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Women in TaxLeadersThe comprehensive guide to the world’s leadingfemale tax advisers
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8 Bouverie Street, London EC4Y 8AX, UKTel: +44 20 7779 8308Fax: +44 20 7779 8500Managing editor Ralph [email protected] Matthew [email protected] Joe [email protected] editor, TPWeek.com Sophie [email protected], TPWeek.com Joelle [email protected] editor João [email protected] Oliver [email protected] publisher Andrew [email protected] associate publisher Megan [email protected] Marketing executive Sophie [email protected] Subscriptions manager Nick [email protected] manager James [email protected] director Greg KilminsterSUBSCRIPTIONS AND CUSTOMER SERVICESCustomer services:+44 20 7779 8610UK subscription hotline:+44 20 7779 8999US subscription hotline:+1 800 437 9997© Euromoney Trading Limited, 2015. 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.Chairman Richard EnsorDirectors Sir Patrick Sergeant, The Viscount Rothermere,Christopher Fordham (managing director), Neil Osborn,John Botts, Colin Jones, Diane Alfano, Jane Wilkinson,Martin Morgan, David Pritchard, Bashar AL-Rehany,Andrew Ballingal, Tristan HillgarthInternational 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
3 OverviewWomen in tax:Diversity
4 Australia
11 Austria
12 Belgium
13 Brazil
14 Bulgaria
15 Canada
16 China
17 Colombia
17 Croatia
18 CyprusDomicile underCypriot Tax Law
21 CzechRepublic
21 Denmark
21 Finland
22 France
24 GCC (UAE)
25 Germany
27 Greece
27 Hong Kong
28 India
35 Indonesia
36 Ireland
38 Italy
39 Latvia
39 Lithuania
40 Luxembourg
41 Malaysia
42 MaltaIntroduction toMalta’scorporateincome taxregime
46 Mexico
49 Netherlands
50 New Zealand
51 NorwayMethod forgross up of netsalary forcross-borderemployees
55 Philippines
55 Poland
56 Portugal
57 Romania
58 Russia
59 Singapore
61 South Africa
62 Spain
63 Sweden
67 Switzerland
68 Taiwan
68 Tunisia
69 Turkey
70 Ukraine
71 UK
80 USWomen in tax:The USperspective
95 Index of firms
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IntroductionIt is acknowledged that gender inequality is anunacceptable and outdated concept. Judging theability of a professional – in whatever sphere theyhappen to operate – by reference to gender, is nei-ther appropriate nor helpful.
Despite recent advances in the area of diversity,women account for just 15% of board members ofthe top S&P 1500 companies. This figure may bethe highest it has ever been, but given that womenmake up roughly half of the population, and of theworkforce, it is easy to see that the picture remainsskewed.
The amount of women in public accountingfirms diminishes by 60% at partner level, accordingto research from Tax Talent. In 2014, men account-ed for 79% of the partnership at Big 4 accounting firms, while females made up 21%. Onentry to senior staff, the gender mix is roughly 50-50. Statistics like this show that while theglass ceiling may be higher than ever before, it still exists.
Companies should be keen to smash through this barrier, particularly given that variousstudies show greater gender balance as directly proportional to better business performance,while research from Wake Forest University and University of North Carolina-Wilmingtonindicates that diversity in the C-suite leads to more honest financial decision-making. Intoday’s world where transparency and reputation are of central importance to multinationalcompanies, boardrooms cannot afford to take any backward steps. Part of the solution maybe staring them in the face.
There is clearly still work to be done to completely eradicate gender bias. An importantpart of finding parity on gender issues is addressing the historical imbalance. This is part ofthe motivation for launching International Tax Review’s Women in Tax Leaders guide. Wewant to highlight some of the women making strides in a field traditionally viewed as male-dominated.
This guide also brings you a selection of articles contributed by some of the leading femaleadvisers listed within its covers. These range from tax technical analysis pieces aimed at giv-ing readers a primer on some of the areas these women are excelling in, to insights on thespecific impact women are making in the tax advisory practices of law and accountancy firms,as well as tax boutiques.
