Universidad deNavarra and a master’s degree in taxation from the Instituto deEmpresa.

He has published several articles and has co-written bookson tax controversy and litigation.

Luis Enrique is a professor of taxation and tax procedure atIFFE Business School.

Spain

Luis Enrique Rodriguez Otero

Deloitte Spain

Avenida Garcia Barbon, 106Vigo, Galicia 36201Spain

Tel: +34 914432000Email:[email protected]: www.deloitte.com



Enrique Seoane, Deloitte Spain, has been a partner in the taxdepartment since 2014.

He has extensive professional experience developed inAgencia Estatal de Administración Tributaria (state tax admin-istration agency), where he held the position of deputy chiefinspector in Unidad Provincial de Inspección de Barcelona andUnidad Regional de Recaudación Ejecutiva de Cataluña.Furthermore, he has carried out tasks as an inspector assignedto the National Office of Inspection.

Enrique has occupied several management positions inAgencia Estatal de Administración Tributaria, such as AEATadmin istrator in Terrassa and Sabadell (Barcelona) between2001 and 2006, chief of Unidad Regional de Gestión deGrandes Empresas (regional unit of big companies); and inspec-tor assigned to Dependencia Regional de Inspección de Cataluña(regional inspection unit of Cataluña), between 2006 and 2014.

Enrique is a frequent contributor for courses, lectures, mas-ters and seminars organised by several public and private enti-ties, such as Colegio de Economistas de Cataluña, Colegio deAbogados in Barcelona and Sabadell, Official Chambers of Commerce of Sabadell andTerrassa, Asociación Profesional de Expertos Contables y Tributarios de España, EADA, ESADEand Escuela de Hacienda Pública del Ministerio de Hacienda, among others.

Spain

Enrique Seoane Smith

Deloitte Spain

Avenida Diagonal, 654Barcelona, Cataluña 08034Spain

Tel: +34 932543934Email: [email protected]: www.deloitte.com



Spain

Pedro AguarónBaker & McKenzie

María Antonia AzpeitiaBaker & McKenzie

Ernesto BenitoPwC

Luis BrionesBaker & McKenzie

Javier Gonzalez CarcedoPwC

Julio César GarciaKPMG

Abelardo Delgado PachecoGarrigues

Santiago DíezMarimon Abogados

Bruno DominguezBaker & McKenzie

Rafael FusterUría Menéndez

Javier Garcia-PitaLinklaters

Angel Garcia RuizGarrigues

Jose Maria Garcia-Valdecasas AllozaBalaguer Morera & Garcia Del Rio

Eduardo GardetaGarrigues

Agnès GranésCuatrecasas

José Ignacio Guerra GarciaGarrigues

Alberto HerasRamón y Cajal

Maximino LinaresEY

Jesús López TelloUría Menéndez

Miguel LoránOsborne Clarke



Spain

Antonio PuentesPwC

Esteban RaventósBaker & McKenzie

Carlos Reviriego GomezPwC

Ana RoyuelaBaker & McKenzie

Manuel SaezCasals Abogados

Raúl SalasBaker & McKenzie

Manuel Santa-MaríaGarrigues

Montserrat TrapeKPMG

José Vicente IglesiasGarrigues

Esther Zamarriego SantiagoGarrigues

Adolfo ZunzuneguiEY



Thomas Andersson, Deloitte Sweden, is a partner and memberof the corporate tax team. Thomas has more than 24 years ofprofessional experience in tax, both as a tax adviser and as a taxinspector. Before joining Deloitte Sweden in 2000, he workedwith EY and the Swedish Tax Agency.

Thomas’ practice mainly involves tax engagements for largergroups of companies. He works with large global clients, bothoutbound and inbound. His major projects have includedextensive local and international restructuring services and tax-driven transactions, mergers and services.

Thomas was listed in Euromoney’s guide to the world’s lead-ing tax advisers in 2008, 2010 and 2012. In August 2012,Thomas was named by International Tax Review as one of theworld’s top tax controversy leaders.

Thomas holds a master’s degree in business administrationand accounting. He is a member of the advisory board to theTax Academy (The Faculty Course Foundation at the Stock -holm University) and of the editorial committee of The SwedishTax Magazine (Svensk Skattetidning). He is a frequent lecturerand panel member at seminars and courses held at the Stockholm University.

Sweden

Thomas Andersson

Deloitte Sweden

Rehnsgatan 11Stockholm, 113 79Sweden

Tel: +46 75 246 21 11 /+46 733 97 21 11

Email: [email protected]: www.deloitte.se



Myléne Beiming is a partner at PwC in Stockholm, Sweden. Sheis a lawyer with more than 25 years of professional experienceworking with corporate income tax matters, assisting multina-tionals and middle market corporate clients on structuring,M&A and general domestic and international tax planning.

Myléne is highly experienced with working with majorSwedish multinationals and has wide experience in assistingclients in tax disputes and litigations. She has been previouslynamed in International Tax Review’s Tax Controversy Leadersguide.

Before joining PwC, Myléne worked at the AdministrativeCourt of Appeals as a judge. She obtained a Master of Lawsdegree from the University of Stockholm in 1991.

Sweden

Myléne Beiming

PwC Sweden

SE-113 97 StockholmSweden

Tel: +46 10 21 33 165Email:[email protected]:www.pwc.com/taxcontroversy



Ulrika Bengtsson, Deloitte Sweden, leads the tax controversyteam and has 26 years of experience in controversy services. Shejoined Deloitte in 2012.

Before joining Deloitte, Ulrika was an expert in tax penaltiesand tax controversy proceedings at the legal department of theSwedish tax agency.

Ulrika has wide-ranging experience in tax controversy mat-ters. Primarily, she assists clients with tax litigation matters incourt. She also assists clients with tax disputes and tax audits.Ulrika has a broad background and has dealt mainly with cor-porate tax matters, but also with VAT matters involving tax con-troversy.

During her studies, Ulrika worked as a legal trainee inLondon. After receiving her LLM from the University ofUppsala she started her career at the District Court ofLinköping, after which she worked with a major Swedish lawfirm. During her years at the Swedish tax agency, she workedmainly as an expert, a role which included litigation, developingtrainings, giving internal and external presentations, deliveringtutorials and providing legal advice to the tax agency.

Ulrika is a member of the board of the Institutet för Skatter & Rättssäkerhet (the Instituteof Taxes & Legal Certainty, which is a non-profit organisation aiming to promote better legalcertainty in tax for individuals and companies). Ulrika is also a frequent lecturer and panelmember at seminars and conferences.

Sweden

Ulrika Bengtsson

Deloitte Sweden

Rehnsgatan 11113 79 StockholmSweden

Mobile: +46 700 80 22 65Direct: +46 75 246 22 65Email: [email protected]: www.deloitte.se



Mac Berlin is the managing partner of Skeppsbron Skatt, lead-ing independent firm of tax advisers in Sweden.

Mac has wide experience advising clients across a broadrange of issues and he brings a long experience in Swedish andinternational corporate taxation, predominantly working withM&A and real estate related matters, as well as with tax disputesand tax audits.

Mac has previously worked in a Big 4 firm. He has a master’sdegree in law.

Sweden

Mac Berlin

Skeppsbron Skatt – Taxand

Skeppsbron 20111 30 StockholmSweden

Tel: +46 73 640 91 55Email:[email protected]: skeppsbronskatt.se



Lars Franck, Deloitte Sweden, is a tax partner and leads the cor-porate tax practice. With more than 20 years of Swedish andinternational tax experience, Lars has a broad depth of experi-ence on complex tax issues relating to cross-border transactions,cash repatriation, financial and international tax planning. Hespecialises in planning, implementing and evaluating cross-bor-der mergers and acquisitions and intra-group restructurings.

Lars earned his LLM from the University of Gothenburg in1995, is a certified tax adviser by FAR, the institute for theaccountancy profession in Sweden, and is a member of theInternational Fiscal Association.

Sweden

Lars Franck

Deloitte Sweden

Rehnsgatan 11SE-113 79 StockholmSweden

Tel: +46 75 246 21 26+46 75 246 24 01




Magnus Larsén is a corporate tax partner at Skeppsbron Skatt.He is a lawyer and has 20 years of experience working in the

field of Swedish and international taxation.Magnus brings a long experience in corporate and interna-

tional tax advisory, with deep expertise in international struc-tured financial transactions and mergers and acquisitions(M&A).

He deals with companies in most sectors, specialising partic-ularly in the banking, large corporate and private equity indus-tries.

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. His back-ground also includes working in tax court and at a Magic Circlelaw firm in London.

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



Tel: +46 73 640 91 52Email: [email protected]: skeppsbronskatt.se



Magnus Larsson, Deloitte Sweden, is the lead partner and leaderof the compliance and reporting services team, based in theStockholm office. Magnus has more than 20 years of experiencein tax services, having joined Deloitte in 1989.

Magnus has wide-ranging experience serving multinationalclients and their subsidiaries in Sweden and abroad. He assistsclients with regard to mergers, acquisitions, restructuring andtax due diligence. Magnus’ experience covers a wide range ofsectors and industries. He is now focused primarily on mattersrelated to domestic and international corporate tax law as wellas general tax consultation. His expertise includes high-level taxconsultancy for clients doing business in the consumer, energyand resources, manufacturing, real estate and technology, mediaand telecommunications (TMT) industries.

Magnus’s role as a judge at the Administrative Court ofAppeals also added to his extensive experience in tax litigation.

Recent major projects include: extensive specialisation ininbound investments (Sweden and EU countries); extensivelocal and international restructuring services; and due diligenceand tax planning acquisition services.

Magnus is a member of the General Committee at FAR, the institute for the accountancyprofession in Sweden. He has a master’s degree in law.

Sweden

Magnus Larsson

Deloitte Sweden

Rehnsgatan 11Stockholm, 113 79Sweden

Tel: +46 75 246 21 09 /+46 733 97 73 17




Mika Myllynen is the co-leader of the PwC tax practice in Stock -holm. He was the Swedish transfer pricing country leaderbetween 2007-2014. He is the lead tax and transfer pricingpartner for some of the Swedish tax practice’s largest clientswhich he serves through a well-established global network.

Mika has been with PwC for 13 years and his assignmentshave included a vast variety of engagements, ranging from com-mon compliance to complex transformation projects, tax con-troversy and dispute resolution.

He has a master’s degree in commercial and tax law fromJönköping International Business School, Sweden, 1998.

Sweden

Mika Myllynen

PwC

Torsgatan 21113 97 StockholmSweden

Tel: +46 (0)10 2133 876Mobile: +46 (0)709 293 876Email:[email protected]:www.pwc.com/taxcontroversy



Lennart Staberg is a lawyer and has been practising for approx-imately 20 years as a professional tax adviser.

He has extensive experience of Swedish and internationalcorporate taxation. His area of work includes handling tax dis-putes and resolving tax audits.

Lennart’s earlier work history includes positions as assistantjudge in civil courts as well as in tax courts, and as a directorwith the National Board for Advance Tax Rulings.

Lennart has on several occasions been named one ofSweden’s leading tax advisers in the independent survey of taxadvisers undertaken by International Tax Review.

He obtained a Master of Laws degree from the University ofUppsala in 1986.

Sweden

Lennart Staberg

PwC

(Visiting address: Torsgatan 21)SE-113 97 StockholmSweden




Pär Magnus Wiséen is a tax partner and the national leader ofthe Swedish transfer pricing practice within PwC.

Before joining the tax and transfer pricing practice in 2002,Pär Magnus worked within the corporate finance practice as amergers and acquisitions specialist.

Pär Magnus continuously advises some of the largestSwedish-based multinationals on their global tax planning inSweden and abroad as well as assisting foreign-based multina-tionals on various transfer pricing issues in Sweden, includingtax planning, documentation, business restructuring, APAs,MAPs, tax audits and litigations.

In the past couple of years Pär Magnus has devoted moreand more of his time to complex dispute resolution activitiessuch as the negotiations of APAs, tax audits and litigations. Hisarea of competence covers complex transfer pricing related dis-putes such as business restructurings, IP transfers and valuationissues as well as financial transactions. Not only does PärMagnus specialise in tax audits and litigations, but he also worksextensively with global documentation and value chain transfor-mation projects.

Pär Magnus is a certified tax adviser in Sweden and holds aMaster of Laws degree, as well as a master’s degree in business administration and economics.Both degrees were from Uppsala University.

Sweden

Pär Magnus Wiséen

PwC

Torsgatan 21113 97 StockholmSweden

Tel +46 8 555 332 95Fax: +46 70 929 32 95Email:[email protected]:www.pwc.com/taxcontroversy



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 a broadrange of sectors. As a professional tax adviser he has alwaysfocused on assisting clients in tax disputes and tax audits. He isoften engaged in complex major disputes and has representedclients successfully in some of the most substantial tax cases inSweden.

For six 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



Tel: +46 73 640 91 53Email: [email protected]:www.skeppsbronskatt.se/en/business-areas/tax-litigation



Sweden

Hans EklundKPMG

Per HolstadSkeppsbron Skatt - Taxand

Erik HultmanEY

Magnus JohnssonPwC

Katarina KuuskoskiChouette

Bo LindqvistBaker & McKenzie

Peter NordquistPeter Nordquist Advokatbyrå



Peter Brülisauer, Deloitte Switzerland, has extensive experiencein providing tax advisory services to multinational enterprises.His tax experience comprises corporate restructuring, acquisi-tion, finance restructuring, IP and R&D planning, internationalcross-border tax planning, tax effective supply chain manage-ment, as well as function and risk allocation within multination-al groups. In addition, he advises on permanent establishmentplanning and profit attribution between permanent establish-ments.

Peter is a lecturer for national and international taxation ofthe University of St Gallen and University of Zurich and a fre-quent speaker at tax conferences. He writes commentaries onnational and international corporate taxation, particularly ondetermination and profit allocation of corporations and perma-nent establishments.

Peter has strong and extensive contact with the federal taxauthorities, the Cantonal tax authorities and the State Secretar -iat for International Financial Matters (SIF). He is member ofthe working group for Corporate Tax Reform III and of the SIFBEPS group.

Peter has a PhD in law from the University of St Gallen and is a Swiss certified tax expert.

Switzerland

Peter Brülisauer

Deloitte Switzerland

General-Guisan-Quai 388022 ZürichSwitzerland




Sarah Dahinden is a senior manager at PwC in Switzerland’s taxservices practice. As a lawyer, she regularly and successfullyassists clients in tax litigation cases.

After passing the law and the attorney-at-law degree, Sarahwrote her thesis in international tax law, concerning tax shelter-ing of foreign companies. Subsequently, she passed the exam forcertified tax experts.

Before joining PwC in 2007, Sarah worked at a districtcourt, at the University of Zurich (dealing with tax law), at twoof the bigger law firms in Zurich and in the legal department ofthe tax authority of the canton of Zurich.

Sarah renders services in different tax fields, usually with aclear focus on legal procedures and tax litigation in the corpo-rate tax field. Sarah is a member of the International FiscalAssociation (IFA). She is fluent in English.

Switzerland

Sarah Dahinden

PwC

Birchstrasse 160CH – 8050 ZürichSwitzerland




Jean-Blaise Eckert is a partner at Lenz & Staehelin and co-headof the tax group. His practice areas include tax, private clients,contract law and commercial.

He speaks French, English and German. Jean-Blaise studiedlaw at the University of Neuchâtel and was admitted to the Barof Neuchâtel in 1989 and to the Bar of Geneva in 1991. Hestudied business administration at Berkeley, Haas BusinessSchool, where he acquired an MBA in 1991. He received hisdiploma as a certified tax expert in 1994 and is a certified spe-cialist in inheritance law.

Jean-Blaise is considered as a leading lawyer in Switzerland.He advises a number of multinational groups of companies, aswell as HNWIs. He sits on the board of a number of public andprivate companies. He has been nominated by Chambers in2015 as a leading individual in tax. Jean-Blaise is a frequentspeaker at professional conferences on tax matters. He alsoteaches in the masters programmes of the University of Lau -sanne. Jean-Blaise is deputy secretary general and member ofthe executive committee of the International Fiscal Association(IFA).

Switzerland

Jean-Blaise Eckert

Lenz & Staehelin

Route de Chêne 30CH-1211 Geneva 17Switzerland

Tel: +41 58 450 70 00Fax: +41 58 450 70 01Email: [email protected]: www.lenzstaehelin.com



Niklaus Honauer is a partner at PwC in Switzerland’s tax serv-ices practice. He regularly and successfully assists clients in taxlitigation.

After completing his law degree and the attorney-at-law,Niklaus joined PwC in 1990 as partner and leader of the SwissVAT team. In 2000, he became a member of the competencecentre for indirect taxes of the Swiss Chamber of Tax Advisers,which he leads as president. Since 2001, he has been a memberof the indirect tax leading team within PwC.

Niklaus has been a tax and legal consultant for nearly 30years. He consults for both multinational and mid-sized enter-prises in all kinds of indirect tax issues. He is one of the leadingindirect tax consultants in Switzerland and is well known in theindustry and the tax administration.

With his position as a member of the indirect tax leadingboard in Europe, he has a direct link to all PwC indirect taxpartners all over the world.

Niklaus’s mother tongue is Swiss German. He speaks Englishand French fluently.

Switzerland

Niklaus Honauer

PwC

Birchstrasse 160CH – 8050 ZürichSwitzerland




Benjamin leads the transfer pricing and value chain transforma-tion practice of PwC Switzerland.

Before joining PwC, Benjamin gained diversified interna-tional management experience in finance as controller and CFOof companies in the pharmaceutical R&D and pharmaceuticaldistribution industry, the telecommunications sector, and theconstruction industry. He also gained international experienceas a senior consultant for M&A and equity finance.

Benjamin’s experience includes advising multinational enter-prises on the structuring of global manufacturing and distribu-tion, development of global core documentation, migration ofintangible property, establishing global trademark royaltyschemes and the development of service fee concepts. Benjaminhas successfully implemented various value chain/businessmodel transformation projects including post-merger integra-tion.

Benjamin also has substantial experience assisting companiesin preventing tax audits and managing international tax contro-versies through the proactive use of advance pricing agreements(APAs), tax rulings and mutual agreement procedures (MAPs).Benjamin is PwC’s Swiss territory leader for tax controversy and dispute resolution.

In his capacity as an experienced transfer pricing partner, he is representing PwCSwitzerland in the technical working groups of the Swiss Corporate Tax Reform III.

Benjamin holds an MBA from the University of Rochester and is fluent in German andEnglish.

Switzerland

Benjamin Koch

PwC

Birchstrasse 160Ch-8060 ZurichSwitzerland




Ferdinando Mercuri, Deloitte Switzerland, is a tax partner andis a certified tax expert. He has broad experience in all taxationmatters and has been advising both corporations and individualsfor more than 18 years.

Ferdinando serves several large listed and non-listed compa-nies in Switzerland, providing them with meaningful advice andsupport in relocation, mergers and acquisitions, due diligenceand compliance duties. He is in charge of individual clients, par-ticularly in the field of private equity and hedge funds, and is theFSI tax leader for the French and Italian speaking parts ofSwitzerland.

Ferdinando holds a law degree from the University ofLausanne. He teaches tax law in Western Switzerland and isresponsible for the international tax module for the French partof the Swiss Tax Academy. He is also a frequent speaker at sem-inars on tax matters and has held numerous presentations andwritten several articles covering Swiss outbound investmentsand cross-border structuring, tax planning, dividend stripping,and financing.

Switzerland

Ferdinando Mercuri


Avenue de Montchoisi 15P.O. Box 4601001 LausanneSwitzerland

Tel: +41 58 279 9242Fax: +41 58 279 9300Email: [email protected]: www.deloitte.ch



René Schreiber, Deloitte Switzerland, is a corporate interna-tional tax partner and the outbound tax leader.

René has advised many leading Swiss multinationals. Hispro jects include advising on international structuring andfinancing matters as well as cross-border reorganisations. Headvises clients across manufacturing, energy and resources andbiotechnology industries in all aspects of tax controversy mat-ters including preparation of appeals against tax assessments andassisting with tax audits and complex tax ruling proceedings.His client portfolio consists of large Swiss-based multinationalsand well-established entities in the mid-market.

René is a Swiss certified tax expert, attorney-at-law and has adiploma in law (lic-iur) from the University of Bern.

He is a member of the study commission and lectures oninter national tax law at the Schweizerisches Institut für Steuer -lehre (SIST) in Zurich for the master of advanced studies in tax-ation/LLM programme. René is also a frequent speaker atnation al and international tax conferences and has publishednumerous articles in the field of corporate and international tax-ation.

Switzerland

René Schreiber


General Guisan-Quai 388022 ZurichSwitzerland

Tel: +41 58 279 7216Email: [email protected]: www.deloitte.ch



Raoul Stocker, Deloitte Switzerland, has broad experience in alltaxation matters and has been advising both corporations andindividuals for more than 15 years. He focuses on corporate taxplanning, cross-border structuring of corporate transactions andbusinesses, transfer pricing, as well as taxation of financial insti-tutions. He is specifically experienced in international tax litiga-tion such as mutual agreement procedures and advance pricingagreements.

Raoul Stocker is assistant professor for taxation (in particularfor corporate taxation) at the University of St Gallen and a fre-quent speaker at tax conferences. He publishes articles in numer-ous national and international tax journals.

From 2003 to 2008, Raoul Stocker was head of transfer pric-ing at the Swiss Federal Tax Administration, where he was res -ponsible for MAP and APA negotiations in transfer pricing mat-ters.

Switzerland

Raoul Stocker


General Guisan Quai 388022 ZurichSwitzerland

Tel: +41 58 279 6271Fax: +41 58 279 6600Email: [email protected]: www.deloitte.ch



Switzerland

Denis BerdozBaker & McKenzie

Harun CanSchellenberg Wittmer

Marcus DesaxWalder Wyss

Pierre GilliozGillioz Dorsaz & Associés

Pierre-Marie GlauserOberson Abels

Hans KochBaker & McKenzie

Xavier ObersonOberson Abels

Per Prod’homPython

Markus WyssKPMG



Robert Chen, Deloitte Taiwan, is a tax partner of the Taipeioffice. He joined Deloitte & Touche in 1995 and has servedboth the audit and tax functions. He has extensive experience inproviding various domestic tax services including corporate taxconsulting, tax controversy, tax preference application, individ-ual tax, family tax planning, and estate and gift tax planning. Inaddition, Robert is highly experienced in advising multinationalenterprises setting up in Taiwan.

His experience spans multiple industries including financialservices, manufacturing, and consumer products. He is alsoexperienced in assisting clients to apply for VAT refunds and hashad several successful cases in the past few years.