Matthew Gilleard, Editor, International Tax Review
Methodology
Women in Tax Leaders is a guide tothe leading female tax advisers inthe world. Inclusion in the Womenin Tax Leaders guide is based on aminimum number of nominationsreceived from peers and clients,along with evidence of outstandingsuccess in the past year. Firms andindividuals cannot pay to be recom-mended in this guide.
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Gender diversity is an issue that all firms need to consider if theyare to develop a truly modern workforce.
Females must be represented at every level of an organisa-tion, as appointing women to high-profile positions makes iteasier for others to follow in their footsteps.
Big 4 firms around the globe are working towards partner-ship gender equity and have ambitious goals around this sub-ject. There are promising figures around newly appointedfemale equity partners and this is key to the tax professionattracting and retaining talent.
We are seeing firms ranked according to parental leave andpartnership gender equity and firms are now viewing diversity asa strategic key to commercial success and not just an employerbranding initiative.
Why promote gender diversity in tax? There are various studies into diversity and the avoidance ofrisk. The overall findings demonstrate that adopting genderdiversity directives leads to altering the cultures and values with-in an organisation, in turn promoting greater balance. We see anincreasing number of professionals moving into the C-suite andprofessional services leadership roles. Diversity in tax shouldlead to an increase in the percentage of women securing toplevel leadership positions.
Diversity and its related goals are long term projects thatshould be underpinned by talent development, succession plan-ning and continuous measurement of results. Improvements areevident but we need to sustain and build on them.
Overview
Elspeth McAinshBrewer Morris
Women in tax: Diversity
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Fiona leads Deloitte’s Australian Transfer Pricing practice – ateam with more than 60 full time specialist practitioners. Fionahas more than 20 years’ experience with Deloitte in Australiaand the UK, including 15 years specialising in transfer pricing.Her impressive track record in achieving successful transfer pric-ing outcomes includes experience in implementing and pricingtax efficient structures for large listed and privately ownedmultinational companies.
Fiona’s experience in negotiating and settling transfer pric-ing cases with revenue authorities in Australia and overseas hasresulted in an impressive list of successful outcomes for herclients – involving both transfer pricing reviews and transferpricing audits, as well as the negotiation of more than 30advance pricing arrangements.
Fiona has been recognised on multiple occasions as a leadingspecialist in Euromoney/Legal Media Group’s Expert Guide tothe World’s Leading Transfer Pricing Advisers.
Fiona is a regular presenter at taxation and industry focussedforums on transfer pricing and a frequent contributor to ATOand Treasury consultations on transfer pricing matters.
Fiona has specialised in transfer pricing for companies in the resources industry and alsoin the technology sector and advises many of these industries’ largest players.
Her work ranges from the structuring of supply chains and pricing of cross-border debtto the development of global policies for services and intangible payments.
Many of the arrangements of Fiona’s clients have been successfully included in APAarrangements or defended under audit.
Australia
Fiona Craig
Deloitte
Grosvenor Place225 George StreetSydney NSW 2000Australia
Direct: +61 (02) 9322 7770Email: [email protected]: www.deloitte.com
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Amelia O’Rourke is a director in Ryan’s Australian practicebased in Sydney and has held a variety of consulting, corporateand government roles.
Amelia advises large corporate clients on all aspects of GSTacross a range of industry sectors. She is particularly recognisedfor her depth of expertise in financial services, having previous-ly worked for five years as an in-house GST adviser for two ofAustralia’s largest financial institutions. Amelia has extensiveexperience in interactions with revenue authorities, includingaudit defence and dispute resolution, and is regularly consultedby the government on GST technical matters.
Amelia began her career in the Australian Taxation Office,including as a member of the original team that designed anddrafted Australia’s GST law. She performed the role of assistantcommissioner responsible for liaison between the AustralianTaxation Office, Treasury and the Parliament, and has alsoworked in the Assistant Treasurer’s Office and the Treasury’sindirect tax policy group.
Australia
Amelia O’Rourke
Ryan
Suite 402, 35 Lime StreetSydney NSW 2000Australia
Tel: +61 2 8243 5101Email: [email protected]: www.ryan.com
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Heather is a partner at Deloitte, the National Practice Leader ofthe Tax & Legal Quality & Risk Services group for DeloitteAustralia and the Global Practice Leader of the Tax & LegalQuality, Risk and Regulation for Deloitte Asia Pacific. She hasbeen a partner at Deloitte for almost 10 years, having joined in2006.
Leading the Quality & Risk management teams withinDeloitte, Heather supports teams with all matters relating toquality, risk management and regulation, including: compliancewith regulatory requirements; assessment of enterprise risks anddevelopment of appropriate risk mitigation plans; delivery ofexceptional client service by overseeing the development ofpolicies, procedures, tools and templates for all tax and legalprofessionals at Deloitte. She is responsible for making sure thattax and legal quality and risk keeps pace with changes impactingthe professional services sector and our clients, performing riskassessment on new service offerings and tools; and third partycontracting.
She also monitors the changing regulatory and social environment as it relates to taxservices.
Heather has been at the forefront of the debates surrounding base erosion and profit shift-ing (BEPS) and responsible taxation in Australia. She has assisted with submissions to theSenate Economics References Committee inquiry into corporate tax avoidance initiated bythe Australian Government in 2014, and appeared before the Committee at their public hear-ings.
Heather was also active in consultation regarding the regulation of tax advisers, includingthe development and implementation of the Tax Agent Services Act 2009 and variousAccounting Professional & Ethics Standards Board standards.
She has a strong interest in integrity, ethics and governance issues, and is the inauguralchair of Cycling Australia’s Ethics & Integrity Panel, appointed in consultation with theAustralian Sports Commission.
Heather has had a diverse career spanning 30 years, while constantly maintaining a focuson Australian direct and indirect taxes. Her roles have included: taxation senior associate withArthur Robinson & Hedderwicks (Lawyers), case manager for the Australian BankingIndustry Ombudsman Office, lecturer in tax and corporate law at the University ofMelbourne and the Queensland University of Technology, and taxation adviser at Ernst &Whinney and Bentley & Co.
Heather is a qualified Australian legal practitioner and chartered accountant, and holds amaster’s degree in law (Bond University), and bachelor’s degrees in law (QUT) and businessand accountancy (QUT) on top of qualifications in learning and knowledge management.
Australia
Heather Park
Deloitte
550 BourkeMelbourne 3000Australia
Email: [email protected]: www.deloitte.com
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Tracey is a corporate and international tax partner in Sydneywith more than 20 years of cross-border M&A, internationalstructuring and advisory experience.
Tracey is the Sydney leader of the Corporate & InternationalTax group.
Tracey provides advice on all major areas of Australian taxincluding capital gains tax issues relating to acquisitions, divest-ments and restructures, loss management and integrity issues,capital allowance provisions, repatriation matters, tax consolida-tion and IFRS.
Tracey was previously in the International and M&A groupand was the lead tax adviser on numerous IPOs, acquisitions ofmining and mining services companies and divestments.
She has also advised clients on the implementation of the taxconsolidation, TOFA and the minerals resource rent tax(MRRT) provisions.
Tracey advises clients mainly in the Energy & Resources sec-tor based in NSW including mining companies as well as min-ing services companies and suppliers to companies in these sec-tors.
She also provides tax services to clients in the retail, property, technology and tourism andleisure sectors.
Tracey is a national councillor of The Tax Institute as well as being a member of variouseducation, technical and membership committees of the Institute.
Tracey has a master’s in taxation from University of New South Wales and bachelor’sdegree in economics and law from Sydney University.
She has been admitted as a solicitor of Supreme Court of New South Wales, is an associ-ate of the Institute of Chartered Accountants of Australia and a chartered tax adviser of theTax Institute of Australia.
Australia
Tracey Rens
Deloitte
Grosvenor Place225 George StreetSydney NSW 2000Australia
Direct: +61 2 9322 7599Email: [email protected]: www.deloitte.com
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Karen is an R&D tax partner at Deloitte of 15 years in a careerspanning 25 years. Having spent close to seven years at an R&Dtax consulting firm, Karen joined Deloitte in 1997.