Robert holds a master’s degree in accounting from theNational Taipei University in Taiwan. He is also a certified pub-lic accountant, certified internal auditor and certified securitiesspecialist. Robert is a member of the Taipei City CPA Associa -tion and the Taiwan Provincial CPA Association.

Taiwan

Robert T Chen

Deloitte Taiwan

12th Floor, Hung Tai Financial PlazaNo 156 Min Sheng East RoadSec. 3, Taipei 10596Taiwan, ROC

Tel: +886 (2) 2545 9988 ext. 1211

Fax: +886 (2) 2545 9966 ext. 1211

Email: [email protected]: www.deloitte.com



Thomas Chen, Deloitte Taiwan, is a partner of the tax division.With over 20 years of experience in tax advisory and tax contro-versy, he has focused on M&A tax planning and deals with casesof tax controversy on goodwill amortisation.

His experience spans multiple industries, including financialservices, manufacturing, life sciences and health care. He pro-vides main services on tax advisory services in relation to mergerand acquisitions, investment consultation and inbound taxissues consultation, tax compliance, transfer pricing, and taxcontroversy. He is very experienced in helping clients througheach stage of tax controversy, including re-examination applica-tion, tax appeal with the Ministry of Finance, filing tax lawsuitswith related courts, and even filing petitions for the interpreta-tion of the Constitution.

Thomas holds a bachelors degree in finance from theNational Sun Yat-sen University in Taiwan and he is a certifiedpublic accountant. Thomas is a member of the Taipei City CPAAssociation, a member of the Taichung City CPA Association,and a member of the Taiwan Provincial CPA Association.

Taiwan

Thomas Chen

Deloitte Taiwan

14th Floor, Hung Tai Financial Plaza156 Min Sheng East RoadSec3, Taipei 10596Taiwan

Tel: +886 22545 9988 (ext 5467)Email:[email protected]: www.deloitte.com



Robin Lin, Deloitte Taiwan, has been the managing partnersince 2006. Robin has represented his clients in administrativelitigation, tax controversy, civil and criminal litigation, anti-trustlaw, forensic accounting, corporate investment and general cor-porate matters for more than 20 years.

He has extensive experience in regulatory compliance andfocuses on consultation regarding tax law, the Personal In -forma tion Protection Act (PIPA), Foreign Account Tax Com -pliance Act (FATCA), trade secret protections and corporateaffairs. Throughout his career, Robin has participated in or spo-ken at many seminars and symposia of government agencies andprivate organisations. Robin has been a lecturer on tax contro-versy issues at the National Taiwan University and NationalChengchi University.

Robin participated in contract negotiations for the build-operate-transfer (BOT) project for the Taipei Nangang Exhibit -ion Hall, and was the legal consultant for the private participa-tion in infrastructure management project (PPIMP).

He also assists Taiwan financial institutions, including banksand insurance companies, to implement FATCA compliance projects.

Robin works with clients operating in the financial, logistics, hotel, travel and real estateindustries, regarding compliance with PIPA, establishment of PIPA management systems,and to acquire international certificates.

Robin holds a bachelors degree in law from the National Taiwan University. He is a mem-ber of the Taipei Bar Association, a member of the Taichung Bar Association, a member ofthe Taiwan Administrative Association, a member of the Taiwan Insurance Law Association,and a representative of the Arbitration Association of the Republic of China.

Taiwan

Robin Lin

Deloitte Taiwan

13th Floor, Hung Tai Financial Plaza156 Min Sheng East Road Sec3Taipei 10596Taiwan

Tel: +886 22545 9988; ext 7527Email: [email protected]: www.deloitte.com



Ye-Hsin Lin, Deloitte Taiwan, is a tax partner and the serviceline leader of domestic tax services. She specialises in tax struc-turing, tax consultation on transactions, transfer pricing, and taxcontroversy services. She has more than 25 years of experiencein domestic tax and tax risk management, and has worked close-ly with tax authorities on policy making and dispute resolution.She has helped clients apply favourable tax treatments and closetax disputes through formal tax controversy processes or nego-tiation and settlement.

Ye-Hsin holds a master’s degree in accounting and a BA inpublic finance from the National Chengchi University in Taiwanand is a board member of Deloitte Taiwan. Ye-Hsin is a memberof the Certified Public Accountant of Taiwan, and a deputyleader of the tax regulations committee of the National Fed -eration of Certified Public Accountant Associations of the RoC.

Taiwan

Ye-Hsin Lin

Deloitte Taiwan

12th Floor, Hung Tai Financial PlazaNo 156 Min Sheng East Road,Sec. 3, Taipei 10596Taiwan, ROC

Tel: +886 (2) 2545 9988 ext. 3505Fax: +886 (2) 2545 9966 ext. 3505Email: [email protected]: www.deloitte.com



Glendy Yuan, Deloitte Taiwan, is a tax partner who has morethan 20 years of experience in tax advisory and tax controversy.She is one of the leading tax partners for Deloitte Taiwan’s taxcontroversy services.

Her previous tenure at Arthur Andersen Taiwan includedroles as a partner and senior manager of TN Soong & Co.

Glendy’s main focus includes tax advisory services in relationto M&A, investment consultation and consultancy services forinbound tax issues, tax compliance, transfer pricing, and taxcontroversy.

She is very experienced in helping clients through each stageof a tax controversy, including re-examination application, taxappeals with the Ministry of Finance, filing tax lawsuits withrelated courts, and even filing petitions for the interpretation ofthe Taiwanese Constitution.

Her experience spans multiple industries including financialservices, manufacturing, consumer products, and private equityfunds. In addition, Glendy understands the local tax environ-ment and how the Taiwanese tax authorities function.

Glendy holds a bachelors degree in business administrationfrom National Chung Hsin University and she is a certified pub-lic accountant (CPA) and enrolled patent attorney-in-fact.Glendy is a member of the Taipei City CPA Association and a member of the Taiwan Pro vin -cial CPA Association.

Taiwan

Glendy Yuan

Deloitte Taiwan

12th Floor, Hung Tai Financial PlazaNo 156 Min Sheng East RoadSec. 3, Taipei 10596Taiwan, ROC

Tel: +886 (2) 2545 9988 ext. 3371

Fax: +886 (2) 2545 9966 ext. 3371

Email:[email protected]: www.deloitte.com



Taiwan

Sophie ChouEY

Albert GauKPMG

Dennis LeeBaker & McKenzie

Josephine PengLee & Li

Michael WongBaker & McKenzie

Thailand

Chinawat AssavapokeeHunton & Williams

Ruth ChaowanagawiEY

Wynn PakdeejitBaker & McKenzie

Panya SittisakonsinBaker & McKenzie

Aek TantisattamoBaker & McKenzie

Kitipong UrapeepatanapongBaker & McKenzie

Suvarn ValaisathienDr Suvarn Law Offices

Suksawat WatewaiBaker & McKenzie



Ahmet Cangöz, Deloitte Turkey, joined as a tax partner in 2007,having previously worked for the Ministry of Finance as a taxinspector and for a major private Turkish group of companies as atop executive. He has 30 years of experience as a tax professional.

Ahmet leads the tax and legal practice and has been render-ing corporate tax certification and tax consultancy servicesmostly to international clients.

During his career as a tax adviser, Ahmet specifically focusedon taxation matters regarding energy and construction projectsinvolving multinational consortia and joint ventures. Also, as asworn tax adviser and a reputable collaborator, he has assistedwith many sizeable tax disputes before the Tax SettlementCommittee. He has been an expert witness in many local taxcourt cases and several international disputes as well.

Ahmet graduated from Ankara University with a BA in eco-nomics (1985), and earned an MBA from Southern NewHamp shire University, US (1995). He also holds certificatesfrom Ankara University (1992) and Cornell University (2012).

He is certified as a sworn financial adviser (1995) and is reg-istered with the Chamber of Istanbul (2004).

Turkey

Ahmet Cangöz

Deloitte Turkey

Deloitte Values House Maslak No1 SarıyerIstanbul 34398Turkey

Tel: +90 212 366 60 91Email: [email protected]: www.deloitte.com



Niyazi Cömez, Deloitte Turkey, is a partner with more than 30years of experience as a Turkish international and local tax spe-cialist. Before joining Deloitte, Niyazi spent 14 years as aninspector of taxes and head of department at the Turkish taxauthority. Since leaving the Turkish tax authority in 1999, hehas been an adviser, assisting clients with strategic planning anddefence of their tax disputes. He has also appeared in tax courtsand tax settlement committees as an expert witness relating totax matters.

Niyazi serves a range of multinational clients, with particularfocus on real estate investment, private equity, financial services,insurance and mergers and acquisitions. As an experiencedtrainer, he lectured at various OECD tax training programmesin Ankara, Budapest and Vienna. Niyazi is a member of the taxsteering committee of the Association of Turkish Industrialistsand Businessmen (TUSIAD) and working group of the TaxCouncil, and is a sworn-in tax adviser.

Niyazi has an MA in economics from Ankara University andan MBA from Leicester University in the UK. He also holds a cer-tificate from Harvard University’s international tax programme.

Turkey

Niyazi Çömez

Deloitte Turkey

Maslak Mah. Eski Buyukdere Cad.No: 1Maslakno/1 SariyerIstanbul, 34398Turkey

Tel: +90 212 366 60 69Email: [email protected]: www.deloitte.com



Gündoğan Durak, Deloitte Turkey, is a tax director and hasmore than 15 years of experience as a Turkish international andlocal tax specialist. He joined Deloitte Turkey in 2013 andfocused on tax litigation and controversy practice, as well as thetaxation of the financial sector. Prior to joining Deloitte, he wasa tax inspector at the Ministry of Finance and conducted taxaudits of companies operating in different sectors includingfinance, manufacturing, infrastructure, construction and tex-tiles.

Gündoğan possesses extensive knowledge of direct and indi-rect tax laws and has expertise in the taxation of financial instru-ments. He worked on the tax due diligence and internationaltax compliance projects. Gündoğan has been rendering taxreturn certification and tax consultancy services to national andinternational clients.

He manages tax disputes for clients during their tax investi-gations and advises them on how to secure the most favourableoutcome in an efficient manner. He represents clients in lawcourts and administrative hearings.

Gündoğan is a member of the tax steering committee of theAssociation of Turkish Industrialists and Businessmen (TUSIAD).

He is certified as a sworn financial adviser (2013) and is registered with the Chamber ofIstanbul.

Gündoğan has a bachelors degree in public administration from Hacettepe University(2001). He earned his Masters of Science in Finance from the University of Illinois (2010).He holds designations as a CPA (US, Illinois), CMA and CGMA. He is also a certified inde-pendent auditor in Turkey.

Turkey

Gündoğan Durak

Deloitte Turkey

Deloitte Values HouseMaslak No 1 Sarıyerİstanbul 34398Turkey




Refik Yaşar Durusoy, Deloitte Turkey, is a partner with morethan 25 years of experience as a Turkish international and localtax specialist. Before joining Deloitte, he worked as a tax inspec-tor at the Ministry of Finance. During his career as a tax adviser,Yaşar has been rendering tax return certification, tax consultan-cy and VAT refund services to clients. Yaşar focuses on taxationmatters regarding tourism, manufacturing and constructionprojects.

Yaşar specialises in R&D incentives, M&A taxation matters,tax optimisation and tax planning in restructuring projects.

Yaşar has provided tax litigation services for national andmultinational enterprises and is highly experienced in handlingthe complex and technical field of tax law. He has representedclient in law courts and administrative hearings. He has alsoappeared in tax courts and tax settlement committees as anexpert witness relating to tax matters.

He is certified as a sworn financial adviser (2013) and is reg-istered with the Chamber of Istanbul. He is also a certified inde-pendent auditor in Turkey.

He has a bachelors degree in finance from Istanbul University.

Turkey

Refik Yaşar Durusoy

Deloitte Turkey

Deloitte Values HouseMaslak No 1 Sarıyerİstanbul 34398Turkey




Ersin Nazali is the managing partner at Nazali AttorneyPartner ship. He has considerable knowledge in several tax areasincluding tax investigations, litigation, transfer pricing, and taxfree restructuring of companies.

Ersin, who worked as a tax inspector for nine years under theRevenue Administration, began working as a tax consultant andattorney in the private sector from August 2012.

He graduated from Ankara University, Faculty of PoliticalSciences and also Dicle University, Faculty of Law. He has amaster’s degree from Istanbul University in financial law (MSc)and also from King’s College London, School of Law in inter -national tax law (LLM). He is currently working on his PhDthesis entitled ‘Transfer Pricing from Tax Perspective’ in theFiscal Law Department at Istanbul University.

After his graduation from university in 2001, Ersin workedat Arthur Andersen and then as deputy inspector at the PrimeMinistry Board of Inspection. In 2004, he was appointed as theassistant tax inspector and in 2007 became a tax inspector.

In academic year 2008-09, he served as a part-time lecturerat Aydin University. During this time, he also participated inseveral conferences and seminars organised by various institu-tions and organisations. After being appointed to the Tax Council in March 2009, Ersinadvised officials on tax legislation. He was also part of the consultancy commission, which isan organ of the Tax Inspectors’ Board, as a member and reporter. Ersin is one of the foundersof the tax disputes department within the Tax Inspectors’ Board.

Ersin has written over 80 articles published in several tax journals and books including:• ‘Liquidation, Merger, Acquisition, Spin-off and Conversion of Joint Stock and Limited

Liable Companies in respect of Tax and New Turkish Commercial Code’ (4th edition,2015);

• ‘International Tax Law-Transfer Pricing & Double Tax Treaties’ (3rd Edition, 2016);• ‘Tax of Law’ (selected articles) (1st Edition, 2014);• ‘Work Place/Permanent Establishment in respect of Tax Treaties and Turkish Tax Law’

(Unpublished, LLM Thesis-King’s College, London, 2012);• ‘Taxation of Securities within the Scope of European Union Harmonization’ (Un pub lish -

ed, Proficiency Study-Tax Inspectors’ Board, Istanbul, 2007); and• ‘Criminal and Tax Liability of Company Directors’ (Unpublished, Proficiency Study-

Prime Ministry Inspectors Board, Ankara, 2003).

Turkey

Ersin Nazali

Nazali Attorney Partnership

Elit Residence19 Mayıs Cad. Dr. İsmet Öztürk Sok. 3/28 Kat: 10 Şişli 34360 IstanbulTurkey

Tel: +90 212 380 0640Fax: +90 212 217 1890Email: [email protected]: www.nazali.av.tr



Turkey

Erdal EkinciBaker & McKenzie

Duygu GultekinBaker & McKenzie

Zeki GündüzPwC

Abdulkadir KahramanKPMG

Yuksel ToparlakPwC

Bilgutay YasarPwC



Igor Davydenko is a partner in Dentons’ Kyiv office. He hasproven experience advising clients on a wide range of matters ofUkrainian and international tax and customs law, as well as ongeneral matters of corporate, civil and banking and finance law.

Igor has been working with the firm for the last 20 years.During this period he was involved in more than 200 multi-mil-lion complex transactions in different sectors in Ukraine.

Prior to joining the firm, Igor served as a member of theboard of management of three Ukrainian banks between 1991and 1994, during which time he dealt extensively with bankregulatory matters and questions of secured lending and loandocumentation for each of these banks.

Ukraine

Igor Davydenko

Dentons

49-A, Volodymyrska StreetKyiv, 01001Ukraine




Andrey Pronchenko is the managing partner at PwC Ukraine.He has over 14 years of experience in practicing law on interna-tional and domestic markets. This includes almost 10 years withthe Big 4 firms, where he had extensive exposure to all aspectsof international and corporate law while developing his leader-ship skills by running cross-disciplinary and cross-border proj-ects for large multinationals.

During his career, he was honoured to serve such companiesas Amway Ukraine, Boeing, Google Inc., JTI, LG Electronics,Nissan, Opera, Oriflame Cosmetics Ukraine, Oschadbank,P&G, Polpharma, Subaru, Toshiba Corporation, Winner Im -ports Ukraine, Western Union, Wizz Air Ukraine and manyothers, including more than 10 Fortune Global 500 corpora-tions.

For many years, Andrey has been recommended by reputableinternational and Ukrainian independent guides and directoriesas one of the leading professionals in tax disputes.

In 2008, Andrey set up the tax litigation practice within thePwC Ukraine office, which has been successfully growing andextending the firm’s capabilities in the areas connected with taxdisputes, including support of companies’ top officials in criminal proceedings that involvetax matters. The Attorneys Associa tion ‘PwC Legal’ tax controversy team brings togetherspecialists that have solid experience and unique expertise to assist clients in their efforts toexpertly avert, manage and expediently resolve various types of tax audits and disputes.

In 2015, under Andrey’s supervision, the firm’s team of attorneys successfully representedover 30 clients in tax disputes including criminal proceedings. The practice’s success rates intax dispute cases is one of the highest in Ukraine and is more than 90% (the firm and its staffshow zero tolerance to corruption and any controversial practices, including bribes).

Ukraine

Andrey Pronchenko

PwC Ukraine

75, Zhylyanska str. 01032, KyivUkraine

Tel: +38 044 354 04 04Email:[email protected] Website:www.pwc.com/taxcontroversy



Ukraine

Roman BlazhkoLavrynovych & Partners

Zhanna BrazhnykPwC

Vladimir KotenkoEY

Maksym LavrynovychLavrynovych & Partners

Kostiantyn LikarchukKinstellar

Oleh MarchenkoMarchenko Danevych

Vadim MedvedevAvellum Partners

Alexander MininKM Partners

Svitlana MusienkoDLA Piper

Sergiy PopovKPMG

Alexander ShemiatkinKM Partners

Mykola StetsenkoAvellum Partners

Illya SverdlovDLA Piper

Vyacheslav VlasovPwC

Hennadiy VoytsitskyiBaker & McKenzie

Yuriy ZaluskyyBaker & McKenzie

Tatiana ZamorskaKPMG



Shaun Austin, Deloitte UK, has more than 14 years of experi-ence as a partner, and 20 years of experience in transfer pricing.

He has been the partner responsible for the UK regionaltransfer pricing practice since 2007, and has been the partner incharge of the UK national transfer pricing practice from 2009.Shaun is now European transfer pricing leader.

Shaun has extensive experience in advising a broad range ofclients in all areas of transfer pricing including planning, docu-mentation, audit defence and MAP, and debt pricing.

Shaun was listed in the most recent version of Euromoney’sTransfer Pricing Expert Guide. He studied at Cambridge Uni -ver sity and is a member of the Institute of Chartered Account -ants in England & Wales (ICAEW).

UK

Shaun Austin

Deloitte UK

2 New Street SquareLondon, EC4A 3BZUK

Tel: +44 (0) 207 007 3079;+44 (0) 121 695 5011

Mobile: +44 (0) 7775 807510Email: [email protected]: www.deloitte.com



Philip Baker is a barrister and Queen’s Counsel, practising fromField Court Tax Chambers in Gray’s Inn. He was called to thebar in 1979, began practising in 1987 and took silk in 2002. Hebecame a bencher of Gray’s Inn in 2011. He specialises in inter-national tax issues, with a particular emphasis on double taxconventions, and on European Union law and taxation. He hasa particular interest in the European Convention on HumanRights and taxation.

Before moving into practice, Philip taught law for sevenyears at the School of Oriental and African Studies, LondonUniversity. He was subsequently a visiting professorial fellow atQueen Mary University of London, and is now a senior associ-ate fellow of the Institute of Advanced Legal Studies, LondonUniversity and a visiting professor at Oxford University. He isthe author of ‘Double Taxation Conventions’ and ‘Inter nation -al Tax Law’ and the editor of the ‘International Tax LawReports’.

In recent years, Philip has been involved in litigation in theUK tax tribunals and the Court of Justice of the EuropeanUnion concerning consortium relief for losses under non-dis-crimination provisions and EU law (Felixstowe Docks), and is part of the Irish governmentlegal team in the Apple state aid case. He has also acted as an expert witness in India(Vodafone) in the US (Entergy, PPL, Bank of New York) in Norway (Transocean) and othercountries. He has also been involved with several arbitrations on tax-related issues. Heappears on behalf of the Mauritius government in Privy Council appeals.

Philip’s advisory practice covers UK and international tax law and EU tax law (includingstate aid), and extends to both private client matters (largely cross-border issues) and corpo-rate matters, including multinational group tax issues.

Philip is a member of the permanent scientific committee of the International FiscalAssociation, the Financial Secretary’s Tax Professional Forum, and the international tax com-mittee of the Law Society.

UK

Philip Baker

FIELD COURT TAX CHAMBERS

Field Court Tax Chambers

3 Field CourtGray’s InnLondon WC1R 5EPUK

Tel: +44 (0)20 3693 3700Email: [email protected]: www.fieldtax.com



Nigel Barker, Deloitte UK, has been a partner for over 10 yearsand is the national head of the private client department, as wellas co-leader of Deloitte’s UK tax disclosure and transparencyteam operating in the private market. Nigel is a member of theglobal tax controversy team and advises on the tax transparencyagenda including the automatic exchange of tax informationand beneficial ownership register regimes.

Nigel has significant experience of advising private clientsand private companies on a wide range of tax matters. He hasadvised on information notices, LDF disclosures and a widerange of HMRC enquiries covering UK residence and domicilestatus, dual contracts, private equity structures, employee bene-fit trusts, specific planning arrangements and trust distributionsand reporting.

Nigel also works closely with Deloitte’s tax policy group inshaping the firm’s responses to HMRC consultations on per-sonal tax and disclosure issues.

Most recently, Nigel has been heavily involved in advisingclients on their approach and methodology to respond to theproposed UK offences of failure to prevent the facilitation of tax evasion.

UK

Nigel Barker

Deloitte UK

2 New Street SquareLondon EC4A 3BZUK

Tel: +44 (0)20 7007 3608Fax: +44 (0)20 7007 3521Email: [email protected]: www.deloitte.com



Sandy Bhogal heads Mayer Brown’s tax group in London. His experience ranges from general corporate tax advice to

transactional advice on matters involving corporate finance,banking, capital markets, asset finance and property. He also hassignificant experience with corporate tax planning, as well aswith advising on the development of domestic and cross-bordertax efficient structures. Sandy advises on a number of controver-sy related matters, including APA’s and other ruling processeswith HMRC, as well as international and domestic tax technicaldisputes.

Prior to joining Mayer Brown in 2005, Sandy was associatedwith Ernst & Young LLP and with a leading international legalpractice.

UK

Sandy Bhogal

Mayer Brown

201 BishopsgateLondon EC2M 3AFUK




Andy Brown is one of the UK’s leading tax disputes practition-ers with more than 20 years’ experience representing clients inboth direct and indirect tax dispute resolution. He is a partnerin PwC Legal’s tax disputes team and is the lead for the taxcrime and investigations practice.