Leading the Consumer Business Industry group for tax with-in Deloitte Australia, Karen assists with the coordination andprovision of industry focussed tax advice to agribusiness, con-sumer product, retail, wholesale and distribution organisations.
Karen is responsible for the New South Wales (NSW) regionR&D Tax & Government Incentives practice, where she assistscompanies with securing funding for the furtherance of theirinnovation and capital projects within Australia.
Karen assists many of Australia’s key consumer business cor-porates with the delivery of industry focused tax advice. In par-ticular, Karen personally assists clients with securing funding tosupport their innovation and R&D strategic plans. Her depth ofconsumer business industry expertise adds value in the identifi-cation and qualification of associated funding programmes,including tax incentives and grants.
Her understanding of the innovation life cycles within theconsumer business industry, and the many related drivers and levers, assists with recognisingthe areas which may be supported by external funding.
Karen is a regular presenter at consumer business conferences and has assisted in a num-ber of industry awards programmes as a panel judge.
Karen also leads the NSW R&D life-sciences team, where she assists start-ups and developedlife-sciences and pharma companies maximise their R&D funding opportunities. Included inthis is the provision of detailed training sessions and workshops, analysis and review of record-keeping and innovation processes, and an examination of R&D projects. Karen assists suchcompanies with a focus on their clinical trials, overseas activities, foreign investments withinAustralia, involvement of exempt entities, and application of a range of grants.
Karen assists companies with ATO and IR&D Board audits, development of R&D taxconcession and incentive claims, and grant applications. She is focused on knowledge trans-fer and assisting companies with developing systems and processes which maximise theirR&D claims, and attainment of grants.
Karen holds a master’s degree in law (University of Sydney), diploma of legal studies(University of Technology, Sydney), and bachelor’s degrees in law (University of NSW) andeconomics (Macquarie University). She is also admitted as a solicitor of the Supreme Courtof NSW and is a former member of the Institute of Chartered Accountants Tax TechnicalCommittee. Karen is an external assessor on the Victorian Government’s Panel VoucherProgram.
Karen is studying an MSc degree in coaching psychology at Sydney University.
Australia
Karen Stein
Deloitte
Grosvenor Place225 George StreetSydney NSW 2000Australia
Direct: +61 2 9322 7387Email: [email protected]: www.deloitte.com
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Jill has more than 20 years of experience providing advice to glob-al organisations and their internationally mobile employees andexecutives covering issues from taxation, pensions, equity incen-tives, benefits, compensation planning, risk mitigation, socialsecurity, cost reduction, global employment companies, aligningpolicies with business strategy and regulatory compliance.
She was previously a senior partner with a Big 4 firm in theUK where she held a variety of leadership roles with responsibil-ity for up to 900 people across five European countries and abudget of €100 million.
In these roles she was involved in setting strategy, develop-ing business plans, delivering budgets, people management andimplementing various change management and transformationprojects including offshoring and digitalising user experiencesand processes.
She has been the lead global service line partner for a num-ber of organisations in the financial services and mining sectors.
She is based in Australia and has experience working in theUK and Hong Kong.
Jill has a master’s degree in environmental science, an MBA and is a qualified executivecoach, as well as holding professional qualifications from the Institute of CharteredAccountants of England & Wales, the Australian Institute of Company Directors and theChartered Institute of Taxation.
Australia
Jill Storey
Deloitte
Grosvenor Place225 George StreetSydney NSW 2000Australia
Direct: +61 451 832068Email: [email protected]: www.deloitte.com
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Australia
Fiona CahillDeloitte
Rebecca CohenPwC
Jenny ElliottPwC
Helen FazzinoPwC
Rosheen GarnonKPMG
Deborah JenkinsKPMG
Ada LamEY
Maria LuiKPMG
Carmen McElwainMinter Ellison
Jane RolfeKPMG
Judy SullivanPwC
Michelle TremainPwC
Sue WilliamsonEY
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Barbara Polster has been a partner in KPMG Austria’s tax prac-tice for more than 10 years and leads the Austrian M&A tax prac-tice. Before joining KPMG in 2005, she worked for PwC andArthur Andersen. Barbara has more than 25 years’ experience inserving multinational and major local companies and in advisingthem on all kinds of Austrian and international tax matters.