Andy primarily advises clients who are subject to HM Rev -enue and Customs (HMRC) criminal and civil investigations fortax fraud as to how they should deal with issues, and advises atall stages of the investigation, including the initial criminalinvestigation and disclosure work through to formal criminalproceedings and prosecutions. This also includes elements oftax litigation at the Tax Tribunal, challenges by way of theJudicial Review and Magistrate and Crown court work.

His practice is international in nature with many clients oper-ating outside of the UK and it covers private clients through tolarge corporates.

UK

Andy Brown

PwC Legal

1 Embankment PlaceLondon WC2N 6DXUK

Tel: +44 (0) 191 269 4441Mobile: +44 (0) 7525 925707Email:[email protected]:www.pwc.com/taxcontroversy



Liesl Fichardt leads Clifford Chance’s tax dispute resolutionpractice and is one of the UK’s leading tax disputes practition-ers. She has extensive experience in tax litigation, negotiatingwith revenue authorities and settling disputes. She possessesconsiderable court and tribunal experience including conduct-ing cases in the Tax Tribunal, the Courts of Appeal and theCourt of Justice of the European Union.

Liesl practiced as a tax barrister for 13 years and previouslyacted as a judge in the High Court of South Africa. She is Chair -person of the UK branch of the International Fiscal Association.She is recognised in leading legal directories for her outstandingsuccess and for consistent positive feedback from clients andpeers.

Liesl leads arguably the most experienced group of partnersand associates who deal with tax investigations, litigation anddispute resolution. The combination of local expertise and aglobal network allows Clifford Chance to handle complex dis-putes effectively and efficiently, whether in the UK or any otherjurisdiction.

Clifford Chance advises multinationals, financial institutions,corporates and high-net worth individuals on a number of ongoing tax and VAT matters cov-ering the entire range of tax dispute resolution. This includes:• Prevention-related advice, risk assessments and risk management;• Tax audits and tax raids;• Tax compliance-related advice;• Investigations (both civil and criminal);• Negotiation and drafting of settlements with tax authorities;• Cross-border disclosure requests from tax authorities;• Tax litigation before national and international courts, specialist tax tribunals, the Courts

of Appeal and the Court of Justice of the European Union;• Parliamentary, European Commission and similar investigations;• Lobbying revenue authorities on the formulation of tax legislation and guidelines; and• Enforcement proceedings.

UK

Liesl Fichardt

Clifford Chance

10 Upper Bank StreetLondon, E14 5JJUK

Tel: +44 (0)20 7006 2044 Email:[email protected] Website: www.cliffordchance.com



John Henshall, Deloitte UK, is a partner in the firm’s Londoninternational tax practice specialising in transfer pricing. In thisrole, John is responsible for service to clients on all aspects ofcross-border pricing arrangements. This has included providingassistance to major multinational enterprises in their dealingswith the UK and foreign tax authorities in transfer pricing com-pliance matters and Advance Pricing Arrangements, as well asreviewing companies’ cross-border pricing arrangements forplanning – known as mobile income studies. In particular, Johnhas assisted companies in the electronics, retail, biotechnology,defence and general trading industries in the developmentand/or defence of their tax planning and/or pricing arrange-ments.

John has a particular interest in the transfer pricing of intel-lectual property. He has also been consulted by the govern-ments of China and Iran about the modernisation of theirapproach to international taxation.

John is heading the European global earnings managementstrategies (GEMS) team, which raises mobile income planningto a higher, more practical level.

Training initially with the UK HM Revenue and Customs, prior to joining Deloitte in2000, John spent 12 years at another Big 4 firm. He began transfer pricing work in 1991 andhas been involved with transfer pricing on a full-time basis for four years. He is regularly pub-lished, including in International Tax Review and the International Transfer Pricing Journal,and was co-author of ‘International Transfer Pricing 1999–2000’ published by CCH. Johnalso lectures in the UK and Europe on transfer pricing.

UK

John Henshall

Deloitte UK

2 New Street SquareLondon EC4A 3BZ UK




Oliver Jarratt, Deloitte UK, is a director in the litigation,advisory and settlement (LAS) team, and leads the advisorypart of LAS in the UK.

Oliver and his team help to resolve clients’ disputes withHMRC by the most appropriate and cost-effective means (suchas negotiation, alternative dispute resolution or tribunal litiga-tion), and they are involved in a wide range of consultancy workwith complex technical angles. The vast majority of Oliver’swork relates to VAT, but he also advises on customs duty andsome environmental taxes, assisting clients of all sizes, frommulti national to local. Oliver works across all industries, butwith particular emphasis on the consumer business and automo-tive sectors.

UK

Oliver Jarratt

Deloitte UK

Four BrindleyplaceBirmingham, B1 2HZUK




Anbreen Khan, Deloitte UK, is the head of the dispute resolu-tion group, specialising in indirect taxes. She is a partner, basedin London, with expertise and significant experience in dealingwith indirect taxes and in particular dispute resolution work.Anbreen advises a wide spectrum of clients and has advised in anumber of landmark VAT cases in the UK and at the Court ofJustice of the European Union including The Rank Group plc;and Everything Everywhere (formerly T-Mobile). Other notablecases include: Marks & Spencer Plc; and Association of Invest -ment Trust Companies/JP Morgan Fleming. These cases havemade an outstanding contribution to UK business and thedevelop ment of tax policy.

Anbreen has extensive experience in dealing with complexVAT legal issues and negotiations in relation to collaborative taxdispute resolution. Anbreen leads a group of tax specialists inthe UK who provide a dedicated dispute resolution serviceacross both indirect tax and corporate tax. The team has a highmarket profile, winning the ‘UK Best VAT Team’ award twicein 2007 and 2009 and was voted the ‘Best Big 4 Tax Team’ in2011.

Anbreen is a qualified lawyer. She is a former winner of the ‘Rising Star’ award for TheTax Journal’s Indirect Tax Awards and is also a member of the Institute of CharteredAccountants England and Wales. Anbreen was recently listed as an indirect tax expert in the2012, 2013, 2014 and 2015 editions of the Indirect Tax Leaders guide.

UK

Anbreen Khan

Deloitte UK

Athene Place66 Shoe LaneLondon EC4A 3BQUK




Jason Marsh, Deloitte UK, has been a partner in the corporatetax practice in London since 2001. He joined Deloitte UK in1991. He is a qualified mediator (by the Centre for EffectiveDispute Resolution (CEDR)) and has been a founding memberof the Deloitte UK tax risk management and resolution teamsince 2007.

Jason has gained extensive experience working with corpo-rate clients, and HM Revenue & Customs (HMRC), to resolvetax disputes through HMRC’s high risk corporate programme(HRCP), managing corporate risks programme (MCRP) andcollaborative dispute resolution (CDR) processes and gover-nance frameworks.

UK

Jason Marsh

Deloitte UK

2 New Street SquareLondon, EC4A 3BZUK




Edward Morris, Deloitte UK, has advised on many transfer pric-ing issues across many industries and has been instrumental informing Deloitte’s global Competent Authority network of ex-government and specialised expertise to help clients with allforms of dispute resolution and dispute prevention. In particu-lar, Edward has helped many clients negotiate successfuladvance pricing agreements (APAs) and mutual agreement pro-cedures (MAPs) and to resolve ongoing transfer pricingenquiries.

Edward joined Deloitte UK in 2009 after a career in thehead office international division of Her Majesty’s Revenue andCustoms (HMRC). He was involved in a range of internationaltax issues and problems but specialised in transfer pricing, PEsand treaty matters and represented the UK at the OECD.

Edward served as the UK delegated Competent Authorityfor MAP and EU arbitration cases. This work involved disputeresolution as well as dispute prevention work on APAs, with fis-cal authorities around the world.

Previously, Edward led many of HMRC’s transfer pricingenquiries into the biggest and most complex cases, including involvement in litigation workbefore the UK courts.

Edward enjoyed a two and half year secondment to Brussels, where he served on the sec-retariat to the EU Joint Transfer Pricing Forum (JTPF), helping to update the EU Arbitra -tion Convention and the various associated codes of conduct. Edward’s magnum opus wasthe EU APA guidelines adopted by all 28 member states.

Edward has also spent considerable time at the OECD, attending Working Party 6 ontransfer pricing (including the sub-groups on dispute resolution and business restructuring),either for the UK or as Commission observer and latterly as a private sector representative.Edward also attends meeting of the EU JTPF. Edward’s eminence in the wider internationaltax field was recognised by the OECD when he was asked to speak at the 50th anniversarycelebration of the OECD Model Tax Convention and by IFA in 2011 when Edward partic-ipated in the opening plenary session on business restructuring. Edward has appeared consis-tently in Euromoney’s Transfer Pricing Expert Guide since joining Deloitte.

UK

Edward Morris

Deloitte UK


Tel: +44 207 007 6568Mobile +44 7813 292806Email: [email protected]: www.deloitte.com



Tom Rowbotham, Deloitte UK, is a tax partner and is respon-sible for the firm’s strategy in the area of tax disputes. He is alsoa member of the global tax controversy management executiveteam and leads the service line in relation to all disclosure facil-ities. Tom has worked for large international businesses, owner-managed businesses, and high-net worth individuals and has ex ten sive experience in dealing with all forms of tax dispute.

Before joining Deloitte UK, Tom worked for 20 years as aninspector of taxes for HM Revenue & Customs (HMRC). Tomled many significant cases where HMRC raised inquiries orrequested information from clients and external referrals acrossall aspects of industry.

As Tom’s main focus is advising clients on dealings and inter-actions with HMRC, his experiences from working on both theside of the inspector and the client prove invaluable in providingpractical commercial strategies. Tom is advising a number ofclients with regard to HMRC’s initiatives around tax trans-parency and exchange of information.

Some highlights of Tom’s project experiences include signif-icant and varied issues covering many industry sectors delivering client-favorable outcomes,information requests from HMRC, which are both sensitive and potentially commerciallydamaging, disclosures to HMRC in areas of uncertainty to achieve a controlled outcomereflecting appropriate commercial pressures, and requests by UK and other jurisdictionsunder tax information exchange agreements (TIEAs).

UK

Tom Rowbotham

Deloitte UK


Tel: +44 20 7007 6580Email:[email protected] Website: www.deloitte.com



UK

Graham Aaronson QCJoseph Hage Aaronson

David AndersonPwC

James AndersonSkadden, Arps, Slate, Meagher & Flom

Michael AndersonJoseph Hage Aaronson

Kevin AshmanHogan Lovells

Rupert Baldry QCPump Court Tax Chambers

Mark BevingtonBaker & McKenzie

Giovanni BraccoPwC

John Brinsmead-Stockham11 New Square

Amanda BrownKPMG

Helen BuchananFreshfields Bruckhaus Deringer

Stephen CammPwC

Alex ChadwickBaker & McKenzie

Murray ClaysonFreshfields Bruckhaus Deringer

Jason CollinsPinsent Masons

Michael Conlon QCTemple Tax Chambers

Adam CraggsRPC

Mark DelaneyBaker & McKenzie

Paul DennisEY



UK

Nigel DolmanBaker & McKenzie

Karen EcksteinBond Dickinson

Stephen EdgeSlaughter and May

Kevin ElliottKPMG

Paul FarmerJoseph Hage Aaronson

Richard FletcherBaker & McKenzie

Philippe FreundJoseph Hage Aaronson

Malcolm Gammie QCOne Essex Court

John Gardiner QC11 New Square

Philip GershunyHogan Lovells

Heather GethingHerbert Smith Freehills

Julian Ghosh QCPump Court Tax Chambers

Ian Glick QCOne Essex Court

David HarknessClifford Chance

Diane HayPwC

Andrew HinsleyRSM

Andrew Hitchmough QCPump Court Tax Chambers

Julie HughffKPMG

David HumeDeloitte



UK

Chris Hutley-HurstCarey Olsen

Ian HydePinsent Masons

Richard JeensSlaughter and May

Geoffrey KayBaker & McKenzie

Sarah LeeSlaughter and May

Geoff LloydEY

Sara LuderSlaughter and May

David Milne QCPump Court Tax Chambers

Stephen MorsePwC

Dan NeidleClifford Chance

Peter NiasPump Court Tax Chambers

Christopher OrchardPwC

Conall PattonOne Essex Court

Jonathan Peacock QC11 New Square

Kevin Prosser QCPump Court Tax Chambers

Dominic RobertsonSlaughter and May

David SalehClifford Chance

Giles SalmondEversheds

Jonathan SchwarzTemple Tax Chambers



UK

Heather SelfPinsent Masons

Rupert ShiersHogan Lovells

Alan SinyorBerwin Leighton Paisner

Nick SkerrettSimmons & Simmons

James StaceySlaughter and May

Stuart WalshPinsent Masons

William WatsonSlaughter and May

Philippa WhippleOne Crown Office Row

Simon WhiteheadJoseph Hage Aaronson

Mark WhitehousePwC

Simon WilksPwC

James WilsonEY

Zizhen YangPump Court Tax Chambers

Jeanette ZamanSlaughter and May



Taxpayers celebrate Medtronic’s victory in US Tax CourtIn a significant victory for the taxpayer, the US Tax Court inMedtronic, Inc. v. Commissioner, T.C. Memo 2016-112, heldthat the Internal Revenue Service’s (IRS’s) transfer pricingadjust ments (which amounted to almost $1.4 billion for the2005 and 2006 tax years) were arbitrary, capricious, or unrea-sonable. The Tax Court’s decision in Medtronic follows signifi-cant taxpayer victories in other § 482 cases, including Veritas v.Commissioner, 133 T.C. 297 (2009), nonacq, and AlteraCorporation v. Commissioner, 145 T.C. 91 (2015).

The primary issue in Medtronic was whether income relatedto certain intercompany licenses for intangible propertyrequired to manufacture medical devices and leads should bereallocated under § 482 from Medtronic US to its PuertoRican subsidiary (MPROC). Interestingly, the taxpayer andthe IRS had reached an agreement on the royalty rates in aprior audit cycle, which resulted in a memorandum of under-standing (MoU) between the parties regarding the royalties.However, after completing its examination of Medtronic’s2005 and 2006 tax returns, the IRS departed from theapproach in the MoU and asserted a large royalty adjustment,which prompted Medtronic to then assert a refund based onits pre-MoU pricing.

While the taxpayer in Medtronic applied the comparableuncontrolled transaction (CUT) method to determine thearm’s-length royalty rate on the intercompany sales, the IRSasserted that the comparable profits method (CPM) was thebest method to determine the arm’s-length royalty rates onintercompany sales. The IRS’s position was based largely on itscontention that MPROC performed only assembly of finishedproducts, with Medtronic US performing all other economical-ly significant functions.

US

Andrew Kim and LarissaNeumannFenwick & West

The top US tax controversiesin 2016There have been a number of significant developments in the area of US tax controversiesduring 2016. We highlight below some of the top US tax cases from this year, including severallarge § 482 transfer pricing cases that could provide helpful insight for taxpayers who may befacing similar significant transfer pricing adjustments.



US

The Tax Court rejected the IRS’s use of the CPM method, as well as the IRS’s character-isation of MPROC as providing only minimal contributions and functions. The court statedthat the commensurate-with-income standard under § 482 does not replace the arm’s-lengthstandard, and that the IRS’s use of CPM was therefore not required under the commensu-rate-with-income standard.

The court ultimately found that the royalty rates charged for the intercompany sales ofdevices and leads were not at arm’s-length because certain adjustments were required toaccount for variations in profit potential. However, the Tax Court also appeared to criticisethe IRS for adopting an all-or-nothing approach by advocating a result based on the CPMusing a value chain methodology, while refusing to suggest adjustments to Medtronic’s CUTmethod for the devices and leads. Ultimately, the royalty rates determined by the courtappeared to generally fall in line with the royalty rates previously agreed to in the MoU.

Significantly, the Tax Court rejected the IRS’s proposed aggregation of the transactionsat issue, which would have treated MPROC as an ordinary contract manufacturer. Notingthat the functions at issue in the covered transactions are able to exist independently, thecourt determined that aggregation was not the most reliable means of determining arm’s-length consideration for the controlled transactions.

The Tax Court also rejected the IRS’s alternative argument that if a § 482 adjustment wasnot warranted, then Medtronic should be required to recognise a deemed royalty under§ 367(d) for the transfer of intangible property by Medtronic US to MPROC. The TaxCourt rejected this IRS’s alternative argument, stating that the IRS did not identify specificintangibles that were purportedly transferred from Medtronic US to MPROC.

Cost-sharing arrangements in Altera are still in contentionThe IRS has filed its appeal of the Tax Court’s decision in Altera Corporation v. Commis -sioner, 145 T.C. 91 (2015), in the Ninth Circuit. Altera is a follow-on to Xilinx v. Commis -sion er, 125 T.C. 37 (2005), aff ’d, 598 F.3d 1191 (9th Cir. 2010).

In Xilinx, the Tax Court held that unrelated parties would not agree to share the costs ofstock-based compensation in a cost-sharing arrangement. The Ninth Circuit, in affirming thelower court decision, held that the “all costs” requirement of the 1995 cost-sharing regula-tions were irreconcilable with the arm’s-length standard. In an effort to overrule a negativedecision in Xilinx, the Treasury and the IRS in 2003 issued a specific stock-based compen-sation rule under Treas. Reg. § 1.482-7(d)(2). The 2003 regulation requires controlled par-ties entering into cost-sharing agreements to share stock-based compensation costs.

The Tax Court in Altera held that the 2003 regulation was invalid because it failed to sat-isfy the reasoned decision-making standard underMotor Vehicle Manufacturers Association ofthe US Inc. v. State Farm Mutual Auto Insurance Co., 463 US 29 (1983). The court also stat-ed that the Treasury violated the Administrative Procedures Act when it failed to considercommentary that unrelated parties never share the cost of stock-based compensation. TheTax Court also held that under Chevron, U.S.A., Inc. v. Natural Resources Defense Council,Inc., 467 US 837 (1984), “the final rule is invalid because it is ‘arbitrary or capricious in sub-stance’ [citations omitted], and therefore cannot be justified as being a reasonable interpre-tation of what sec. 482 requires”. The Treasury is not permitted to arbitrarily define what isarm’s-length. The Tax Court stated that the “Treasury’s ipse dixit conclusion, coupled with



its failure to respond to contrary arguments resting on solid data, epitomises arbitrary andcapricious decision-making”. Altera is an important case for taxpayers. The case is a taxpayer victory on not only the

narrow stock-based compensation issue, but it also establishes an important precedent forchallenging regulations that are issued by the IRS without reasoned decision making.

The Department of Justice (DoJ) filed its appellate brief with the Ninth Circuit on June27 2016. The DoJ’s brief largely makes the same arguments the government made, and loston, in Xilinx. Two different amici briefs have been filed by law professors arguing that theNinth Circuit should uphold the 2003 regulation as a reasonable exercise of the Treasury’sstatutory authority.

IRS challenges Coca-Cola’s royalty paymentsIn another large transfer pricing case, the IRS has proposed a $9.4 billion income adjustment($3.3 billion tax deficiency) related to intercompany royalties that were charged by Coca-Cola to seven foreign affiliates.

The IRS’s royalty adjustment pertains to trademark and product formula licenses thatwere granted to the foreign affiliates who used these licensed rights to produce beverage con-centrates. The foreign affiliates sold the beverage concentrates to third-party bottlers, who inturn produced and sold the finished beverage products to distributors and retailers. Althoughthe IRS’s asserted adjustments are significant, the potential long-term continuing impact onCoca-Cola is likely to be much larger if the continuing intercompany royalty rates are adjust-ed.

Interestingly, the IRS’s position in this case bears some similarities with the IRS’s positionin Medtronic, discussed above.

First, the taxpayer and IRS apparently had reached a formal agreement regarding theintercompany royalties in an earlier year, which had been consistently applied for a numberof years. The IRS’s proposed royalty adjustment appears to be a significant departure fromthe methodology that was previously agreed to, and consistently applied.

Second, as it did in Medtronic, the IRS is attempting to apply the comparable profitsmethod in a manner that would suggest that the foreign licensee is entitled only to routinereturns, with all non-routine profits being assigned to the US parent.

The taxpayer’s petition accuses the IRS of adopting an inconsistent position in a separateadjustment. In a situation where Coca-Cola’s Canadian subsidiary owned the IP, the IRSallocated only a routine return to the legal owner of intangible property and allocated allresidual profits to the US parent who purportedly bore the entrepreneurial risk. The petitionalso notes that the IRS’s $9.4 billion income adjustment would total more than 100% of theaggregate operating profits of the foreign licensees.

Given that this case is still in the early stages, with the taxpayer having filed its petition inthe Tax Court in December 2015 and the IRS having filed its answer in February 2016, itwill be a while before we can expect the court to reach a decision (assuming that the case isnot settled beforehand, which seems unlikely likely given that the IRS designated this case forlitigation).

US



US

The IRS has appealed the Santander case concerning anti-abuse doctrinesIn Santander Holdings USA v. US, the Massachusetts District Court granted a summaryjudgment for the taxpayer, stating that the judicial anti-abuse doctrines of economic sub-stance and substance-over-form do not invalidate a STARS foreign tax credit generator.

The judge criticised the earlier decisions in Salem Fin., Inc. v. United States, 786 F.3d 932,937-39 (Fed. Cir. 2015), petition for certificate filed (US September 29 2015) (No. 15-380), and Bank of N.Y. Mellon Corp. v. Commissioner, 801 F.3d 104, 110-12 (2d Cir. 2015),petitions for certificate filed (US October 13 2015) (No. 15-478) and (US November 22015) (No. 15-572), stating that what the government is really doing is defending doubletaxation. In a very articulate and well-reasoned opinion, the judge criticised the IRS for mak-ing moral judgments rather than using legal rationality and stated that the anti-abuse doc-trines should be analytical and not visceral.

The government has appealed the Santander District Court decision with the First Circuit(brief filed on June 9 2016), arguing that Santander did not generate a profit on a pre-taxbasis. The case is ongoing.

IRS to stop using outside law firms in audits after Microsoft disputeMicrosoft’s transfer pricing methodology for its cost-sharing arrangements are in dispute,which could lead to a multi-billion dollar income adjustment. This could be the largest trans-fer pricing issue to date. IRS officials have stated that this is one of the largest audits in IRShistory.

The Microsoft dispute made headlines when Microsoft challenged the IRS’s use of outsidelaw firm Quinn Emanuel Urquhart & Sullivan. Quinn is primary outside counsel to Google,one of Microsoft’s largest competitors. The IRS filed a summons enforcement action againstMicrosoft seeking more documents and interviews. Microsoft challenged the requests andargued that the use of Quinn was an improper delegation of a government function andraised taxpayer confidentiality and privacy concerns.