She has extensive expertise in corporate and international tax-ation, M&A tax structuring, tax due diligence, transfer pricingissues, litigations and arbitration procedures. She acts as lead taxpartner for larger consumers, manufacturing and telecommuni-cation clients across many sectors and leads a team of tax profes-sionals in Austria specialising in M&A and transfer pricing.
Barbara and her team have a high reputation for providinginnovative and practical solutions to Austrian and internationalclients. They represent their clients very successfully in taxaudits, advance pricing agreement (APA) appeal and arbitrationprocedures and negotiate with tax authorities on a senior level.
As frequent lecturer at business institutions and universitiesshe speaks about different tax matters including corporate andgroup taxation, transfer pricing, impacts of BEPS, financing,cash pooling, R&D incentives and others. She has published several books on internationaltaxation, M&A and cash pooling and private equity and many articles in the area of taxation.
Barbara has a master’s degree in business administration and is a certified tax adviser inAustria. She is member of the committee of Austrian tax experts and is actively involved inthe professional assessment of draft tax law in her areas of specialisation. Together with otherfemale partners in the Austrian practice, she has initiated the ‘KPMG Ladies Talk’ a breakfastfor leading businesswomen held twice a year which is well recognised as an eligible meetingand inspiration point by female business leaders in Austria.
Austria
Barbara Polster
KPMG Alpen-Treuhand
Porzellangasse 511090 ViennaAustria
Tel: +43 1 313 32-815Email: [email protected]: www.kpmg.at
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Austria
Imke GerdesBaker & McKenzie
Ingrid RattingerEY
Belgium
Francoise BaltusAvocats Baltus
Caroline DoccloLoyens & Loeff
Stephanie HouxAllen & Overy
Ine LejeuneLaw Square
Liesbet NevelsteenDeloitte
Astrid PieronMayer Brown
Laurence PinteLiedekerke Wolters Waelbroeck
Isabelle RichelleLiedekerke Wolters Waelbroeck
Annick van HoorebekeBaker & McKenzie
Isabel VerlindenPwC
Annick VisschersLaga
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Marienne Coutinho is an experienced tax partner at KPMG inBrazil, bringing more than 21 years of international experienceto her clients. As partner in charge of international tax, she alsoleads Brazil’s practices for transfer pricing and deal advisory –M&A tax. Marienne serves as a member of KPMG’s GlobalInternational Tax Steering committee, where she helps to devel-op, monitor and implement the firm’s global strategy for inter-national tax.
Based in São Paulo, Marienne works with major organisa-tions and multinational corporations to assist with complexprojects, delivering focused practical advice on Brazilian andinternational tax matters. Her areas of expertise include supplychain management, market entry, BEPS, M&A tax structuring,and corporate reorganisations, among others. Marienne alsoassists companies in evaluating the performance and structure oftheir tax functions in Brazil, reviewing processes, performingGAAP analysis, and advising on benchmarking and efficiencyimprovements.
Beyond her client work, Marienne is committed to influencingtax policy and furthering education. She actively representsKPMG before a number of organisations, such as GETAP[Grupo de Estudos Tributários Aplicados], an organisation thatcongregates major Brazilian companies and senior tax directors, and GET, an association thatdiscusses relevant tax topics with representatives of the administrative tax courts and tax admin-istration.
Marienne is a lawyer, and completed post-graduate work in international business affairsat Johns Hopkins University. She is a frequent author on issues related to taxation in Brazil,and is a regular speaker and presenter at tax conferences around the world. She is responsi-ble for the coordination of the KPMG guide, Investment in Brazil, and co-author of thebook, The Rise of Brazilian Multinationals.
Marienne was the first woman to become a tax partner at KPMG in Brazil and she con-tinues to advocate for the advancement of other professionals, including leading the KPMGdiversity initiative in Brazil as the leader of KPMG’s Network of Women, and serving as co-chair of the Brazil Chapter of Women Corporate Directors. She is a member of Mulheres doBrasil, IBEF-Mulher (Brazilian Institute of Finance Professionals) and LIDEM (WomenBusiness Leaders) and teaches at the esteemed Brazilian university FGV (Fundação GetulioVargas) on diversity in organisations.
Brazil
Marienne Coutinho
KPMG in Brazil
Rua Arquiteto Olavo Redig deCampos, 105, 10º andar04711-904, São Paulo - SPBrazil
Tel: +55 (11) 3940 3182Fax: +55 (11) 3940 5001Email:[email protected]: www.kpmg.com/BR
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Brazil
Andrea Bazzo LaulettaMattos Filho
Isabel BertolettiMachado Associados
Mariana De VitoTrench Rossi e Watanabe - in association with Baker & McKenzie
Daniela Duque EstradaCastro, Barros, Sobral, Gomes
Maria Fernanda Furtado FernandesTrench Rossi e Watanabe - in association with Baker & McKenzie
Luciana GalhardoPinheiro Neto Advogados
Maria Eugenia KanazawaTrench Rossi e Watanabe - in association with Baker & McKenzie
Alessandra MachadoTrench Rossi e Watanabe - in association with Baker & McKenzie
Cristiane MagalhaesMachado Associados
Simone MusaTrench Rossi e Watanabe - in association with Baker & McKenzie
Raquel NovaisMachado Meyer
Lucilene PradoDerraik & Menezes Advogados
Adriana StamatoTrench Rossi e Watanabe - in association with Baker & McKenzie
Ana Cláudia Akie UtumiTozziniFreire Advogados
Tatiana Galvao VillaniMachado Associados
Erika Yumi TukiamaMachado Associados
Bulgaria
Dobrinka ShishkovaAFA OOD
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Canada
Carrie AikenBlake, Cassels & Graydon
Monica BiringerOsler, Hoskin & Harcourt
Wendy BrousseauMcCarthy Tetrault
Alexandra BrownBlake, Cassels & Graydon
Audrey DiamantPwC
Nancy DiepBlake, Cassels & Graydon
Cheryl GibsonDentons
Laurie GoldbachDeloitte
Nathalie GoyettePwC
Jennifer HannaMNP
Alison JacksonEY
Erin JensenKPMG
Jodi KelleherKPMG
Claire KennedyBennett Jones
Martha MacDonaldTorys
Deborah MacPhersonKPMG
Lori MathisonDentons
Janice McCartBlake, Cassels & Graydon
Siobhan MonaghanKPMG
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Canada
Anu NijhawanBennett Jones
Kathleen PennyBlake, Cassels & Graydon
Gabrielle RichardsMcCarthy Tetrault
Janice RoperDeloitte
Wanda RumballKPMG
Michelle SledzKPMG
Carrie SmitGoodmans
Manon ThiviergeOsler, Hoskin & Harcourt
Deborah ToazeBlake, Cassels & Graydon
Katri UlmonenMNP
Kimberley WharramOsler, Hoskin & Harcourt
Sabrina WongBlake, Cassels & Graydon
Penelope (Penny) WoolfordKPMG
China
Xiaoying ChenPwC
Julie ChengJun He
Liqun GaoDeloitte
Vivian JiangDeloitte
Daisy KangPwC
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China
Eunice KuoDeloitte
Nancy LaiBaker & McKenzie
Jean LiEY
Lilly LiKPMG
Amy LingBaker & McKenzie
Jinghua LiuBaker & McKenzie
Joanne SuEY
Jane WangPwC
Janet XuPwC
Dolly ZhangDeloitte
Janet ZhangDeloitte
Julie ZhangDeloitte
Colombia
Lucy Cruz de QuinonesQuinones Cruz
Catalina HoyosGodoy & Hoyos
Croatia
Maja MaksimovicKPMG
Helena SchmidtDeloitte
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Surprising as it may seem, most of the advantages of the Cypriottax regime were, up until recently, directed at non-Cypriot taxresidents. This effectively meant that, to enjoy the full benefitsof the regime, one had to be a non-resident.