The IRS has faced criticism from the public and Congress for its use of an outside law firmin an audit. Top-ranking IRS officials recently stated that the IRS does not plan to use outsidelaw firms in other audits.

Amazon’s cost-sharing agreement to go on trialSometime in 2016, the Tax Court could issue an opinion in Amazon. Amazon.com, Inc. v.Com missioner, T.C. Dkt. 31197-12, involves a cost-sharing agreement with allocatedamounts of over $1 billion for each of the two years in issue.

It involves some of the same issues that were litigated in Veritas v. Commissioner, 133 T.C.297 (2009), nonacq, which is cited in Amazon’s Tax Court petition. The IRS designatedAmazon for trial.

Guidant’s appeal against IRS tax adjustments failIn Guidant LLC v. Commissioner, Docket Nos. 5989-11, 5990-11, 10985-11, 26876-11,5501-12, and 5502-12 (February 29 2016), the Tax Court denied the taxpayer’s motion forsummary judgment and held that the IRS’s § 482 adjustments are not arbitrary, capricious,and unreasonable as a matter of law.



Guidant involves a group of US corporations that filed consolidated federal income taxreturns. The IRS’s § 482 adjustments involve transactions between the US consolidatedgroup members and foreign distribution affiliates in Ireland and Puerto Rico.

The IRS asserted an adjustment to the taxpayer’s income under § 482 without makingspecific adjustments to any of the subsidiaries’ separate taxable incomes. The IRS also did notmake specific adjustments for each separate transaction, but rather asserted an aggregatedtransfer pricing adjustment. The taxpayer filed a motion for a partial summary judgmentasserting that the IRS did not determine “true taxable income” of each controlled taxpayeras required under Treasury Regulations § 1.482-1(f)(iv), and did not make specific adjust-ments with respect to each transaction. The court rejected both arguments.

While the court stated that Treasury Regulations § 1.482-1(f)(1)(iv) require the IRS todetermine both consolidated taxable income and separate taxable income when making a§ 482 adjustment with respect to income reported on a consolidated return, the court heldthat as a matter of law the IRS can assert a § 482 adjustment before it determines the separatetaxable income.

The court stated that whether the IRS’s decision to delay the separate-company taxableincome computations constitutes an abuse of discretion under these circumstances is still indispute and remains to be determined on the basis of the full record as developed at trial.Thus, the court did not conclusively hold that the IRS’s § 482 adjustments were not arbi-trary, capricious or unreasonable as a matter of fact. It only held that the IRS’s § 482 adjust-ments were not arbitrary, capricious, or unreasonable as a matter of law.

US



David Abbott is a highly respected tax litigator and transactionallawyer. He advises clients across a broad range of critical issues,with a particular focus on key areas of corporate concern involv-ing tax litigation.

David’s dispute resolution practice emphasises tax litigationand controversy, as well as bankruptcy disputes. He has experi-ence with tax audits and appeals, and represents clients beforethe US Tax Court and the US Court of Federal Claims. David’scurrent and past cases involve corporate acquisition-relatedissues, payment of acquisition-related fees and financing-relatedissues such as debt vs. equity characterisations, debt/equityswaps, transfer pricing and tax treatment of leasing transactions,including LILOs and SILOs. In addition, David has representedequity investors in Chapter 11 bankruptcy cases involving sev-eral leading airlines with respect to aircraft lease tax indemnityagree ment claims.

Straddling his tax litigation and transactional work, Davidhas extensive experience with valuations of business enterprisesplus tangible and intangible assets. He works regularly with val-uation experts to document and justify appraisal conclusions and present or defend them intax audits and litigation.

US

David F Abbott

Mayer Brown

1221 Avenue of the AmericasNew York, NY 10020-1001US




J Bradford Anwyll is a principal in the transfer pricing group ofPwC’s national tax services practice. Brad has more than 30years of experience in tax controversy and litigation mattersinvolving federal and international issues. He has participated inmore than 250 cases before the Internal Revenue Service’sAdvance Pricing and Mutual Agreement programme,Examination Division, and Appeals Office and has litigatedmore than 30 cases before the US Tax Court, the US Court ofFederal Claims, the Federal District Courts, and the US Courtsof Appeals. Brad has represented clients from a variety of indus-tries including telecommunications, consumer products, oil andgas, pharmaceutical, and chemical manufacturing.

Brad has been recognised as one of the country’s leading taxcontroversy and litigation practitioners by International TaxReview’s Tax Controversy Leaders guide since 2013, by Cham -bers USA for national tax litigation in 2008, by the Legal 500 fortax controversy in 2007, and Washington, DC Super Lawyersguide 2007.

Brad is a fellow of the American College of Tax Counsel anda member of the section of taxation of the American BarAssociation, where he served as a member of the Tax Court appointments committee andchair of the court procedure and practice committee. He also is a member of the FederalCircuit Bar Association and the Court of Federal Claims Bar Association, where he served aschair of the tax section.

Brad has written a number of articles on tax controversy issues and was co-author of the1999-2003 Cumulative Supplements to Litigation of Federal Civil Tax Controversies (Warren,Gorham & Lamont, 2nd edition, 1997). He also is a frequent speaker at national tax confer-ences and seminars.

Brad received his JD, with distinction, from the Duke University School of Law and a BA,with University and Departmental (Economics) Honours, from Johns Hopkins University.Following law school, Brad was a judicial clerk to the Honourable Marion T Bennett of theUS Court of Appeals for the Federal Circuit.

US

J Bradford Anwyll

PwC

600 13th Street NW, Suite 1000Washington, DC 20005US




Howard Berman, Deloitte US, is a member of the tax contro-versy services team. Howard specialises in representing clientsbefore the International Revenue Service (IRS) and in coordi-nating complex IRS examinations and appeals for multinationalenterprises. Howard has significant experience handling inboundand outbound transfer pricing matters, was one of the first prac-titioners to use alternative dispute resolution (ADR) techniques(that is, third party mediation) with the IRS and regularly usesfast-track settlement and other ADR techniques to negotiatethe resolution of complex tax disputes for his clients.

In addition to transfer pricing issues, Howard has helpedclients resolve issues surrounding the treatment of debt financ-ing structures, the allocation of interest and other deductions toUS source activities, the determination and computation of tax-payers’ subpart F income and the correct information reportingof transactions between US and related foreign entities. Formore than 20 years, Howard has represented clients in a varietyof industries, including financial services, heavy manufacturing,pharmaceuticals, media and retail.

Howard served as a senior trial attorney for the US Department of the Treasury, and rep-resented the IRS before the US Tax Court. While representing the IRS, Howard served asindustry counsel for the financial services and LBO/merger and acquisition industries. In histenure at the US Department of the Treasury, Howard helped to develop the CoordinatedExamination Programme, and, in that capacity, advised many IRS agents and appellate offi-cers with respect to the development of cases and the resolution of technical issues.

Howard also has significant experience in IRS practice and procedure, penalty and qualitycontrol issues and has spoken and written extensively with respect to numerous IRS practiceand procedure issues. Howard has a JD from the State University of New York at Buffalo –Faculty of Law and Jurisprudence, and a BA from Brandeis University.

US

Howard Berman

Deloitte Tax LLP

30 Rockefeller PlazaNew York, NY 10112-0015US




Kevin Brown is the co-leader of PwC’s Washington national taxservices’ US tax controversy and regulatory services team. Kevinjoined PwC after several notable professional roles, includingstints as acting commissioner of the Internal Revenue Service(IRS) and chief operating officer of the American Red Cross.

In his nine years at the IRS, Kevin worked in a number ofpositions. Most significantly, he served as the acting commis-sioner, where he managed more than 100,000 IRS employeesresponsible for a budget of $12 billion and the collection ofmore than $2.2 trillion dollars, approximately 95% of all federalrevenues.

Other roles held by Kevin at the IRS included: deputy com-missioner for services and enforcement, where he was responsi-ble for the four IRS operating divisions, as well as all staff andactivities related to IRS audits, collections, investigations, andservice delivery, including telephone operations and returnsprocessing; commissioner of the Small Business/Self-Employed(SB/SE) Division, where he oversaw excise, estate and gift, andemployment tax for more than 45 million small business andself-employed taxpayers, and managed Bank Secrecy Act exam-inations on behalf of the IRS; principal adviser and chief-of-staff for former IRS Com -missioner, Mark Everson; as well as division counsel for the SB/SE Division and assistant toformer IRS commissioner, Charles Rossotti. Kevin’s career also includes experience in the USDepartment of Justice, Tax Division, where he served as counsel to the assistant attorney gen-eral, and as a trial attorney who argued more than 50 cases in US Courts of Appeals.

While at PwC, Kevin has represented clients in a broad range of matters, including IRSaudits, appeals and obtaining administrative guidance. In particular, he has helped a numberof companies enter into pre-filing agreements – thereby affording them certainty that theirreturn positions will not be subject to later challenge on audit. In addition, Kevin led a coali-tion of insurance companies in securing an industry-wide resolution allowing them greaterlatitude in their treatment of impaired securities. More recently, he led another insuranceindustry coalition that obtained a safe harbour regarding the treatment of hedging gains andlosses associated with variable annuities.

Kevin earned his JD (cum laude) from Boston College Law School and his BA (cumlaude) from Hamilton College. He is a member of the Massachusetts and District ofColumbia bar associations.

US

Kevin Brown

PwC

600 13th Street, NWSuite 1000Washington, DC 20005-3333US




Cabell Chinnis specialises in audits and appeals, focusing in thecontentious area of transfer pricing. He has obtained speedy andfavourable results by identifying key issues in each case andresolving them. He also has significant experience in advancepricing agreements and tax treaties.

In audit, Cabell provides advice on working with the examteams in special situations, preparing executives and other busi-ness personnel for interviews by the Internal Revenue Service(IRS) or their experts, coordinating presentations to the examteam and resolving discovery disagreements with the exam teamor Department of Justice. Cabell has successfully advised clientson how best to escalate matters within the IRS to senior agencypersonnel to facilitate resolution of audit issues. In appeals,Cabell specialises in handling complex matters and expeditingthe resolution of issues if they are more limited in scope. Hiscases since January 1 2013 have involved section 482 issues in avariety of areas (services, tangible goods, transfers of intangi-bles), valuation disputes, R&D credit, and section 199.

Cabell also handles tax-related alternate dispute resolution,including fast-track and limited issue audits. In addition, hecounsels tax-exempt entities on a full range of matters, including their organisation, operationand sponsorship.

Cabell began his nearly 30-year career by serving as a judicial clerk at the US SupremeCourt for The Hon. Louis Powell, Jr.

US

C Cabell Chinnis

Mayer Brown

Two Palo Alto Square, Suite 3003000 El Camino RealPalo Alto, CA 94306-2112US




Kerwin Chung, Deloitte US, is a principal in the Deloitte TaxWashington national tax office transfer pricing team, and leaderof Deloitte’s national advance pricing agreement (APA) andmutual agreement procedure (MAP) group. Kerwin has morethan 20 years’ transfer pricing experience, specialising in APAs,MAPs, planning, examinations, and customs matters. His clientsinclude US and foreign-based multinationals in numerousindustries, including apparel, automotive, biotech, chemicals,computers, electronics, energy, food and beverage, industrialmachinery, internet, logistics, office products, pharmaceuticals,professional services, publishing, semiconductors, software andtelecommunications.

Kerwin’s practice has involved complex transfer pricingissues, including a bilateral APA and rollback for a pharmaceu-tical company that resulted in the withdrawal of an InternalRevenue Service (IRS) transfer pricing adjustment and penaltyassessment, amounting to more than $100 million. Kerwin hasalso been involved in a bilateral APA, covering cost sharing plat-form contribution transactions and cost sharing transactions fora software company, and bilateral APAs and Competent Authority representations withrespect to inbound and outbound intercompany license transactions in several industries.

Kerwin has co-authored numerous publications, including ‘Seeking efficiencies in the newIRS APA and MAP programmes’, published by International Tax Review (November 2011);‘Competently Negotiating the US Competent Authority Process’, published by the 59 TaxExecu tive No. 3, (May/June 2007); and the ‘Transfer Pricing Rules and Compliance Hand -book’, published by CCH (2006).

Kerwin has been included in Euromoney’s Transfer Pricing Expert Guide since 2002 andin International Tax Review’s Tax Controversy Leaders guide since 2015. He is an activemember of the ABA tax section transfer pricing committee, having moderated a panel ontransfer pricing in a down economy issues in 2009 and presented on a panel discussing theIRS APA programme in 2011.

He has a JD (cum laude) from Harvard Law School and a BBA in accounting and realestate from the University of Hawaii. Kerwin has been admitted to the New York Bar and theDistrict of Columbia Bar.

US

Kerwin Chung

Deloitte Tax LLP

555 12th St. NW, Suite 400Washington, DC 20004US




Kenneth Clark is a partner in the tax group of Fenwick & Westand chairs its tax litigation practice. The firm has receivednumerous accolades for its tax controversy practice, includingrecognition by International Tax Review as US tax litigationfirm of the year in three different years. The principal focus ofKenneth’s practice is complex federal tax litigation and tax con-troversy work, with a significant emphasis on transfer pricingand international issues. He regularly practices in the US TaxCourt and has appeared in many federal and state courts. He iswidely published in the field of tax controversies.

Kenneth has worked on numerous high profile tax contro-versy matters for clients such as Xilinx Inc., The Limited, Inc.,Lim ited Brands Inc., Textron Inc., Apple Inc., Daimler AG, GMTrading, Dover Corporation, Adaptec, Inc., Analog Devices,Office Depot, and CBS.

With four decades of experience, Kenneth also has manageda variety of complex commercial disputes in a number of foreigncountries and more than 20 states. Litigation prevention andalternative dispute resolution (ADR) also have been importantparts of his practice. He has served as Fenwick & West’s ADRcoordinator, as an American Arbitration Association arbitrator,and has been involved in numerous mediations and arbitrations.

Kenneth received a BA from the University of Redlands (summa cum laude), and was firstin his class. He received a JD from New York University School of Law (cum laude), and wasa member of that school’s Law Review. Kenneth also received an MBA from the Universityof California at Berkeley.

US

Kenneth B Clark

Fenwick & West

Silicon Valley Centre801 California StreetMountain View, CA 94041US

Tel: +1 650 335 7215Fax: +1 650 938 5200Email: [email protected] Website: www.fenwick.com



Ward Connolly is a principal in PwC’s national tax services(NTS) group and is resident in the firm’s Silicon ValleyTechnology Center of Excellence in San Jose, California. Wardis a member of PwC’s advance pricing, mutual agreement andtransfer pricing controversy practice. Ward has 20 years of expe-rience as a tax professional and has represented US and foreignmultinational enterprises in complex tax audits, administrativedisputes (IRS Appeals), alternative dispute resolution (e.g.mediation), advance pricing agreements (APAs) and litigation.

Ward has been recognised as one of the world’s leading taxcontroversy advisers by International Tax Review and one ofthe best lawyers in the San Francisco Bay Area by Bay AreaLawyer magazine. Ward has also been recognised in Inter -national Tax Review’s World Tax guide for his skills in transferpricing, where he has extensive experience with the issues facedby clients in the high-tech, biotech, and pharmaceutical indus-tries.

Prior to joining PwC, Ward was a partner at Fenwick &West. Ward was previously a faculty member in the Departmentof Economics at Trinity University.

Ward earned his JD, with honours, from Duke University School of Law, and his PhD ineconomics and his BA from the University of South Carolina. Ward is a member of theCalifornia Bar Association and has written many technical articles for trade journals and otherpublications. Ward has been a frequent speaker for professional tax groups, including numer-ous chapters of the Tax Executives Institute and BNA/CITE.

US

Ward Connolly

PwC

488 Almaden BoulevardSan Jose, CA 95110US




Daniel Cook, Deloitte US, is a managing director specialising infederal tax controversy services.

Dan has represented taxpayers at all stages of federal tax con-troversy, including IRS examinations, the IRS administrativeappeals process, alternative dispute resolution proceedings, andcollection due process matters. In addition, he has advisedclients regarding pre-examination matters including audit readi-ness studies, internal company compliance initiatives, strategicplanning initiatives and proactive voluntary disclosure initiativesby taxpayers to the IRS. Prior to joining Deloitte Tax, Dan alsorepresented taxpayers in litigation proceedings before the USTax Court, the US District Court, the US Federal Court ofClaims and in post-trial appeals to the US Circuit Courts ofAppeals.

Dan’s clients have included multinational enterprises in thefinance, insurance, oil and gas, and pharmaceutical industries, aswell as professional partnerships and their members, and indi-viduals.

Dan received a BA in 2000 from Carleton College; a JD,with distinction, in 2004 from the University of Iowa College of Law; and a LLM in taxation,with honours, in 2005 from the Northwestern University School of Law.

US

Daniel Cook

Deloitte Tax LLP

Chicago, IllinoisUS




A principal since 2000, Anthony Curtis is a senior economist,transfer pricing specialist and leader of the New York metro taxcontroversy practice, integrating tax controversy resolution andprevention specialists from federal and international tax, transferpricing, state and local tax with former government and otherspecialists. Tony has 26 years of experience conducting econom-ic analysis for PwC. For 24 years, he has specialised primarily inthe economics of intercompany pricing, including planningstudies to help taxpayers determine appropriate transfer pricesfor future transactions, economic studies for use in the defenceof transfer prices under examination, and economic analysis forAPA and Competent Authority negotiations with the IRS andforeign tax authorities.

He currently is negotiating several APAs, transfer pricingaudits, and Competent Authority cases with the Internal Rev -enue Service for his clients, including bilateral and multilateralcases involving China, Switzerland, and the UK.

Tony is also the US retail and consumer products sectorleader for the transfer pricing practice. As a result of this role,Tony works with PwC’s leading retail, luxury goods, and con-sumer products clients to ensure that they have access to thebest practices and personnel of the PwC network.

He previously was the leader of the NY transfer pricing region, the practice’s globallycoordinated documentation service offering, as well as the Americas editor for PwC’s transferpricing news articles. He is also a frequent author and presenter. Tony is also passionate aboutPwC’s people and enjoys recruiting and working on PwC’s diversity and inclusion initiatives.

Tony previously taught graduate courses in business economics and money and bankingat Johns Hopkins University. He has a MBA with a concentration in marketing and a BBAwith a concentration in business economics and public policy from The George WashingtonUniversity and has completed several graduate classes in taxation at Fordham University.

US

Anthony Curtis

PwC

300 Madison AvenueNew York, NY 10017US




Paul DiSangro focuses his practice on resolving tax disputeswith the IRS and state agencies. Paul obtains favourable resultsin an efficient time frame by collaborating with clients to devel-op a clear strategy for navigating the thorny issues that arise incomplex tax cases. He has more than 20 years’ experience, rep-resenting clients in all facets of tax controversy, including auditsand administrative appeals, alternative dispute resolution, andlitigation.

Paul has successfully handled a broad range of tax issues withthe IRS, including, most recently, transfer pricing, cost sharing,subpart F exceptions, the R&D credit, the section 199 domesticproduction activity deduction, IP migration and valuation dis-putes, captive insurance company benefits, executive compensa-tion, depreciation, capitalisation, deductions, withholding,independent contractors vs. employees, offshore accounts, part-nership issues, and debt vs. equity. At present, Paul is litigatinga section 199 issue for a mineral makeup company in a US taxcourt.

Paul also has extensive state and local tax controversy expe-rience with the California Franchise Tax Board, the CaliforniaBoard of Equalisation, the California Employment Development Department, and theCalifornia Unemployment Insurance Appeals Board, as well as with tax agencies in otherstates. His recent state cases have included state transfer pricing and valuation disputes, alter-native apportionment, sales and use taxes for online sales, trust and estate issues, market-based sourcing, tax shelters, independent contractors vs. employees, and navigating voluntarydisclosure programs in more than 40 states.

Paul is recognised as a leading tax controversy adviser in the Tax Controversy LeadersGuide 2016. Paul has written several important works on US and international tax issues, andspeaks and presents at professional tax seminars and symposia. He is the organiser of theannual Tax Controversy Seminar in Silicon Valley with the Tax Executives Institute. In addi-tion, he has taught international tax classes as an adjunct professor at the LLM level. Prior tojoining Mayer Brown in 2003, Paul practiced in Washington DC and San Francisco with twoother prominent international law firms.

US

Paul DiSangro

Mayer Brown





Thomas J Driscoll, Deloitte US, is the partner in charge ofDeloitte’s international tax and transfer pricing practice.Thomas received a bachelor of science degree, with honours,from the University of Illinois Urbana-Champaign and a mas-ter’s of science degree with distinction from DePaul University.

Thomas specialises in the international tax, trading and treas-ury area, assisting multinational clients with financing strategies,tax efficient supply chain structuring, intellectual property plan-ning strategies, hedging/risk management strategies, foreigntax credit planning, repatriation techniques and global tax min-imisation. Clients served include US and non-US based multi-national enterprises and financial market participants.

Thomas is a frequent speaker on various topics involving fed-eral income taxation and regularly speaks at Deloitte Taxnational training, as well as external seminars and conferences.Thomas previously was an adjunct professor at the University ofChicago Graduate School of Business and taught at North -western University’s JL Kellogg Graduate School of Management.

Thomas is a certified public accountant and a member of theAmerican Institute of Certified Public Accountants and Illinois Society of CPAs.

US

Thomas J Driscoll

Deloitte Tax LLP

111 S Wacker DrChicago, IL 60606-4301US




Daniel Dumezich, Deloitte Tax LLP, is the managing directorof federal tax controversy services. Before joining Deloitte Tax,Daniel was in the private practice of law for 26 years, includinga four year term as the chair of the federal tax controversy prac-tice at a major international law firm.

During his practice of law, Daniel has tried cases in the USTax Court involving §482 reallocations and subpart F issues.He has also tried matters involving the deductibility of interestexpense relating to a debt versus equity characterisation, a debt-equity swap, and capitalisation versus current deductibility ofexpenditures. Acquisition-related issues he has tried include val-uation of assets and tax advantaged structuring.

Outside of litigation, Daniel has settled cases favourably forhis clients, including his representation of 980 former partnersof a large professional firm in a case in which the IRS soughtmore than $450 million in taxes – the matter settled for approx-imately 5% of that amount. He has achieved similar results formajor financial institutions including banks, hedge funds, insur-ance companies and individuals involved with tax advantagedtransactions deemed abusive by the IRS. Also he has represented clients on income and with-holding tax matters.

Daniel served as a judge in Indiana and in Indiana’s General Assembly as a state represen-tative. He is also a frequent speaker on various tax controversy topics for a variety of organi-sations.

Daniel received a bachelor of business administration with a major in accounting in 1982from Western Michigan University and a master of science in taxation in 1985 from DePaulUniversity. He received a juris doctor with the highest distinction in 1989 from the JohnMarshall Law School.

US

Daniel Dumezich

Deloitte Tax LLP

111 South Wacker DriveChicago, IL 60606US




Jeffry Erney focuses his practice on tax litigation and disputeresolution. When representing clients faced with complex issues,Jeff draws on years of experience as a senior tax attorney for theOffice of Chief Counsel with the Internal Revenue Service(IRS), as well as his background as a certified public accountant(CPA), to most effectively provide counsel.

Jeff’s background, both in private practice and as a govern-mental attorney, provides him with the tools to assess thestrengths and risks of each issue, negotiate favourable settle-ments with the government and, if necessary, litigate the matterbefore the appropriate court. Jeff easily adapts to the venue inwhich he finds himself practicing, whether it is in front of theIRS or in trial, and does not lose focus of his clients’ objectivesthroughout the representation process.

Jeff has litigated more than 30 cases in the US Tax Court inaddition to negotiating over 100 favourable settlements withthe IRS at the examination, appellate and counsel level.

Jeff is listed in The Best Lawyers in America guide (2007–2016) and the Ohio Super Lawyers (2008–2009, 2011–2015)and has been a frequent speaker before the Tax Executive Institute, the American BarAssociation’s tax section and the Cleveland Tax Institute. The US tax controversy practiceand criminal tax practice was recognised by The Legal 500 in 2016 for outstanding work incontentious tax.

Jeff was the panel chair for practice and procedure at Cleveland Tax Institute (2015, 2013,2011, 2008, 2006) and has been the primary author of ‘Representation Before The UnitedStates Tax Court’ (Thomson West 2014) since 2007.

US

Jeffry Erney

Dentons

1900 K Street NWWashington, DC 20006US




David Forst is the practice group leader of the tax group ofFenwick & West.

David’s practice focuses on international corporate and part-nership taxation. He is a lecturer at Stanford Law School oninternational taxation. He is an editor of and regular contribu-tor to the Journal of Taxation, where his publications haveincluded articles on international joint ventures, internationaltax aspects of mergers and acquisitions, the dual consolidatedloss regulations, and foreign currency issues. He is a regularcon tributor to the Journal of Passthrough Entities, where hewrites a column on international issues.

David graduated with an AB (cum laude) Phi Beta Kappa,from Princeton University’s Woodrow Wilson School of Publicand International Affairs, and received his JD, with distinction,from Stanford Law School.

He is included in Euromoney’s Tax Advisers Expert Guideand in Law and Business Research’s International Who’s Who ofCorporate Tax Lawyers (for the last seven years). David wasnamed one of the top tax advisers in the western US byInternational Tax Review, is listed in Chambers USA America’sLeading Lawyers for Business (2011-16), and has been named a Northern California SuperLawyer in Tax by San Francisco Magazine.

David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute,the Tax Executives Institute, and the International Fiscal Association.

US

David Forst

Fenwick & West


Tel: +1 650 335 7254Email: [email protected]: www.fenwick.com



Jim Fuller is a partner in the tax group at Fenwick & West inMountain View, California. He is one of the world’s top 25 taxadvisers, according to Euromoney. Fuller is described as one ofthe three “most highly regarded” US tax practitioners in LawBusiness Research’s Who’s Who Legal (2015), and is the only UStax adviser to receive a coveted Chambers ‘star performer’ rating(higher than first tier) in Chambers USA (2016).

Fuller and his firm have served as counsel in more than 150large-corporate IRS Appeals proceedings and more than 70 fed-eral tax court cases. Seven Fenwick tax partners appear inInternational Tax Review’s Tax Controversy Leaders guide.Fenwick has been named US (or Americas) ‘Tax Litigation Firmof the Year’ three times at International Tax Review’s annualAmericas Awards.

Two of our tax partners were shortlisted by Euromoney at itsWomen in Business Law Awards in the America’s ‘LeadingLawyer for Tax Dispute Resolution’ category. One is a two-timewinner of the award.

Much of our tax dispute resolution work has involved trans-fer pricing. Fenwick & West is first tier in International TaxReview’s World Transfer Pricing guide (2016). Five Fenwick tax partners have appeared inEuromoney’s Transfer Pricing Expert Guide. Transfer pricing cases in which we have beeninvolved include: Apple Computer, Xilinx, DHL, and LimitedBrands, among others. The vastmajority of our transfer pricing cases have been resolved in appeals, some on a ‘no change’basis.

Other cases in which we’ve represented clients in federal tax litigation matters includethose that involved Sanofi, CBS, Analog Devices, Dover, Chrysler, Textron, JohnsonControls, Del Commercial, Illinois Tool Works, VF, S.C. Johnson, Intel, CMI Int’l, Laidlaw,Hitachi, Union Bank, GM Trading, and others.

US

James Fuller

Fenwick & West

Silicon Valley Center801 California StreetMountain View, CA 94041US

Tel: +1 650 335 7205Fax: +1 650 919 0942Email: [email protected]: www.fenwick.com



Jennifer Fuller is a senior partner in the tax group at Fenwick &West in Mountain View, California. She was included for thefifth time as one of the world’s top 25 women tax advisers inEuromoney’s guide to the world’s leading women businesslawyers (2015).

Jennifer was named ‘America’s Best in Tax Dispute Resolu -tion’ by Euromoney at its 2014 and 2015 Americas Women inBusiness Law awards, the only repeat winner. She also has beenon Euromoney’s ‘Women in Business Law’ shortlist four timesfor the award ‘Best in Tax’.

Jennifer’s work during 2016 included large-corporate tax lit-igation and M&A matters, including work on some of therecent and widely publicised inversion transactions.

Jennifer is on the executive leadership committee of theInternational Fiscal Association, which is a highly-regardedworld wide association of leading tax advisers, and has appearedregularly in Euromoney’s guide to the world’s leading taxlawyers.

Jennifer has served as the Northern California chair for theCalifornia State Bar International Tax Committee. She has spo-ken at and chaired numerous seminars on international tax subjects. Jennifer’s articles haveappeared in Tax Notes International magazine and in Tax Notes magazine.

Whittier College awarded Jennifer its Alumna Achievement Award in 2013 “for superioraccomplishments in her career”. Later that year, Jennifer was elected to serve on the WhittierCollege Board of Trustees, a position she still holds.

Jennifer has been a tax partner at Fenwick for more than 20 years, and plays an instrumen-tal role in the firm’s tax practice. The firm has represented six of the Fortune top 10 compa-nies, more than 50 of the Fortune 100 and more than 100 of the Fortune 500 companies infederal tax matters.

Jennifer has also been included in Euromoney’s guide to the world’s leading tax advisers,Law and Business Research’s International Who’s Who of Corporate Tax Lawyers,International Tax Review’s leading lawyers in the western US, Euromoney’s guide to the lead-ing US tax lawyers, and International Tax Review’s guide to the best tax advisers in NorthAmerica.

US

Jennifer Fuller

Fenwick & West





Erin Gladney is a tax controversy partner in Mayer Brown’sNew York office. Erin represents clients in all stages of federaltax controversies, including audits, administrative appeals, andlitigation. Her experience includes controversies involvingtransfer pricing, advance pricing agreements, economic sub-stance, substance-over-form doctrines, and summons enforce-ment. Erin also has experience defending against civil tax penal-ties and preserving taxpayers’ attorney-client privilege and workproduct protection during audit, appeals, and litigation.

Mayer Brown was recently named ‘Tax Controversy Team ofthe Year’ for the second consecutive year in the Legal 500 USAwards. “Mayer Brown is ‘among the best’ and fields a largeteam…dedicated exclusively to tax controversy and transferpricing,” said Legal 500 and its sources in the US edition. Thefirm is “regularly seen in the most high-profile controversy casesbefore the US Tax Court” and produced “yet another impres-sive run of work” in 2014.

US

Erin G Gladney

Mayer Brown





John Hildy has represented taxpayers in all stages of federal taxcontroversy, including pre-audit, audit, administrative appeals,and litigation.

He is also experienced in representing taxpayers during IRSfast-track proceedings and in court-supervised mediation. Johnhas also advised taxpayers in connection with CompetentAuthority negotiations, advance pricing agreements, and othertax treaty matters.

John’s practice focuses heavily on defending and structuringtransactions with significant transfer pricing implications,including cross-border transfer pricing of tangible and intangi-ble property, shared headquarter services, and cost sharingarrangements. He has advised both US taxpayers with respect tointernational tax implications of offshore operations (for exam-ple, subpart F manufacturing, section 936), as well as non-UStaxpayers with respect to the implications of their US activities.

John has extensive experience defending against civil andcriminal tax penalties and in addressing evidentiary privileges inthe tax controversy context, including the attorney client privi-lege and work product protection in the modern business environment in light of IRS poli-cies concerning tax accrual work papers.

US

John T Hildy

Mayer Brown

71 S Wacker DriveChicago, IL 60606US




Cindy Hustad, Deloitte Tax LLP, is the West Region tax con-troversy competency leader and represents corporate clientsbefore the IRS. During her 15-year tenure at Deloitte, Cindyhas successfully represented many large and small clients, bothat the examination and appeals levels, specialising in transferpricing and international issues. Before joining Deloitte, Cindywas a special trial attorney with the IRS Chief Counsel’s Officewhere she represented the IRS in the US Tax Court in upwardsof 50 litigated cases. During her period at the IRS, Cindy alsoadvised large case agents, international examiners, and appealsofficers in some of the largest examinations undertaken by theIRS involving a wide range of complex international anddomestic corporate issues. Cindy also represented the govern-ment in litigating several large corporate tax and transfer pricingcases, including DHL v. Commissioner. Cindy has also held theposition of law clerk at the US Court of Appeals for the NinthCircuit, while other positions held include acting assistant pro-fessor at the New York University Law School.

Cindy is admitted to the state bar of California, holds anadmission to practice at the US Tax Court and is a past president of the San Francisco TaxLitigation Club. She was also the recipient of the IRS Chief Counsel National LitigationAward in 1997.

Cindy holds a BA from the University of Wisconsin, a JD from the University of Wiscon -sin Law School and achieved her LLM (tax) at the New York University Law School.

US

Cynthia Hustad

Deloitte Tax LLP

555 Mission StreetSan Francisco, CA 94105-0920US




Sharon Katz-Pearlman is the national principal-in-charge ofKPMG’s tax dispute resolution network in the US. She alsoserves as KPMG International’s head of global tax dispute reso-lution and controversy, overseeing a network of dispute resolu-tion specialists from KPMG’s member firms.

Sharon advises clients during all phases of the disputes con-tinuum, from pre-dispute (for instance, audit readiness, volun-tary disclosures and pre-filing assistance) through examination,appeals and alternative dispute resolution (ADR) processes.With more than 25 years of experience in the field, Sharonworks with clients on all aspects of their IRS matters, dealingwith a wide variety of domestic and international tax issues.

Sharon’s US practice focuses primarily on representationbefore the IRS, of multinational corporate clients and financialinstitutions, both domestic and international. She providesassistance in all facets of alternate dispute resolution (ADR),including pre-filing agreements, early referral and mediation, aswell as traditional examination and appeals consulting. Sharonadvises on disputes involving a wide range of technical issuesincluding domestic corporate reorganisations, TEFRA matters,Competent Authority proceedings and transfer pricing issues.

Before joining KPMG, Sharon was a special litigation attor-ney with the IRS Office of Chief Counsel, Manhattan District Counsel, advising many examand appeals teams on varied issues. She was also responsible for the development and litiga-tion of major tax matters before the US Tax Court and served on a number of litigationteams. While with the IRS, Sharon received the National Attorney of the Year award (theJames Markham Memorial Award), presented annually to one field attorney in the country,for outstanding contribution to the Office of Chief Counsel.

Sharon is an adjunct professor of law at NYU Law School, where she teaches Civil TaxControversies and Litigation in the graduate tax (LLM) program. She is a frequent presenterat tax conferences and has published a variety of industry articles on various domestic andinternational tax topics.

US

Sharon Katz-Pearlman

KPMG

345 Park AvenueNew York, NY 10154US

Tel: +1 212 872 6084Fax: +1 212 409 8270Cell: +1 917 533 3375Email:[email protected]: www.kpmg.com



John R Keenan, Deloitte Tax LLP, is the managing director ofthe tax controversy group in the Washington national tax office.

In his role as a tax controversy specialist, John representsclients before the IRS Examination Division and IRS Appeals.John also assists clients on a wide range of procedural issues,such as statute of limitations, refund claims, and penalty issuesas well as solving sensitive problems through strategic solutions.Before joining Deloitte, John worked in Arthur Andersen’s fed-eral tax services office, specialising in tax controversy issues.

From 1988 to 1998, John served as a senior attorney in theIRS Chief Counsel’s Office where he represented the IRSbefore the United States Tax Court and provided advice to IRSpersonnel on all matters incident to the assessment and collec-tion of taxes. John also was appointed a special assistant USattorney, which allowed him to represent the IRS in the USBankruptcy Courts.

John has a number of qualifications and memberships. Hehas been admitted to the District of Columbia Bar and theTennessee Bar, and is admitted to practice in the US Tax Court.He is a member of the administrative practice committee of the American Bar Association,and a member of the IRS advocacy and relations committee at the American Institute ofCPAs (AICPA). John also frequently speaks to professional groups on IRS controversy andIRS practice issues.

He has a JD from the University of Memphis and a BA from Rutgers University.

US

John Keenan

Deloitte Tax LLP

555 12th St NW Ste 400Washington, DC 20004-1207US




Andrew Kim is a partner in the tax group of Fenwick & West.His practice focuses on both domestic and international corpo-rate tax matters, with an emphasis on tax dispute matters.Andrew served as counsel in CBS Corporation v. United Statesin the US Court of Federal Claims, and is now serving as coun-sel in Analog Devices, Inc. v. Commissioner, and TBL LicensingLLC v. Commissioner in the US Tax Court.

Andrew appears in Euromoney’s world’s leading tax advisersguide, International Tax Review’s Tax Controversy Leaders guide,Law Business Research’s Who’s Who Legal: Corporate Tax, TheLegal 500, and Chambers USA.

Andrew has significant experience in representing clientswith respect to cross-border transactions, corporate restructur-ings, international joint ventures, transfer pricing, as well as dis-pute resolution matters. He has published articles on interna-tional tax issues and developments in the Journal of Taxation,International Taxation, the Euromoney Corporate Tax Hand -book, and World Tax. Andrew frequently speaks on internationaltax issues at meetings for professional tax groups, including theTax Executives Institute and Bloomberg BNA.

Fenwick’s tax practice has earned a reputation as one of the nation’s leading domestic andinternational tax practices. Fenwick was named US (or Americas) Tax Litigation Firm of theYear three separate times by International Tax Review. Fenwick has also been recognised byInternational Tax Review as first tier in both its World’s Leading Tax Planning Firms andWorld’s Leading Transactional Firms surveys, and has been recognised as Americas M&A TaxFirm of the Year.

Andrew received his JD (cum laude) from Harvard Law School, and BS in psychologywith highest honours from the University of Illinois.

Andrew is a member of the state bars of California and Illinois.

US

Andrew Kim

Fenwick & West





Tom Kittle-Kamp is the co-leader of Mayer Brown’s tax contro-versy and transfer pricing practice.

His litigation experience includes the trial and appeal ofmajor corporate cases involving Section 482 allocations, sub-stance-over-form theories, intangible assets, debt-equity charac-terization, valuation disputes, capitalisation questions, SubpartF and other international tax issues, Subchapter C issues, andleasing transactions.

Tom also maintains an extensive practice of advising and rep-resenting clients with respect to administrative matters, includ-ing IRS audits, IRS appeals (including fast track and appealsmediation procedures) and Competent Authority negotiations.He also represents corporate clients with respect to tax-sharingdisputes.

Tom has extensive experience in all aspects of internationaltransfer pricing, particularly matters involving intangible assetsand intellectual property. He provides tax planning advice withrespect to cross-border transactions involving intangible assets,goods and services, transfer-pricing documentation, and thedevelopment, exploitation and disposition of intangible assets, including licenses, sales andcost-sharing arrangements.

He is the co-author of the treatise Federal Income Taxation of Intellectual Properties andIntangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year.

Before law school, he worked for several years as a newspaper reporter.

US

Thomas Kittle-Kamp

Mayer Brown





Brian Kittle is co-leader of Mayer Brown’s tax controversy &transfer pricing practice.

Since joining the firm in 2006, Brian has represented clientsin every facet of tax controversy and litigation. This includesIRS examinations and administrative appeals, through the litiga-tion of highly complex tax controversies involving a broad rangeof international and domestic tax issues. This includes having alead role in the recent Eaton transfer pricing US Tax Court lit-igation. His controversy experience also includes frequent use ofIRS alternative dispute resolution tools, including pre-filing andadvance pricing agreements, and defending taxpayers in sum-mons enforcement proceedings.

In addition to his controversy practice, Brian provides taxadvice on related-party and highly-sophisticated transactionsinvolving acquisitions and integrations. He also frequentlyspeaks and writes articles about substantive and procedural taxissues.

Brian has been repeatedly recognised as a rising star byInter national Tax Review’s Tax Controversy Leaders guide andSuper Lawyers. He was also recently recognised by Chambers USA as a noted practitioner fortax in New York.

Before joining Mayer Brown, Brian served as an attorney advisor to Judge Joseph R.Goeke of the US Tax Court. This experience provided him with unique insight into thecourt’s procedures and decision making process.

US

Brian W Kittle

Mayer Brown





Kenneth Klein concentrates his practice on international taxa-tion. His experience includes planning, structuring/restructur-ing, tax controversies, regulations, legislation, private letter rul-ings, and amicus briefs. He has represented domestic and inter-national clients in numerous industries, including manufactur-ing, financial services, software, transportation, pharmaceuti-cals, services, real estate, agricultural, trading, and entertain-ment, among others.

Ken has experience with outbound investments, inboundinvestments, income bifurcation and amalgamation, controlledforeign corporations (subpart F), investments in US property,in tangibles, contract manufacturing, source of income, foreigntax credits, transfer pricing, portfolio interest, conduit financingarrangements, withholding tax, tax treaties, investment funds,derivatives, and stock and securities lending.

Ken was co-chairman of Mayer Brown’s tax transactionspractice from 2006-12. Before Mayer Brown, he worked at theIRS, first as attorney and then as assistant branch chief in theLegislation & Regulations Division and the General LitigationDivision (1977-81), and later as the Associate Chief Counsel (Technical) (1988-90). Ken wasan associate and then a tax partner at Cadwalader, Wickersham & Taft from 1981-88 and1990-2002. He was also a fellow of the American Society of International Law (1976-77).

Year after year Ken is recognised for his skills in international taxation. He has been laudedby clients for his “sophisticated cross-border tax planning, structuring and restructuring fora number of US and non-US multinationals”. Legal 500 2016 refers to Ken as “very experi-enced” and has named him a leading lawyer for six consecutive years. For the past seven years,Ken has been named among the World’s Leading Tax Advisers (Euromoney/InternationalTax Review). He is recognised as a leading tax controversy adviser in the International TaxReview Tax Controversy Leaders guide and named among the ‘Best Tax Lawyers’ in Washing -ton DC by Washingtonian Magazine and Washington Post Magazine. Ken has also been fea-tured as a leading tax lawyer in Washington DC by Super Lawyers for six consecutive years.

Ken is chair of the Washington International Tax Study Group, president of the Legal AidSociety of the District of Columbia and is on the board of visitors of the University ofGeorgia School of Law.

US

Kenneth Klein

Mayer Brown

1999 K Street, NWWashington, DC 20006-1101US




Attorney Larry Langdon brings comprehensive experience inthe areas of tax controversy and planning to clients’ service. Heis widely recognised for his knowledge of federal tax policies andapplications and has been characterised by Chambers USA as “agreat tax mind”.

Larry has been a speaker at the American Bar AssociationSection of Taxation, American Institute of CPAs, ManufacturersAlliance, Tax Executives Institute and many other professionaland industry groups.

Larry joined Mayer Brown in 2003. Previously, he held sen-ior positions with the US Internal Revenue Service (Commis -sioner, large & mid-size business division, 1999–03; legislationand regulations division, office of counsel, 1964–68; and jointcommittee division, office of chief counsel, 1961–62). In theprivate sector, Larry has worked with leading firms such asHewlett-Packard (VP, general transition manager, 1999; VP,tax, licensing and customs, 1978–99); Vetco (director of taxesand corporate secretary, 1976–1978); and the Ford MotorCompany (senior tax attorney, general counsel’s office, 1968–76). Larry also worked with the CARE organisation from1962–64.

US

Larry R Langdon

Mayer Brown





Marc Levey is a partner in the New York office of Baker &McKenzie. He has more than 35 years of experience in interna-tional taxation and is a nationally recognised expert in his field,particularly in structuring and defending transfer pricing strate-gies. He has frequently been acknowledged by Euromoney in itsguide to the world’s leading tax advisers and included in its Bestof the Best global tax experts.

Marc’s practice focuses on transfer pricing and cross-bordertransactions; tax controversies and litigation; general corporate,international and partnership taxation, and restructuring multina-tional company’s global operations. He has worked in variousindustries such as pharma/life sciences, financial institutions,energy, automotive, chemicals, electronics, consumer goods,gaming, fashion and luxury products. Marc serves on the UStransfer pricing management committee, was the past chairman ofthe firm’s global transfer pricing steering committee and is co-chair of the firm’s luxury and fashion industry practice group.

Marc previously served as tax attorney with the internationaltax ruling group of the National Office of the Internal RevenueService (IRS) from 1975 to 1977. He acted as senior trial attor-ney with the Tax Division of the US Department of Justice from1977 to 1981. He was the Special Attorney to the Attorney General of the US Departmentof Justice in 1982.

Marc represents a wide range of clients in proceedings before the IRS and federal courtsand has substantial experience in handling tax controversies. He has been, and still is, taxcounsel to numerous significant Tax Court and US Claims Court cases and has also success-fully negotiated conclusions to numerous IRS tax audits, appeals controversies, fast trackappeals, Competent Authority matters and advance pricing agreements.

Marc has been a featured speaker at numerous international tax seminars throughout theworld. He is also the editor and author of tax treatises US Taxation of Foreign ControlledBusiness, co-author of International Transfer Pricing OECD Guidelines, Warren GormanLamont treatises, the co-author of Transfer Pricing: Rules, Compliance and Controversy 4thEdition, CCH Incorporated, the co-author of Transfer Pricing: Alternate Practical Strategies890 Tax Management Foreign Income Portfolios (2001 and 2007), co-editor of TransferPricing and Dispute Resolution (IBFD 2011) and co-editor of Transfer Pricing and Intra-Group Financing (IBFD 2012). Marc has authored more than 180 publications over the last20 years in leading global tax publications.