The idea behind this was to have a twofold regime, one forCypriot tax residents and one for investors wishing to use Cyprusas part of their tax planning operations. This distinction at firstseems logical and is actually a method applied in many jurisdic-tions with attractive tax regimes. The locals pay their taxes to thegovernment while specific tax incentives are in place to encourageinternational investors to make new investments.
Over the years, the government realised that many individu-als from abroad liked the Cypriot weather and lifestyle so muchthat they decided to make Cyprus their permanent home. Theapplicable rule, in accordance with the provisions of the CypriotIncome Tax Law, is that anyone residing for more than 183 dayswithin a given tax year becomes a Cypriot tax resident.
Many found the Cypriot tax regime attractive compared withtheir countries of origin. While the Cypriot regime was advan-tageous for the average individual wishing to enjoy Cyprus on adaily basis, this was not the case for high net worth individuals(HNWIs). More specifically, up until recently, a Cypriot tax res-ident had to pay, on a worldwide basis, a 17% special defencecontribution (SDC) on dividends, 30% SDC on interest onbank deposits and 3% SDC on rental income.
Narrowing of SDCIn a bid to attract HNWIs, the government has sought to cre-ate a further differentiation in the tax regime of Cyprus byintroducing the legal concept of ‘domicile’ as part of a series ofamendments to the tax legislation passed in July 2015.
Cyprus
Zoe KokoniEurofast Taxand
Domicile under Cypriot TaxLaw
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Cyprus
The concept of domicile was inserted into the provisions of the SDC law, clearly aimed atcreating a further differentiation in the tax regime. The end result is that tax residents mustalso be domiciled in Cyprus in order to be required to pay SDC on dividends, interest onbank deposits and rental income.
The legal concept of domicile is not a new concept in Cypriot law. Domicile was alreadyincluded in the provisions of the Cypriot Wills and Succession Law and is very important fordetermining which jurisdiction shall govern and regulate the succession of a deceased person.Indeed, the determination of domicile for succession purposes stems from a set of rules basedon domicile of origin (where someone was born) and domicile of choice (where someone hasdecided to make their permanent home).
It should be stated, however, that the determination of domicile should be seen as distinctfrom citizenship or residence. The determination of domicile for succession purposes is basedupon specific legal rules and specialist legal advice should be obtained.
The new amending provisions of the SDC law provide that a tax resident for the purpos-es of SDC law (and not income tax law) shall be a person also having its domicile of originin Cyprus in accordance with the provisions of the Wills and Succession Law.
Furthermore, the new provisions provide that there shall be an exemption from SDC obli-gations for persons having their domicile of choice in accordance with the Wills andSuccession Law outside Cyprus (provided they have not been tax residents in Cyprus underthe 183 days rule during the 20 years before the tax year in question) or simply a person whohas not been a tax resident of Cyprus for 183 days a year in the last 20 years. It should alsobe noted that anyone who has been a tax resident of Cyprus for 17 of the last 20 years pre-ceding the tax year in question shall be deemed to have its domicile in Cyprus.
This new amendment will have profound effects in the area of tax planning and is expect-ed to place Cyprus on the map as one of the best jurisdictions in the world for the establish-ment of residence for high net worth individuals. Obviously, specialist advice should beobtained from tax and legal experts in order to plan and achieve such tax migration exercis-es in accordance with the new provisions of the SDC law.
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Zoe Kokoni is a director in the International Business Servicesdivision at Eurofast Taxand. With more than 20 years of expe-rience in taxation issues, she is the head of the company’sDomestic Tax department. Zoe specialises in the estate duty, theinternal tax legislation and its applicability for a great number ofyears. Her extensive wealth of experience concerning advanceddomestic taxation matters has enabled Zoe to provide our com-pany with strong administrative heritage incentives.
She is a regular participant and speaker in various interna-tional and local conferences concerning tax related matters.