He received his JD from University of Cincinnati College of Law in 1972 and his BS fromWilkes University in 1969. He received his LLM in taxation with honours from Universityof Miami Law School in 1983. He is admitted to practise in the states of New York, Californiaand in the District of Columbia.

US

Marc Levey

Baker & McKenzie

452 Fifth AvenueNew York, NY 10018US

Tel: +1 212 891 3944Fax: +1 212 310 1644Email:[email protected]:www.bakermckenzie.com



Trained as a lawyer and a certified public accountant, DarrinLitsky, Deloitte US, is a transfer pricing specialist in the NewYork office. Darrin has a diverse background of 30 years of pro-fessional tax and accounting experience with industry, the Big 4firms in public accounting, major law firms, and the InternalRevenue Service’s (IRS) advance pricing agreement (APA) pro-gramme. While in industry, Darrin served as general tax counselof a publicly owned telecommunications company and wasresponsible for its worldwide transfer pricing.

Darrin served as a team leader for four years with the IRSAPA programme. During his time in government practice,Darrin has been substantively involved in hundreds of APA andmutual agreement procedure (MAP) requests involving a vari-ety of different countries and industries. His current transferpricing practice is primarily on APA and MAP request represen-tations and audit defense.

Darrin is a past chairman of the transfer pricing committeeof the American Bar Association (ABA) tax section. Over thepast 15-plus years, he served as the committee’s chairman, vicechairman, led subcommittees on APAs, intercompany services, and important developments,and received the committee’s Outstanding Service Award for 2003/04.

In 2014, Darrin led an ABA taskforce that provided formal comments to the IRS on pro-posed procedures for obtaining an APA. Similarly, in 2005, Darrin was responsible for leadingthe ABA’s formal comments to the IRS on the operation of the APA programme and pro-vided oral testimony. In 2004 and 2006, Darrin led and participated in ABA task forces thatprovided formal comments on proposed and temporary Treasury regulations for transferpricing of intercompany services.

Darrin has given numerous speeches and presentations over the years at the ABA, theAmerican Conference Institute, New York University, Tax Executive Institute, BroadbandTax Institute, CITE, ATLAS, and at IRS meetings and conferences on transfer pricing issuesand APAs.

He has written and co-authored several articles, including ‘Strategic Considerations forTax Controversy Risk Management and Double Taxation Avoidance’ for International TaxReview (March 2016) with S Kumar and E Lesprit, and published ‘Comments on Notice2013-79 Proposed Procedures for Advance Pricing Agreements’ with ABA members for theABA on March 18 2014.

Darrin holds a BS Economics degree (magna cum laude) from The Wharton School anda JD degree from Georgetown University Law Center. He is a member of the District ofColumbia Bar and a certified public accountant (New York and New Jersey).

US

Darrin Litsky

Deloitte Tax LLP

30 Rockefeller PlazaNew York, NY 10112-0015US




James (Jim) Mastracchio is a seasoned advocate who chairsDentons’ US tax controversy practice and criminal tax practice,which was recognised by Legal 500 in 2016 for outstandingwork in contentious tax.

Jim’s work focuses on advising clients facing civil and crimi-nal tax investigations. His work in civil tax disputes includes awide range of civil tax reporting issues and the defence of struc-tured products, tax-driven structures and their promotion. Inthe criminal tax arena, Jim represents clients facing tax fraud andevasion, conspiracy, obstruction, mail/wire fraud and monetarystructuring charges.

Jim has represented regulated financial institutions withinand outside the US on a variety of civil and criminal tax investi-gations. He served as an independent examiner for a majorSwiss banking institution, advised foreign financial institutionson the implementation of the Foreign Account Tax ComplianceAct (FATCA) and the Organisation for Economic Cooperationand Development OECD reporting standards, and was leadcounsel involving the first criminal tax investigation conductedby US authorities of a Cayman Island financial institution and its subsidiaries.

Jim has also represented more than 400 individuals located across the globe who have par-ticipated in the Internal Revenue Service’s (IRS) offshore voluntary disclosure programmesto resolve disputes involving previously undisclosed offshore accounts and structures. He reg-ularly practices before the IRS (including the IRS Office of Appeals and IRS CriminalInvestigation), the Department of Justice’s tax division and various US attorneys’ officesacross the country, as well as in federal court.

Jim has been recognised as a leading national tax controversy lawyer in the US Legal 500Litigation guide and Super Lawyers. He is the author of the chapter ‘Best Practices forManaging Tax Investigations’ in ‘Inside the Minds: Common Issues in White Collar Law’,published by Thomson West Publishing (2007). He has been widely quoted in the nationalmedia, including by The New York Times, The Wall Street Journal, The Washington Post,Market Watch, Bloomberg BNA, Tax Analysts, CCH and numerous other business and taxpublications. Jim is a frequent speaker and panellist on civil and criminal tax matters.

US

James Mastracchio

Dentons

1900 K Street NWWashington, DC 20006US




Wade McKnight, Deloitte US, is the managing director of De -loitte’s tax controversy services practice for the South CentralUS.

He has extensive tax controversies experience over a broadrange of clients including several Fortune 100 energy compa-nies, oil-field services companies, transportation companies, aMajor League Baseball team, real estate management compa-nies, engineering and construction firms, retailers, airlines,investment funds, and high-wealth individuals.

Wade’s tax controversies experience includes handling IRScase management for primarily large business and internationalindustry cases and coordinated industry cases at both the exam-ination and appeals levels. In addition, Wade regularly providesadvice on general Internal Revenue Service (IRS) practice andprocedure issues and assists clients with penalty abatements.Wade has assisted numerous clients with voluntary compliancesubmissions to the IRS related to withholding tax issues. He hasalso represented several clients during withholding tax examina-tions and has helped companies implement new tax andaccounting processes and procedures to facilitate compliancewith the withholding rules.

Wade received his JD from the Paul M. Hebert Law Center at Louisiana State University.He has been admitted to the State Bar of Louisiana, State Bar of Texas and the US TaxCourt. He is also an active member of the Texas State Bar Association and an inactive mem-ber of the Louisiana State Bar Association.

US

Wade McKnight

Deloitte Tax LLP

1111 Bagby St., Suite 4500Houston, TX 77002US




Kristin Mikolaitis is a partner in the tax controversy practice inMayer Brown’s New York office.

Since joining the firm in 2008, Kristin has represented tax-payers at all stages of federal tax controversies, including duringaudit, in administrative appeals, and before federal courts.

Kristin’s controversy experience includes major corporate taxmatters involving international tax and transfer pricing, sub-stance-over-form disputes, economic substance issues, financialand leasing transactions, and civil tax penalties. Her litigationexperience includes extensive trial work in the US Court ofFederal Claims and the US Tax Court, as well as matters in var-ious US Courts of Appeals.

Kristin has also actively participated in the firm’s pro bonoefforts by representing individuals in tax, landlord-tenant, andestate planning matters.

Kristin serves on the firm’s committee on diversity and inclu-sion and the women’s forum committee. In addition, from2012 to 2015, she served on the leadership advisory committeeof the National Women’s Law Center.

From 2009 to 2012, Kristin was based in the firm’s Washington, DC office.

US

Kristin M Mikolaitis

Mayer Brown


Tel: +1 212 506 2265Email:[email protected]: www.mayerbrown.com



Mark Nehoray, Deloitte US, is a senior partner, based in LosAngeles.

Mark is consistently recognised as a leading transfer pricingadviser by publications including International Tax Review andEuromoney’s Transfer Pricing Expert Guide.

With more than 34 years of experience in tax and transferpricing, Mark assists multinationals with transfer pricing studies,restructuring of foreign royalties and other foreign incomestreams. Mark led the team that successfully negotiatedMexico’s first transfer pricing ruling.

Mark is the transfer pricing adviser to three of the world’slargest multinationals and has conducted a significant numberof transfer pricing studies across various industries (e.g. enter-tainment and media, gaming, multi-level marketing, hi-tech,apparel, and non-profit). These projects have included bothdefensive work with respect to on-going Internal RevenueService (IRS) audits and Competent Authority assistance, aswell as planning studies and APAs. Over the past 15 years, hehas been responsible for Deloitte’s largest APA, as well one ofthe largest multilateral APAs in the programme. He is currently assisting two large US-basedmultinationals with their IRS transfer pricing examinations, another two US-based multina-tionals with their unilateral APAs, as well as assisting 10 foreign-based multinationals withtheir bilateral APAs.

Since 2002, Mark has been the executive producer and the host of Deloitte’s TransferPricing Dbriefs, a monthly internet program. He is a frequent speaker at US transfer pricingconferences sponsored by Bloomberg BNA.

His recent publications include: the OECD Guidance on Transfer Pricing Document ation:Preparing for the New Global Standard; Bloomberg BNA’s Tax Management Transfer PricingReport (May 26 2016); Complying with OECD’s Country-by-Country Reporting, Anaplan(November 2014); ‘Integrating Tax and Treasury Operations with Transfer Pricing’ in theCFO Journal (from the Wall Street Journal, August 27 2014); and International TaxReview’s ‘Transfer Pricing of Intangibles – Media and Entertainment’ (December 2013),(‘Turning Tech Investments into Value Repositories’ (February 2011), and ‘How APAs Fitinto Today’s Regulatory Landscape’ (May 2009).

Mark has a bachelor’s degree in business administration and a master’s degree in businesstaxation from the University of Southern California.

US

Mark Nehoray

Deloitte Tax LLP

555 W. Fifth StreetLos Angeles, CA 90013US




Larissa Neumann focuses her practice on US tax planning andtax controversy with an emphasis on international transactions.She has broad experience advising clients on acquisitions,restructurings and transfer pricing issues. She has successfullyrepresented clients in federal tax controversies at the audit level,in appeals and in court.

Larissa appears in International Tax Review’s Tax Contro -versy Leaders guide and in Euromoney’s Tax Advisers ExpertGuide. Euromoney selected Larissa for inclusion in the AmericasWomen in Business Law Awards shortlist for ‘Best in TaxDispute Resolution’ in 2014 and she was named the 2015Rising Star: Tax. She was also named in the Silicon Valley Bus -iness Journal’s ‘40 Under 40’. In 2016, Larissa was named a“Rising Star” in tax by Law360.

Larissa frequently speaks at conferences for professional taxgroups, including TEI, IFA, Pacific Rim Tax Institute, Bloom -berg, and the ABA. She is the ABA international law tax liaison.

Larissa has published several articles, including recently: • ‘New Intercompany Debt Rules Shock Multinational

Companies’, Euromoney’s LMG Rising Stars 2016• ‘The Top Tax Controversy Cases in 2016’, International Tax Review (2016)• ‘Responding to the Changes in the Transfer Pricing Landscape’, International TaxReview (May 2016)

• ‘US Tax Overview’, Euromoney’s LMG Rising Stars 2015• ‘US transfer pricing litigation update ’, International Tax Review (March 2015)• ‘Areas of TP Scrutiny in a pre- and post-BEPS World’, International Tax Review

(February 2015)• ‘US International Tax Developments’, The Euromoney Corporate Tax Handbook 2015• ‘US Transfer Pricing Developments’, International Tax Review (2014)• ‘US Tax Developments’, International Tax Review (December/January 2013)• ‘Character and Source of Income from Internet Business Activities’, The ContemporaryTax Journal (July 2011)• ‘The Application of the Branch Rule to Partnerships’, International Tax Journal (July-

August 2010)Fenwick has one of the world’s top tax planning and tax transactional practices, according

to International Tax Review, and is a first-tier firm in tax, according to World Tax. Inter -national Tax Review gave Fenwick its San Francisco Tax Firm Award a total of seven timesand its US Tax Litigation Firm Award a total of three times. International Tax Review hasalso named Fenwick as the “Americas M&A Tax Firm of the Year”.

US

Larissa Neumann

Fenwick & West





Shawn O’Brien is a tax partner, who represents clients in alltypes of tax disputes with taxing authorities on international,federal and state levels.

He routinely advises clients on various tax issues during taxexaminations, in administrative appeals and as an advocate intrial and appellate litigation before the US Tax Court, the USCourt of Federal Claims and US district courts. Shawn’s taxcontroversy and litigation experience spans a broad range ofareas, including transfer pricing controversies, debt v. equityissues, international withholdings, advance pricing agreements,tax shelter disallowances, R&D tax credits, excise taxes, andchanges in accounting methods.

Shawn advises foreign and domestic corporations, partner-ships, MLPs, REITS, and LLCs seeking corporate and taxadvice in connection with various types of foreign and domestictransactions, including 1031 exchanges, mergers and acquisi-tions, restructurings, divestitures, leveraged buyouts, structuredfinancings, and oil and gas transactions. Shawn is a certifiedpublic accountant (CPA) licensed in Louisiana.

Shawn serves on the Internal Revenue Service AdvisoryCouncil (IRSAC), where he is a member of the Large Business & International (LB & I) sub-committee of IRSAC.

Shawn specialises on a variety of tax issues facing the energy industry including tax con-troversy, joint ventures, restructuring, acquisition and disposition of energy assets. Shawnserved as chair of the Energy and Natural Resources Committee of the State Bar of Texas TaxSection from 2011 to 2013.

According to International Tax Review’s World Tax 2014, Mayer Brown’s Houston taxpractice is “known for its sophisticated transactional tax and tax controversy work”.

US

Shawn R O’Brien

Mayer Brown

700 Louisiana StreetSuite 3400Houston, TX 77002-2730US




Edward Osterberg is a tax transactions and consulting partner inMayer Brown’s Houston office.

His extensive experience includes all areas of business incometaxation, with emphasis on corporate and partnership taxationand international transactions.

Ed has advised corporate and individual clients on the federaltax consequences of various transactions, including mergers andacquisitions, tax-free reorganisations, corporate spin-offs andother divestitures, partnerships, international operations,including cross-border joint ventures with non-US partners,and inbound investment into the US by non-US investors.Chambers USA 2016 refers to Ed as “the dean of tax” and

“very bright”. Chambers USA also says: “He devotes a substan-tial part of his practice advising on the tax implications of high-value corporate matters, such as debt and equity instruments,spin-offs and restructurings”.

US

Edward C Osterberg Jr

Mayer Brown

700 Louisiana StreetSuite 3400Houston, TX 77002-2730US




Kimberley Peterson, Deloitte US, is a managing director in theSilicon Valley office of Deloitte Tax’s tax controversy serviceswest region practice. During her seven-year tenure at Deloitte,Kim has successfully represented many corporate and partner-ship clients before the Internal Revenue Service (IRS), both atthe examination and appeals levels, throughout the US. Kimspecialises in transfer pricing and other cross-border and inter-national issues.

Before joining Deloitte, Kim spent 13 years with the IRSChief Counsel’s Office, as international field counsel, associatearea counsel, and deputy area counsel for strategic litigation.While at the IRS, Kim advised large case agents, internationalexaminers, and appeals officers in some of the largest examina-tions undertaken by the IRS, involving a wide range of complexinternational and domestic corporate issues. Kim also represent-ed the IRS in the US Tax Court in large case litigation involvingtransfer pricing and other international issues, including in theDHL v. Commissioner and Microsoft v. Commissioner cases,receiving western regional and national litigation awards. Asassociate area counsel and deputy area counsel for strategic liti-gation, Kim had responsibility for large case litigation, includingthe special trial attorney litigation of Xilinx v. Commissioner and Veritas v. Commissioner.

Kim is a member of the State Bar of California and is admitted to practice before the USTax Court and the US Court of Appeals for the Ninth Circuit. Kim is a frequent speaker onIRS practice and procedure and the management of complex IRS examinations, especiallytransfer pricing examinations. In 2015, Kim became an instructor in tax practices, penaltiesand procedures in the San Jose State University master’s in taxation programme. Kimreceived her BS in business administration from the University of California, Berkeley, andher JD from the University of Arizona, James E Rogers College of Law.

US

Kimberley Peterson

Deloitte Tax LLP

225 West Santa Clara StreetSuite 600San Jose, CA 95113-2303US




Irving H Plotkin, senior managing director of PwC’s tax andeconomic controversy practice and a member of its national taxservice based in Boston, is one of the premier experts in the fieldof transfer pricing and other complex domestic and internation-al tax issues such as economic substance, financial products, andinsurance.

He specialises in analysis of the effects of various types ofgovernment regulation, self-regulation, and taxation on capitalflows, output, prices, risk-taking, competition, and efficiencywithin individual industries.

His work on risk/return measurement and on internationaland domestic tax issues is widely cited, as is his expert testimonyon behalf of US and foreign taxpayers and the Internal RevenueService and Department of Justice in many high-profile andprecedent-setting tax disputes (including Du Pont, Xilinx, UPS,DHL, ACM, Bausch and Lomb, Dow [COLI], The Limited[NYS], Toys R Us [NYC], Cambridge Brands [Mass.], and thecaptive insurance cases).

He has designed, directed, and published research involvingmicroeconomics, finance, industrial organisation, and econo-metrics. He has presented the results of these studies before several US Senate and Housecommittees, the Federal Reserve Board, the Interstate Commerce Commission, the FederalMaritime Commission, the Federal Trade Commission, US claims, tax, and district courts,and numerous state legislative committees, courts, regulatory agencies, and arbitration pan-els. He has assisted in the writing of international tax legislation and regulations.

Irv holds a BS in economics from the Wharton School (University of Pennsylvania) and aPhD in mathematical economics from the Massachusetts Institute of Technology, where hetaught computer science and finance. He has presented numerous papers in several fields ofeconomics and regulation before various academic societies, professional organisations andindustrial associations and has served as an editorial reviewer for the Journal of the AmericanStatistical Association, the Journal of Industrial Economics, and the Journal of Risk andInsurance. His published papers, books, and monographs include ‘Risk/Return: US IndustryPattern’ (Harvard Business Review), ‘Rates of Return in the Property and Liability InsuranceIndustry: A Comparative Analysis’ (Journal of Risk and Insurance); ‘The Consequences ofIndustrial Regulation on Profitability, Risk Taking, and Innovation’; ‘Torrens in the UnitedStates’; and ‘Economic Principles in Establishing Transfer Prices’ (Tax Management, ForeignIncome Portfolio, co-author). His comments on current tax developments appear frequentlyin tax periodicals.

US

Irving Plotkin

PwC

101 Seaport BoulevardBoston MA 02210US




Keith Reams, Deloitte Tax LLP, is the US and global leader forclients and markets for Deloitte’s global transfer pricing servicespractice. He has advised clients around the globe on intercom-pany pricing transactions with respect to income tax regulationsin Argentina, Australia, Belgium, Brazil, Canada, Chile, China,Columbia, Czech Republic, Denmark, France, Germany, India,Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia,Mexico, the Netherlands, Norway, Peru, Poland, Singapore,South Africa, Spain, Switzerland, Taiwan, Thailand, the UK,and the US.

Keith has assisted numerous multinational enterprises withinternational valuation and economic consulting services involv-ing merger and acquisition activity, international tax planning,and restructuring and reorganisation of international opera-tions. Keith is on the global tax management team for Deloitte’stechnology, media and telecommunications (TMT) group andis a leader in the area of transfer pricing for newly emergingindustries, such as electronic commerce and cloud computing,where he has extensive experience around the world in helpingclients extend their business models into new territories.

Keith has testified as a qualified expert in numerous valuation and transfer pricing dis-putes, including the cases of Nestle Holdings Inc. v. Commissioner; DHL Corp. v. Commission -er; and United Parcel Service of America, Inc. v. Commissioner. In addition, he is one of onlythree economists in the US approved by the New York State Department of Taxation andFinance to provide transfer pricing expertise and testimony in cases involving cross-bordertransactions within commonly controlled affiliated groups. He has also helped many clientsto successfully resolve valuation and transfer pricing disputes before they reach trial.

Keith completed course requirements for a PhD in international finance from New YorkUniversity. He holds a master of arts degree in economics from California State UniversitySacramento and a BS degree in chemical engineering from Stanford University.

US

Keith Reams

Deloitte Tax LLP

980 9th Street Suite 1800Sacramento, CA 95814-2738US




William Schmalzl focuses on tax litigation, corporate tax plan-ning and state tax advice at Mayer Brown.

He represents clients in all stages of tax litigation includingaudits, administrative proceedings, US Tax Court, federal dis-trict court and courts of appeals and Illinois state courts.

The issues he has litigated include IRC section 199, section263A, section 482, the investment tax credit, research tax cred-it, sale-leasebacks, foreign tax credits, franchises, patents andother intangibles.

William’s undergraduate majors in economics and mathe-matics have proven invaluable in the preparation of expertreports and in the examination of expert witnesses at trial.William’s trial experience includes Seagate Technology, NationalSemiconductor, United Parcel Service, RJR Nabisco, ConEd,Wells Fargo and Flextronics.

Before joining Mayer Brown, William served as an articleseditor at the Harvard Law Review and a clerk to the Honour -able Robert Ainsworth, Jr., of the 5th Circuit Court of Appeals(1977-78).

US

William A Schmalzl

Mayer Brown





Ronald Schrotenboer practises at Fenwick & West’s MountainView office.

His published decisions include Xilinx, Inc. v. Commissioner,125 T.C. 37 (2005), aff’d (9th Cir. 2010) (stock optionamounts not required to be cost shared under § 482); SunMicrosystems v. Commissioner 69 T.C.M. 1884 (1995), (incen-tive stock option deduction qualifies for R&D credit); Appeal ofFinnigan Corporation, CCH 401-797 (1990), (throwback ruleis applied on a unitary basis; Appeal of Joyce overruled); andPetition of Intel Corporation, CCH 402-675 (1992), (technol-ogy transfers are not subject to California sales 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.

US

Ronald Schrotenboer

Fenwick & West


Tel: +1 650 335 7207Fax: +1 650 938 5200Email:[email protected]: www.fenwick.com



George Soba, Deloitte Tax LLP, is a principal of the transferpricing practice. George has more than 18 years of experiencewith Deloitte, representing US and foreign multinational clientsin transfer pricing controversies (audits, appeals, andCompetent Authority proceedings between the US and foreigntax authorities), and in advance pricing agreements (APAs). Headvises clients on the transfer pricing aspects of global tax ratio-nalisation, planning, documentation, and audit defence prepara-tion. George’s industry experience includes aerospace; con-sumer goods companies (retailers, distributors, and manufactur-ers); e-commerce; financial transaction processing and electron-ic trading exchanges; healthcare (vertically integrated pharma-ceutical companies, biotech, and medical instruments) and con-tract research organisations; heavy manufacturing (constructionequipment, printing, automotive companies, and automotiveparts manufacturers); real estate investment trusts (REITs); andtechnology (wafer manufacturers, chip design and manufactur-ing, internet-related optical routers, servers, and infrastructure).

Before joining Deloitte, George worked as a field attorneyfor nine years in the IRS Office of Chief Counsel, served as an adviser to IRS examinationteams conducting transfer pricing audits, advised appeals officers on the resolution of transferpricing matters, served as one of the first IRS field attorneys on APAs, was on the IRS litiga-tion team for the Perkin-Elmer transfer pricing trial before the US Tax Court, and was sec-onded to the IRS APA programme where he served as a team leader during the establishmentof the APA programme. He then worked for two years in the Office of Associate ChiefCounsel (Inter national) advising large-case examination teams on transfer pricing issues, eval-uating transfer pricing controversies for potential litigation by the IRS, advising the USCompetent Authority on transfer pricing, permanent establishment, and business profitsissues, and as a team leader in the APA programme.

George is a frequent speaker on transfer pricing topics and has authored and co-authoredpapers on transfer pricing audits, blocked income, APAs, and other topics. He holds an LLMin tax from New York University School of Law, and is a member of the American andWashing ton, DC Bar associations.

US

George Soba

Deloitte Tax LLP

191 Peachtree St Ste 2000Atlanta, GA 30303-1749US




David Stallings, Deloitte US, is the Deloitte global leader ofbusiness tax and international tax. The business tax professionalsof Deloitte member firms specialise in consulting for multina-tional enterprises on tax, treasury and business issues and Davidis a frequent speaker on these topics. He spends a significantamount of time advising US-based multinational clients on mat-ters such as structuring of subsidiaries and joint ventures, acqui-sition and disposition planning, cross-border financing, inter-company pricing, foreign tax credit planning, and global cashmanagement. David spent one year on assignment in Londonwhere his clients were US-based and UK-based companies withmultinational operations. Prior to joining Deloitte, David was incharge of the Southeast international tax practice at anotherlarge tax services firm.

In 1987, David graduated from Oglethorpe University witha BBA in accounting. He is a certified public accountant inGeorgia and a member of the International Fiscal Association.

US

David Stallings

Deloitte Tax LLP

191 Peachtree Street NESuite 2000, Atlanta GA 30303US




Since joining Mayer Brown in 1989, Scott Stewart’s practice hasfocused exclusively on tax disputes, including transfer pricingand intercompany debt matters. He represents taxpayers at alllevels of federal tax controversy, including audits, administrativeappeals before the Internal Revenue Service, mediation involv-ing the appeals division of the IRS, and litigation before the USTax Court.

Recognised by Chambers USA each year from 2006 to 2016,Scott is described as “a talented litigator and corporate advisor”who wins the confidence of clients with his “extraordinary com-munication skills” and “broad and deep experience”. He is“recommended for his spot-on judgment and analysis”, “hisresponsiveness and strategic thinking” and his “ability to antic-ipate issues before they arise”. Chambers USA 2016 describeshim as “very knowledgeable on the subject matter, attentive toclient needs and quick to learn the client’s issues and business”.Chambers also notes that he is “particularly adept at handlingtransfer pricing cases at all levels”.

Scott has extensive experience with deductibility of interestexpense in related-party transactions, including debt vs. equity characterisation and “shamtransaction” and “economic substance” issues, dating back to his involvement in the land-mark Nestlé Holdings case during the 1990s. Recently, Scott led the Mayer Brown team thatfiled 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco Internationaland related companies. The cases, which involved $3 billion in interest expense incurred from1998 to 2000 and implicated an additional $6.5 billion in interest expense incurred from2001 to 2007, were settled for 8% of the amount in dispute.

Scott is also experienced in all aspects of international transfer pricing, including cross-bor-der movements of tangible and intangible property, advance pricing agreements, cost sharingarrangements, Section 6662 documentation, transfer pricing litigation, and issues related toSection 936 Puerto Rico possessions corporations. His transfer pricing litigation experienceincludes a number of the major cases of the last two decades, such as National Semiconductor,Seagate Technology, Nestlé Holdings and United Parcel Service.

Scott holds a JD from Harvard Law School and an MBA from the Johnson GraduateSchool of Management at Cornell University.

US

Scott M Stewart

Mayer Brown





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 650 tax controversy professionals, located in upwardsof 80 countries across the globe, who assist multinational enter-prises to prevent, manage, and resolve tax audits and disputesworldwide.

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 par-ticipated in more than 250 tax controversies involving auditsand disputes between MNEs and the Internal Revenue Service(IRS), as well as dozens of other revenue authorities around theworld.

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 (Carborun -dum), and intellectual property rights (Exide/Exxon). David also participated in several land-mark tax cases before the US Supreme Court, including the Barclays Bank, Boeing, andGood year cases. David has been described as “one of the top five tax controversy experts inthe 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 Treasury Depart -ment and IRS, and has been an adjunct professor at Georgetown University Law Center,where he continuously taught courses for 25 years relating to international corporate incometaxation. David received his MLT from Georgetown University Law School, and his JD, withhonours, and BA, with distinction, from the University of Mississippi. David also has beenadmitted to practice before the US Tax Court, the US Court of Federal Claims, numerousUS Federal Courts of Appeal, and the US Supreme Court.

US

David Swenson

PwC





Joe Tobin, Deloitte US, is a senior manager in global transferpricing at Deloitte’s Washington national tax practice. Joe isvery experienced in transfer pricing controversy and transferpricing planning, especially in the area of cost sharing arrange-ments. Joe serves a wide variety of clients, specialising in intan-gible-centric industries such as the high-technology industryand the bio-pharmaceutical industry. Joe was the primarydrafter of US Treasury’s Regs. §1.482-7 (2011) and Regs.§1.482-7 (2013) on final cost sharing regulations. Joe was cho-sen by USCIB to comment on the OECD’s 2015 discussiondraft on cost contribution arrangements. Joe also helped theABA and USCIB draft comments on Notice 2015-54 and theSection 367 temporary regulations and Section 482 temporaryregulations released in September 2015.

Joe was previously senior counsel at the Department ofTreasury, within the Internal Revenue Service (IRS) office ofassociate chief counsel (international) (branch 6) (transfer pric-ing) in Washington DC, where he was the national officereviewer in charge of many of the high-profile transfer pricinglitigation cases involving transfers of intangibles. Joe also advised IRS exam and field counselon hundreds of contentious transfer pricing audits that went to IRS appeals. Joe has alsocommented on several versions of the draft IRS appeals settlement guidelines on cost sharingbuy-ins, which have never been published. Joe was also known as the “go to” person foradvanced pricing agreements (APAs) with complex technical issues involving cost sharingarrangements (CSAs), and he advised on several such APAs with CSAs.

Joe has spoken at numerous conferences, webcasts, and training sessions on transfer pric-ing and cost sharing. He has been a member of the Georgetown Law Adjunct Faculty since2013, where he co-teaches a class on transfer pricing.

Joe received a master’s degree in tax law from New York University in 2007, a JD fromthe University of Virginia in 2005, and a Bachelor of Arts in Philosophy and Political Sciencefrom Reed College in 1995. Joe is licensed to practice law in Nevada and New York.

US

Joe Tobin

Deloitte Tax LLP

555 12th St. NWSuite 400Washington, DC 20004US




Gary Wilcox is a principal with PwC in Washington, DC, wherehe co-leads a US controversy team that actively advises clientsduring the audit management and appeals and resolution phasesof an Internal Revenue Service (IRS) dispute. Gary also worksclosely with corporate and international specialists in cross-bor-der transactions to help clients prepare for potential controversy.Gary’s team frequently seeks rulings and other guidance forclients from the IRS and Treasury as a means of proactivelyavoiding tax controversies.

Gary was recently a partner with Morgan Lewis, where heheaded up the firm’s tax practice. Prior to that, he served asdeputy chief counsel (technical) in the IRS Office of ChiefCounsel and, earlier, a leader of PwC’s mergers and acquisitionspractice.

Gary was litigation counsel to Iberdrola and ScottishPowerin NAGP v. Commissioner, a 2012 US Tax Court decision thatupheld nearly $1 billion of taxpayer’s interest deductions oncross-border intercompany debt.

A frequent lecturer on corporate tax issues, Gary is an authorof the Bloomberg BNA Tax Management Portfolio entitled‘Corporate Acquisitions – (A), (B), and (C) Reorganizations’.

Gary has an LLM in taxation from New York University, a JD with highest honours fromthe University of Oklahoma and an undergraduate degree (cum laude) from Texas TechUniversity.

US

Gary Wilcox

PwC


Tel: +1 202 312 7942Fax: + 1 678 529 4506Email: [email protected] Website:www.pwc.com/taxcontroversy



Joel Williamson is co-chair of Mayer Brown’s tax controversypractice.

He has tried in excess of 60 tax cases to judicial opinions andan unprecedented seven transfer pricing cases, including EliLilly, GD Searle, Westreco (Nestlé), Seagate Technology,National Semiconductor, United Parcel Service and mostrecently in 2015 Eaton Corporation.

Continuing his history of handling the largest of transferpricing cases, Joel is serving as trial counsel in the mega multi-billion dollar Guidant LLC cases. Also, in 2015, Joel was a leadtrial counsel in the multi-billion dollar Exelon like-kindexchange case.

In the international tax area, Joel has litigated subpart F,constructive triangular dividend and R&D moratorium issues,Brazilian and other foreign tax credits for banks, as well as for-eign versus domestic-source income IRC § 863(b) questions. Inaddition, Joel has litigated IRC § 338 corporate acquisitionrelated issues, like debt vs. equity for Nestlé. Joel was a lead trialcounsel in the mega Tyco debt vs. equity cases, which werefavourably settled for Tyco.

Joel has litigated significant procedural questions, including the proper role of IRS trialcounsel in the audit examination process, Westreco (Nestlé). He is also experienced in sum-mons enforcement actions for both foreign and domestic records (Eaton).

Joel has been recognised by Chambers USA as a leading lawyer every year since 2003 to2016. Chambers USA said Joel is “a dean of the tax controversy Bar, revered for his ‘spectac-ular courtroom manner and skills’.” In addition, Legal 500 recognised him as a leading lawyerin 2011 to 2016.

Joel served as an officer in the US Army from 1970 to 1972, assigned to the offices of thestaff judge advocate, 12th support brigade, ft. Bragg, NC, and subsequently to Saigon sup-port command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joeljoined the Chief Counsel’s Office, US Department of Treasury. In 1978, he was appointedto one of 20 special trial attorneys located throughout the US. Joel joined Mayer Brown in1986 as a partner.

US

Joel V Williamson

Mayer Brown





Todd Wolosoff, Deloite Tax LLP, is the global and US leaderfor transfer pricing, and the Deloitte Tax transfer pricing man-aging partner. He is based in the New York office. He has nearly30 years of experience as a partner in representing multinationalenterprises in transfer pricing and international tax matters.

Todd was promoted to his current roles in 2012 and 2011respectively. Previously, Todd was the partner-in-charge oftransfer pricing for the northeast US and the leader of the tri-state transfer pricing group since its inception in 1990. He is afounding member of the Deloitte Tax national transfer pricingleadership group.

In Todd’s global leadership role, he is responsible for creat-ing and implementing strategy and providing vision and leader-ship to the Deloitte member firm network’s nearly 2,000 trans-fer pricing professionals worldwide. In his US transfer pricingleadership role, Todd is responsible for all aspects of the UStransfer pricing group including strategy, operations, hiring andhuman resources. Todd has approximately 50 partners, princi-pals and directors and hundreds of professionals as part of histeam.

Todd serves as an adviser to several of the world’s largest multinationals and has conduct-ed numerous transfer pricing planning studies in virtually all industries, with a particular focuson pharmaceuticals, electronics, financial services, consumer products, automotive, TMT,and fashion and beauty products, for both inbound and outbound taxpayers.

He has been recognised by Euromoney as one of the world’s leading transfer pricingadvisers and was one of four Deloitte tax partners selected by Mondaq in its survey of the topattorneys in the US. Todd is also recognised by International Tax Review as one of theworld’s leading tax advisers.

Todd holds a BS in economics from the Wharton School of the University of Penn -sylvania, a JD from St. John’s School of Law, and an LLM from New York University Schoolof Law. Todd is a licensed attorney and a CPA, as well as a member of the American BarAssociation, the New York State Bar Association, the American Institute of Certified PublicAccountants, and the New York Society of Certified Public Accountants.

US

Todd Wolosoff

Deloitte Tax LLP

1633 BroadwayNew York, NY 10019-6754US




US

Robert H AlbaralBaker & McKenzie

Gregory BartonPwC

Peter BlessingKPMG

Thomas BordersMcDermott Will & Emery

Kim BoylanWhite & Case

Steven S BrownMartin, Brown, Sullivan, Roadman & Hartnett

Thomas CallahanThompson Hine

Nathaniel CardenSkadden, Arps, Slate, Meagher & Flom

George M ClarkeBaker & McKenzie

Jerold CohenSutherland Asbill & Brennan

Erin CollinsKPMG

Andrew CrousoreBaker & McKenzie

Michael DanilackPwC

Lucas DanteKPMG

Michael DesmondLaw Offices of Michael J Desmond

Mike DolanKPMG

Carol DunahooBaker & McKenzie

Michael DurneyLaw Offices of Michael C Durney

Elizabeth EricksonMcDermott Will & Emery



US

David ErnickPwC

Miriam FisherLatham & Watkins

Sean FoleyKPMG

Scott FrewingBaker & McKenzie

Jasper G Taylor IIINorton Rose Fulbright

Stephen GardnerCooley

George GerachisVinson & Elkins

Fred Goldberg JrSkadden, Arps, Slate, Meagher & Flom

Charles HallNorton Rose Fulbright

Rob HansonEY

Lawrence HillShearman & Sterling

Thomas JohnstonShearman & Sterling

Maria JonesMiller & Chevalier

Richard JonesSullivan & Worcester

Roger JonesMcDermott Will & Emery

Phil KarterChamberlain Hrdlicka White Williams & Aughtry

Kevin KenworthyMiller & Chevalier

Donald KorbSullivan & Cromwell

Stephen KranzMcDermott Will & Emery



US

Frank LavaderaKPMG

Gregg LemeinBaker & McKenzie

Patricia LewisCaplin & Drysdale

Jerome LibinSutherland Asbill & Brennan

Thomas LinguantiBaker & McKenzie

Raj MadanSkadden, Arps, Slate, Meagher & Flom

John MageeMorgan Lewis & Bockius

Jane Wells MayMcDermott Will & Emery

David NagleSullivan & Worcester

Deborah NolanEY

Kathryn O’BrienPwC

Mark OatesBaker & McKenzie

Pam OlsonPwC

Emily ParkerThompson & Knight

Jean PawlowMcDermott Will & Emery

Martin PressGunster

Jose Manuel RamirezKPMG

Patricia Anne RexfordBaker & McKenzie

David RosenbloomCaplin & Drysdale



US

Leslie SamuelsCleary Gottlieb Steen & Hamilton

Paul SchickBaker & McKenzie

Leslie SchneiderIvins Phillips & Barker

William SharpSharp Partners

Barry ShottPwC

Sanford StarkMorgan Lewis & Bockius

Douglas StranskySullivan & Worcester

Brian TraumanKPMG

Juan Vasquez, JrChamberlain, Hrdlicka, White, Williams & Aughtry

Mario VerdoliniDavis Polk & Wardwell

Duane WebberBaker & McKenzie

Todd WeltyMcDermott Will & Emery

Daniel WhiteBaker & McKenzie

B John WilliamsSkadden, Arps, Slate, Meagher & Flom

Robert WillmoreCrowell & Moring

Diana WollmanCleary Gottlieb Steen & Hamilton

Steven WrappeKPMG

Russell YoungBaker & McKenzie

Shanwu YuanBaker & McKenzie

Thomas ZolloKPMG



Alberto Benshimol Bello received his law degree (summa cumlaude) from Andrés Bello Catholic University (1996) and aMaster of Laws degree (LLM) in international taxation fromNew York University (1997). He was a recipient of the DonaldL. Brown Scholarship granted by New York University Schoolof Law. He is a professor of financial and tax law in the under-graduate and postgraduate studies at Andres Bello CatholicUniversity (since 2003).

Alberto is a member of the Latin America committee of theInternational Fiscal Association (IFA) and is secretary of IFAVenezuela. He is a member of the New York State Bar Associa -tion and the International Bar Association, as well as being amember of the Society of Trust and Estate Practitioners(STEP).

Albertos’s previous roles have included international associ-ate of the law firm Wilmer, Cutler & Pickering, based in Wash -ing ton, DC (1997-1998), while he was also a member of theVenezuelan team that conducted and completed the negotia-tions of the US-Venezuela tax treaty (1998). Since 2005,Alberto has been a partner of D’Empaire Reyna Abogados.

He has published several articles in Venezuela and abroad on International Taxation andWealth Planning, and frequently lectures on such matters.

He represents individuals, fiduciaries and family businesses in domestic and internationaltax, estate and trust planning. He also represents corporate clients on domestic and interna-tional tax matters, such as Bristol-Myers Squibb, Brown Brothers Harriman, CitigroupPrivate Bank, Coca-Cola Femsa, GE, HSBC, JP Morgan, Mexichem, Rolex, Rosneft andToshiba.

He has also been recognised by numerous surveys including those conducted byChambers and Partners, Who’s Who Legal, World Tax, International Tax Review, LatinLawyer, and Practical Law Review, as a leading Venezuelan tax practitioner.

Venezuela

Alberto Benshimol Bello

D’Empaire Reyna Abogados

Edificio Bancaracas, PHPlaza La CastellanaCaracas 1060Venezuela

Tel: +58 212 264 6244 (general)+58 212 264 7376 (direct)+58 412 264 6250 (mobile)

Email: [email protected]: www.dra.com.ve



Humberto Romero-Muci graduated (summa cum laude) fromAndrés Bello Catholic University (1985). He gained a master’sdegree in law and a specialisation and diploma on internationaltaxation at Harvard Law School (1986), later obtaining a PhDat Central University of Venezuela (2003).

He is a fellow of the National Academy of Political and SocialSciences, Seat N° 14 (2005); a member of the board of direc-tors and treasurer of the same academy from 2007 to 2011, aswell as secretary, a role he still holds. Humberto is also a profes-sor of undergraduate and postgraduate studies at Andrés BelloCatholic University, Central University of Venezuela and theMetropolitan University and is also chair professor and head ofthe finance law lecture at Andrés Bello Catholic University(1987-now).

He is a former Justice of the First Court on tax matters(1990-1993) and of the Political-Administrative Chamber ofthe Supreme Court (1998-2000).

He was previously a partner of the law firm Tinoco, Travieso,Planchart, Erminy y Asociados (1986-1997); co-founder andmanaging partner of the law firm Romero-Muci & Asociados(1997); international partner of Andersen Legal (1997-2002) and Deloitte (2002-2012).Since 2012 he has been a partner of D�Empaire Reyna Abogados.

He has published more than 60 articles in law reviews in Venezuela and abroad, and morethan 12 books on the matters of accounting, taxation and tax litigation.

Humberto has received several awards, including the following: Annual Award from theAttorney General’s Office (1989); Honor Award from the Academy of Political and SocialSciences (1991 and 2005); Nuck Wicksell Honor Award, granted by the VenezuelanAssociation of Law and Economics (1997); Honor Award Marcos Ramirez Murzi granted bythe Venezuelan Tax Law Association (2007 and 2008).

He has taken part in the most relevant cases of tax litigation in customs, transfer pricing,municipal taxes, income taxes and international arbitration, including the representation of:Total, Eni, Weatherford International, FedEx, Brightstar, Coca Cola Femsa, Flowserve,Makro, Norberto Odebrecht Constructora, AstraZeneca, Bayer, and Halliburton, amongothers.

He has also been ranked as a top tax adviser by several tax reviews and directories such asChambers, International Tax Review, and Top Tier Lawyers.

Venezuela

Humberto Romero-Muci


Edificio Bancaracas, PHPlaza La CastellanaCaracas 1060Venezuela

Tel: +58 212 264 6244 (general)+58 212 267 7154 (direct)+58 412 234 3690 (mobile)




José Valecillos is an associate at the tax group of D’EmpaireReyna Abogados.

José has represented multinational enterprises in a widerange of tax disputes, including several transfer pricing litiga-tions. José has also provided tax advice to multinational enter-prises on several corporate transactions and on international taxmatters.

He received his law degree from the Metropolitan Universityin 2007 and a Master of Laws degree (LLM) in taxation fromGeorgetown University Law Center in 2014.

José is the Venezuelan Branch representative of the YoungIFA Network (YIN) and a member of the Venezuelan Tax LawAssociation (AVDT). José has spoken at international confer-ences held by the International Bar Association (IBA) TaxesCommittee and by the International Fiscal Association LatinAmerica. Before joining D’Empaire, José was an associate atDeloitte Caracas and served at the Venezuelan tax authority’slegal office.

Venezuela

José Valecillos


Edificio Bancaracas, PHPlaza La CastellanaCaracas, 1060Venezuela

Tel: +58 212 2646244 (general)+58 414 7299162 (mobile)



Venezuela

José BarnolaBaker & McKenzie

Alberto Blanco-UribeKlemprer, Rivas, Pérez, Trujillo & Asociados

Valmy DíazTorres, Plaz & Araujo

Ronald EvansBaker & McKenzie

Andrés HalvorssenRaffalli de Lemos, Halvorssen, Ortega, Ortiz

Jorge JraigeBaker & McKenzie

Alaska MoscatoEY

Rafael TobíaRodríguez & Mendoza

TAX CONTROVERSY LEADERS www.internationaltaxreview.com | 394394 | www.internationaltaxreview.com TAX CONTROVERSY LEADERS


Minh Bui, Deloitte Vietnam, has over 15 years of professionalpractice experience in tax and business advisory services. Hespecialises in tax advisory and controversy effective planning andis known for his in-depth knowledge of the Vietnamese taxationsystem. He has worked with clients and tax professionals glob-ally. Minh also has an extensive network with different levels oftax and relevant government authorities in Vietnam, such as theGovernment Office, Ministry of Planning and Investment,Ministry of Finance, General Department of Taxation, GeneralDepartment of Customs, and provincial tax and customsauthorities.

Minh has been serving several of the world’s leading heavyindustries, construction, manufacturing and real estate compa-nies with their first entry into Vietnam and later aggressive busi-ness expansion marking certain milestones of their history ofsuccess.

Minh was previously the leader of the Japanese service groupand is currently leader of the Korean service group of DeloitteVietnam. He has contributed significantly to the developmentof the Vietnamese taxation system through his public speeches,articles, and interviews.

His most recent key successes include securing nearly $20 million in tax refunds for a largeJapanese company and a successful petition to secure Vietnamese tax incentives for a SouthKorean Chaebol (a large family-owned business conglomerate).

Minh holds a bachelors degree in accounting and finance (Vietnam) and is a certificatedaccountant by CPA Australia and CPA Vietnam. He is member of the Vietnam TaxConsultants’ Association (VTCA), Korean Chamber of Business in Vietnam (Korcham), andthe tax working group of the Vietnam Business Forum.

Vietnam

Minh Bui

Deloitte Vietnam

12A Floor, Vinaconex Tower34 Lang Ha StreetDong Da District, HanoiVietnam

Tel: +84 (4) 6 288 3568Fax: +84 (4) 6 288 5678Email: [email protected]: www.deloitte.com



Tuan Bui, Deloitte Vietnam, has been practicing audit, tax, andbusiness advisory in Vietnam for over 22 years, including twoyears in the US.

Tuan has held partner roles serving large and prestigiousmultinational clients in all types on Vietnam taxation. He spe-cialises in VAT, duties exemption and refunds, customs andindirect tax reviews and advisory, and indirect tax audits forlarge-scale projects. Tuan’s specialisation covers industries, suchas energy and resources, technology, media and telecommunica-tions, manufacturing and real estate.

Tuan has been recognised as the leading tax professional ofindirect tax. He is the leader of the Chinese service group ofDeloitte Vietnam. He has contributed significantly to the devel-opment of the Vietnamese taxation system through his publicspeeches, articles, and interviews.

Tuan has worked with many different levels of tax and rele-vant government agencies in Vietnam. He also has rich experi-ence in working with tax offices, tax professionals and clients innumerous other countries.

Tuan represents Deloitte to provide comments on draft lawsand regulations on tax and customs. He has very strong connections and relationships withthe Ministry of Finance, General Department of Customs, General Department of Taxationand their lower authorities in major cities and seaports in Vietnam.

Tuan holds a bachelors degree in accounting and finance (Vietnam) and a master’s degreein business administration from the University of Hawaii (US). He is a certificated account-ant by CPA Australia and CPA Vietnam.

He is member of the American Chamber of Commerce in Vietnam, Hong Kong BusinessAssociation Vietnam (HKBAV), Vietnam Tax Consultants’ Association (VTCA) and theVTCA board.

Vietnam

Tuan Bui

Deloitte Vietnam

12A Floor, Vinaconex Tower34 Lang Ha StreetDong Da District, HanoiVietnam

Tel: +84 (4) 6 288 3568Fax: +84 (4) 6 288 5678Email: [email protected]: www.deloitte.com



Nguyen Huong Giang is a partner in the tax and legal servicespractice of PwC Vietnam with nearly 19 years of professionalexperience.

Giang has been involved in advising multinational clients inVietnam and potential investors in various areas including, butnot limited to, direct investment, tax planning and compliance,customs, tax and transfer pricing audit supports.

Giang spent three years working in Tokyo, where she gainedexperience in international taxation and transfer pricing andadvised potential Japanese clients on investing into Vietnam.

Giang leads the government liaison team in PwC Vietnam.She maintains excellent relationships with key governmentoffices to assist clients in clarifying tax and customs and legalregulations. She has extensive experience in tax controversy anddispute resolution.

Particularly, Giang experienced in providing expert opinionsin international arbitration.

Giang holds a bachelors degree in banking and finance fromthe National Economics University, a BA from the HanoiUniversity, and an MBA in international technology from theAsian Technology Institute in Thailand. She is also a member ofthe Vietnam Tax Consultants Association.

Vietnam

Nguyen Huong Giang

PwC Vietnam

16th floor, Keangnam HanoiLandmark 72Pham Hung RoadNam Tu Liem District, HanoiVietnam

Tel: +84 (4) 3946 2237Email:[email protected]:www.pwc.com/taxcontroversy



Christopher Marjoram is a partner in the tax and legal servicespractice in PwC Vietnam and is one of the country’s leading taxdispute practitioners.

He has extensive experience in tax dispute resolution and hasadvised on numerous high-profile tax disputes at both a localand national level, offering insight on matters ranging from dis-pute resolution strategies through to government liaison, nego-tiation and settlement.

Chris has previously held roles in the UK and China andadvises clients on a wide range of tax matters across differentsectors. Having specialised in mergers and acquisitions, interna-tional tax and reorganisations for almost 20 years he is at theforefront of advice on international issues such as transaction-based taxes, VAT on the export of goods and services, treatyclaims and transfer pricing disputes.

Chris works closely with colleagues across all of PwC Viet -nam’s service lines including PwC Vietnam’s market leading taxdisputes and government liaison practice.

Vietnam

Christopher Marjoram

PwC Vietnam

8th Floor, Saigon Tower29 Le Duan StreetDistrict 1 Ho Chi Minh CityVietnam

Tel: +84 8 3824 0118Mobile: +84 (0) 90 230 2909Email: christopher.marjoram@

vn.pwc.comWebsite:www.pwc.com/taxcontroversy



Hoang Phan, Deloitte Vietnam, is a tax partner leading thefinancial services practice.

Hoang has 20 years of experience in tax compliance, taxplanning, tax controversy, finance, and business advisory servic-es to meet the needs of multinational enterprises operating inVietnam in a wide variety of industries such as manufacturing,FMCG, banking and financial services, and telecom.

Hoang has maintained a close and long-term working rela-tionship with various tax authorities in Vietnam, both centraland provincial, by frequently sharing knowledge, experiencesand information about international tax practice.

Hoang actively contributes comments and recommendationsto the Ministry of Finance regarding draft tax regulations via theVietnam Business Forum, VTCA and other organisations.

Hoang regularly speaks at Tax Dialogue event alongside arepresentative of the Minister of Finance and leaders of the HoChi Minh City tax authority.

Hoang is a senior member of the ACCA and has just passedthe test to be admitted to the ICAEW. Hoang is also a memberof CPA Australia, VACPA (Vietnam) and holds an AdvanceDiploma of International Tax by CIOT (UK).

Vietnam

Hoang Phan

Deloitte Vietnam

18th Floor, Times Square BuildingNo, 57-69F Dong Khoi StreetBen Nghe Ward, Ho Chi Minh CityVietnam




Huong Vu is a tax partner and tax leader for the Hanoi marketof EY Vietnam.

She has more than 20 years’ experience in tax and regulatoryconsulting in Vietnam, Laos and Cambodia. Huong has in-depth understanding of Vietnam’s legal system and various taxand investment regulations. She leads a team of experienced andmulti-disciplinary professionals in servicing clients, focusing onforeign invested companies.

Huong is involved in tax review, tax controversy, and tax lit-igation support. She has an exemplary reputation in the marketfor her capabilities in representing the firm, clients or specificindustry to negotiate and provide technical analysis to local andcentral tax authorities for tax rulings and tax incentives. Huongalso has direct contact to a pool of national and internationalexperts to provide global ad-hoc support for various tax, finan-cial planning and public-private partnerships and foreign invest-ment-related issues.

During her 20 years of professional experience, Huong hashelped many clients to resolve various taxation issues with theauthorities. These often relate to issues raised during periodictax audits of companies by provincial tax departments.

Huong is a board member of the Vietnam Tax ConsultantAssociation and regularly represents EY to provide commentson draft laws and regulations on tax and customs. She is also a standing member and theleader of the tax group of the Vietnam Business Forum (VBF) in dialogues with the govern-ment, where she has actively contributed her opinions and initiatives. She is an excellent linkbetween VBF’s foreign investors and regulator/policymakers to resolve any issues or con-cerns of an investor on the investment environment, as well as the tax policy and tax systemin Vietnam.

In working on policy issues and representing industry groups in discussions with the cen-tral tax authorities or Ministry of Finance, Huong is assisted by EY’s specialist governmentliaison team, which has developed strong contacts with all levels of the tax administration –from provincial tax department to ministry and government level.

Huong holds an MBA from the Western Pacific University (US), and is a member of CPAAustralia. Prior to her professional experience in finance, Huong used to be a lecturer atVietnam Maritime University.

Vietnam

Huong Vu

EY Vietnam

8th Floor, CornerStone Building,16 Phan Chu TrinhHoan Kiem District, HanoiVietnam

Tel: +84 4 38315100Mobile: +84 903432791 Email: [email protected] Website: www.ey.com


Vietnam

Frederick BurkeBaker & McKenzie

Richard IrwinPwC

Tram Le BaoPwC

Huu Phuoc NguyenPhuoc & Partners

Thanh Vinh NguyenBaker & McKenzie

401 | www.internationaltaxreview.com TAX CONTROVERSY LEADERSTAX CONTROVERSY LEADERS www.internationaltaxreview.com | 401

Index of firms

11 New Square, 328-330

AAA Advogados, 233

Abreu Advogados, 234

Accura, 107

Adachi Henderson Miyatake & Fujita, 190

Advaita Legal, 164

Advocacia Krakowiak, 53

Afschrift, 42

Akin Gump Strauss Hauer & Feld, 250

Alcalde & Cia Abogados, 83

Alder & Sound, 111

Allen & Overy, 42, 142

Amplo, 83

Andre Teixeira & Associados, 54

Arendt & Medernach, 192

Arsene Taxand, 124

Ashurst, 124

Asorey & Navarrine, 8

Ateleia, 124

Atlas, 217

Avellum Partners, 315

Azman Davidson, 197

BAHR, 225

Baker & McKenzie, 8, 24, 26, 31, 42, 79,103, 106, 124-125, 142-143, 150, 154,173, 183, 190, 197, 209-210, 217, 225,228, 231, 250, 258, 278-279, 291, 300,306, 312, 315, 328-330, 365, 387-390,394, 401

Balaguer Morera & Garcia Del Rio, 278

Baniqued & Baniqued, 228

Barbosa Mussnich Aragao Advogados, 52-53

Basham Ringe y Correa, 209

Bech-Bruun, 107

Bekes Partners, 154

Berwin Leighton Paisner, 331

Bichara Barata & Costa Advogados, 52

Bird & Bird, 111

Bjørnholm Law, 107

BKP (Brauneis Klauser Prandl), 31

Blakes, 79-81

BMR Legal, 164

Bond Dickinson, 329

Bonelli Erede, 183

Booij Bikkers Lawyers, 217

Borenius Attorneys, 111

Brauneis Klauser Prandl, 31

Bruchou Fernandez Madero & Lombardi,8

Bruchou Fernández Madero & Lombardi,8

Index of firms


BSR & Co, 164

Bulit Goñi & Tarsitano, 8

Cabinet Turot, 125

Campos Ferreira Sa Carneiro, 234

Caplin & Drysdale, 389

Carey, 83

Carey Olsen, 330

Carlé Korn Stahl Strahl, 143

Casals Abogados, 279

Castro Barros Sobral Gomes, 52-53

Chamberlain Hrdlicka White Williams &Aughtry, 388, 390

Chiomenti Studio Legale, 183

Chouette, 291

Clayton Utz, 25

Cleary Gottlieb Steen & Hamilton, 124,390

Cliffe Dekker Hofmeyr, 262

Clifford Chance, 321, 329-330

CMS Bureau Francis Lefebvre, 116, 124

Collins Barrow (Canadian member of BakerTilly International), 65

Cooley, 388

Cordeiro Guerra & Associati, 183

Corrs Chambers Westgarth, 25

Cragus Group, 144

Crowe Horwath Australia, 25

Crowell & Moring, 390

Cuatrecasas, 278

Cuatrecasas Goncalves Pereira, 234

D’Empaire Reyna Abogados, 391-393

D&B David si Baias/PwC, 237

Darrois Villey, 124

Dauginet, 42

Davies Ward Phillips & Vineberg, 79

Davis Polk & Wardwell, 390

De Bont Advocaten, 217

De Pardieu Brocas Maffei, 124

Deloitte, 10-13, 15, 22, 28-30, 34, 39-41,44, 55, 57, 59, 62, 67, 72-73, 75-76,79, 88-89, 92-93, 95, 98-99, 101-102,108-110, 129-130, 133-135, 137-138,148-149, 166-168, 170, 172, 174-177,184-185, 188-189, 193-195, 199-201,203-205, 207-208, 211-213, 219-220,223-224, 226-227, 230, 235-236, 239,252, 254-257, 259, 261, 263-268, 270-277, 280, 282, 284, 286, 292, 297-299,301-305, 307-310, 316, 318, 322-327,329, 339, 342, 345, 348-349, 357, 359,366, 368, 370, 374, 376, 379-380, 383,386, 395-396, 399

Deloitte Haskins & Sells, 155-157, 159,161

Deloitte Legal Szarvas Erdős and PartnersLaw Firm (Hungary), 151

Demarest Almeida, 52

Dentons, 56, 58, 60-61, 64, 70, 74, 77,104, 118, 127, 229, 240, 242-244, 246,248-249, 313, 350, 367

Dhruva Advisors, 164

DLA Piper, 31, 150, 154, 183, 315

Dr Gunter Dorr & Kollegen, 142

Dr Suvarn Law Offices, 306

Drew & Napier, 258

Index of firms


Index of firms

Economic Laws Practice, 160, 162-163

Edwards y Cia, 83

Eleven Wentworth Chambers, 25

ENSafrica, 260

Espanha e Associados, 233

Estudio Beccar Varela, 8

Estudio O’Farrell, 8

Eurofast Taxand, 106

Euroglobal SEE Audit, 106

Eversheds, 330

EY, 24, 31, 54, 80-81, 103, 106, 111, 124,143, 150, 154, 164-165, 173, 183, 190,192, 197, 202, 206, 209-210, 218, 221,225, 228, 231, 234, 238, 250, 258, 262,269, 278-279, 291, 306, 315, 328, 330-331, 388-389, 394, 400

EY (SGV & Co), 228

Fasken Martineau, 79-80

Felesky Flynn, 80

Fenwick & West, 332, 343, 351-353, 360,371, 378

Fidal, 124

Field Court Tax Chambers, 317

Fraga Bekierman & Cristiano, 52

Frenkel & Associés, 124-125

Freshfields Bruckhaus Deringer, 31, 42,125, 142, 183, 217, 328

Galhardo Vilão Torres - Sociedade deAdvogados, 234

Garrigues, 83, 233, 278-279

Geoffrey Clews, 221

Gillioz Dorsaz & Associés, 300

Goltsblat BLP, 250

Gowling WLG, 79-80

Greenwoods & Herbert Smith Freehills,24-26

Gunster, 389

Hall & Wilcox, 19

Hannes Snellman, 107, 111

Harleys Chambers, 221

Haynes and Boone, 209

Herbert Smith Freehills, 24-26, 250, 329

Hernandez y Cia, 225

Hertoghs Advocaten, 217-218

Hogan Lovells, 210, 328-329, 331

Hulgaard Advokater, 107

Hunton & Williams, 306

Independent, 150, 164

Independent barrister, 221

Ivins Phillips & Barker, 390

Jaegers & Soons Advocaten, 217

Jalsovszky Law, 154

Johnson Winter & Slattery, 24-25

Joseph Hage Aaronson, 328-329, 331

Khaitan & Co, 164

Kim & Chang, 269

King & Wood Mallesons, 24-25

Kinstellar, 315

Klemprer Rivas Pérez Trujillo & Asociados,394

KM Partners, 315


Kotschnigg, 31

KPMG, 23-25, 31, 42, 48, 79, 83, 103,106, 111, 142-144, 150, 154, 164-165,173, 190-192, 197, 209-210, 221, 225,228, 231, 233-234, 238, 250, 258, 262,269, 278-279, 291, 300, 306, 312, 315,328-329, 358, 387-390

KPMG Acor, 107

KPMG Meijburg & Co, 217

KPMG/Fidal Direction Internationale, 124

Krishnomics Legal, 158, 164

Krogerus, 111

Kroy Abogados, 209

Küffner Maunz Langer Zugmaier, 142-143

Latham & Watkins, 388

Lautenschlager Romeiro e IwamizuAdvogados, 45

Lavrynovych & Partners, 315

Law Offices of Michael C Durney, 387

Law Offices of Michael J Desmond, 387

Law Square, 33, 35-36, 38

LB Y Cia, 209

Lee & Li, 306

Lefosse Advogados, 52

Leitner & Leitner, 31

Lenz & Staehelin, 294

Liedekerke, 42

Linklaters, 42, 142, 278

Long An Law Firm, 91

Loyens & Loeff, 42, 217

Ludovici Piccone & Partners, 183

Luna Requena & Fernandez BorzeseAbogados, 8

Luthra, 165

Macchi di Cellere Gangemi, 183

Machado Associados, 52-53

Machado Meyer, 53

Maisto e Associati, 183

Majmudar & Partners, 164

Marchenko Danevych, 315

Marimon Abogados, 278

Mariz de Oliveira e Siqueira Campos, 53

Martin Brown Sullivan Roadman &Hartnett, 387

Marval O’Farrell and Mairal, 8

Matheson, 173

Mattos Filho, 52-54

Mayer Brown, 37, 47, 49-50, 112, 114,119-120, 319, 337, 341, 347, 354, 356,361-364, 369, 372-373, 377, 381, 385

McCarthy Tetrault, 79

McDermott Will & Emery, 142, 387-390

Miller & Chevalier, 388

Miller Thomson, 79

Minter Ellison, 24-25

Miranda Correia Amendoeira, 233

Mitrani Caballero Ojam & Ruiz Moreno, 8

Monard Law, 42

Morais Leitao Galvao Teles Soares da Silva& Associados, 233

Morgan Lewis & Bockius, 389-390

Nagashima Ohno & Tsunematsu, 190

Index of firms


Index of firms

Nagy és Trócsányi, 154

Natanael Martins Mario Franco e GustavoTeixeira, 53

Nazali Attorney Partnership, 311

NERA, 140

New Chambers, 24-25

Nik Saghir & Ismail, 197

Nishimura & Asahi, 190

Norton Rose Fulbright, 79, 388

Oberson Abels, 300

Oikonomidis - Kontos, 143

One Crown Office Row, 331

One Essex Court, 329-330

Ong Sim Ho, 258

Oppenhoff & Rädler, 142

Oracle India, 164

Ortiz Hernandez y Orendain, 209

Osborne Clarke, 278

OSE, 209-210

Osler Hoskin & Harcourt, 66, 71, 79-80

P+P Pöllath, 142-143

Pepeliaev Group, 250

Pérez Alati Grondona Benites Arntsen &Martínez de Hoz, 8

Peter Nordquist Advokatbyrå, 291

Philippe Derouin Avocat au barreau deParis, 115

Phuoc & Partners, 401

Pinheiro Neto Advogados, 52

Pinsent Masons, 328, 330-331

Platinum Tax Consultants, 197

Plesner, 107

PLMJ, 234

Pump Court Tax Chambers, 328-331

PwC, 3, 8-9, 14, 16-18, 20-21, 24-25, 27,32, 42-43, 46, 51-53, 69, 78, 82-87, 90,94, 96-97, 100, 103, 105-107, 111, 113,124, 126, 128, 131-132, 136, 139, 141-143, 145-147, 150, 152, 154, 165, 169,171, 173, 178-181, 183, 186-187, 190,192, 196, 198, 209-210, 214-216, 222,231-234, 241, 245, 251, 253, 262, 269,278-279, 281, 287-289, 291, 293, 295-296, 312, 314-315, 320, 328-331, 338,340, 344, 346, 375, 382, 384, 387-390,397-398, 401

PwC Law, 63, 68

PwC/Landwell & Associés, 124-125

PwC/Reti Antall & Partners Law Firm,154

Python, 300

Quinones Cruz, 106

Radzikowski Szubielska i Wspólnicy, 231

Raffalli de Lemos Halvorssen Ortega Ortiz,394

Raja Darryl & Loh, 197

Ramón y Cajal, 278

Réti Antall & Partners Law Firm/PwCLegal, 153

Rodríguez & Mendoza, 394

Rogerio Fernandes Ferreira & Associados,233-234

Rosso Alba Francia & Asociados, 8

RPC, 328

RSM, 329


Russell McVeagh, 221

Salvador & Associates, 228

Sánchez DeVanny, 210

Santamarina y Steta, 209

Sapag & González Abogados, 83

Schekin and Partners, 247

Schellenberg Wittmer, 300

Selmer, 225

Serge Gloutnay, 79

Sergio André Rocha Advocacia &Consultoria Tributária, 53

Servulo, 234

Sharp Partners, 390

Shearman & Sterling, 388

Shearn Delamore & Co, 197

Simmons & Simmons, 331

Skadden Arps Slate Meagher & Flom, 328,387-390

Skeppsbron Skatt – Taxand, 283, 285, 290-291

Slaughter and May, 329-331

SML Tax Chamber, 164

Sole practitioner, 164

Stocche Forbes, 53

Stout Street Chambers, 221

Streck Mack Schwedhelm, 142-143

Studio Biscozzi Nobili, 183

Studio Tremonti Romagnoli Piccardi eAssociati, 182

Sullivan & Cromwell, 124, 388

Sullivan & Worcester, 388-390

Sutherland Asbill & Brennan, 387, 389

Taj Société d’Avocats, 117, 121-123

Tauil & Chequer Advogados in associationwith Mayer Brown, 47, 49-50

Tax-Insight, 217

Teijeiro & Ballone Abogados, 8

Temple Tax Chambers, 328, 330

Tenth Floor Chambers, 25

Thompson & Knight, 389

Thompson Hine, 387

Thorndon Chambers, 221

Thorsteinssons, 80-81

Tommy V Christiansen Law Firm, 107

Torres Plaz & Araujo, 394

Torys, 80

Trench Rossi e Watanabe Advogados, 53-54

Trilegal, 165

Turanzas Bravo & Ambrosi, 209

Ulhôa Canto Rezende e Guerra Advogados,52

Ulrich Sorgenfrei, 143

Uría Menéndez, 278

Uria Menendez Proença de Carvalho, 234

Victorian Bar, 24

Vieira de Almeida & Associados, 233-234

Villarroel Lecaros Aste and BaraonaAbogados, 83

Vinhas e Redenschi, 52

Index of firms


Index of firms

Vinson & Elkins, 388

Wagener & Associés, 125

Walder Wyss, 300

Weil Gotshal & Manges, 231

White & Case, 250, 387

William Fry, 173

Wintertaling, 217

Wladimiroff Advocaten, 217

Wolf Theiss, 31

Your Legal Partners, 143

Zepos & Yannopoulos, 143

Zhong Lun, 103

Zizzo e Associati, 183

Zuzunaga & Assereto Abogados, 225


tax controversy leaders - international tax revie · tax controversy leaders the comprehensive...

Documents