Cyprus
Zoe Kokoni
Eurofast Taxand
Cypress Centre, 5 Chytron StrPO Box 24707 1302 Nicosia Cyprus
Tel: +357 22 699 222Email: [email protected]: www.eurofast.eu
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Czech Republic
Ditta HlavackovaHLB Proxy
Eliska KominkovaBaker & McKenzie
Helena NavratilovaKocian Solc Balastik (KSB)
Denmark
Vicki From JorgensenEY
Lida HulgaardHulgaard Advokater
Mette JuulPlesner
Bente Moll PedersenRonne & Lundgen
Bodil TolstrupPlesner
Finland
Kirsti AuranenEY
Henna JovioBorenius
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Admitted to the Paris Bar and qualified in the UK as a solicitorof England and Wales, Sabina Comis is a tax partner and inter-national co-leader of the Private Investment Funds group ofMayer Brown.
She has 18 years of wide–ranging tax experience with astrong emphasis on complex corporate tax structurings andfinancial restructurings, both in France and internationally. Shealso regularly represents clients in tax dispute resolutions.
Sabina has further become a recognised expert on the cre-ation and structuring of private investment funds (private equi-ty or real estate vehicles, and joint ventures, among others). Hertax experience, coupled with her funds’ legal and regulatoryknow-how, allows Sabina to advise on tailor-made, innovativestructures for investments in France and throughout Europe,such as the setting up of: (i) the first dedicated Europeanprovider of mezzanine and preferred equity financing for privateequity portfolios; (ii) the first French regulated and leveragedinvestment vehicle for the purchase of discounted debt; and (iii)the first French type endowment fund.
Sabina regularly speaks at conferences and is a tax lecturer at the University of Dauphinein Paris (Master 2 of Tax “Fiscalité de l’Entreprise”).
Sabina joined Mayer Brown in 2007 after 10 years of practice with two of the UK’s ‘MagicCircle’ firms (having worked in their London and New York tax teams for four years and intheir Paris tax teams for more than five years).
She holds an LLB from the London School of Economics and an LLM from CambridgeUniversity in the UK.
In addition to her native Italian, Sabina is fluent in French and English.
France
Sabina Comis
Mayer Brown
20 Avenue Hoche75008 ParisFrance
Tel: +33 1 53 53 36 24Fax: +33 1 53 96 03 83Email: [email protected] Website: www.mayerbrown.com
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Sabine is a partner in Bird & Bird’s international tax group,based in Paris.
Sabine Sardou is a highly-reputed specialist in internationaltax transfer pricing with more than 20 years of experience underher belt.
Sabine’s specific focus is on defence, strategic tax planningand documentation work. Her recent assignments include cor-porate conversions into low-risk structures (limited-risk distrib-utors, agents/commissionaires and consignment manufac-tures); advance pricing agreements; permanent establishmentissue resolution; extensive negotiation with the French taxauthorities through tax audits and tax litigation and successfultax defence memos regarding management fees, complex struc-turing (consulting services), and loss-making distributors.
She has experience across a number of sectors, includingautomotive IT, communications, pharmaceuticals, financialservices and luxury goods.
After 20 years of transfer pricing practice in the internation-al tax department of Big 4 law firms, including PwC, EY and forthe last eight years, as a transfer pricing partner of Taj, theFrench member law firm of Deloitte, Sabine recently joined thevery well-known international law firm, Bird & Bird.
Sabine teaches transfer pricing and international tax law at several French universities andbusiness schools, and is a frequent participant in professional discussions and training semi-nars. She regularly writes transfer pricing-related articles for tax and business newspapers andmagazines.
A member of the French Bar, Sabine also holds post-graduate degrees in tax and business law.
France
Sabine Sardou
Bird & Bird
Centre d’Affaires Edouard VII3 square Edouard VII75009 ParisFrance
Direct: +33 (0)1 42 68 60 86Tel: +33 (0)1 42 68 60 00Fax: +33 (0)1 42 68 60 11Email:[email protected] Website: www.twobirds.com
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France
Elisabeth AshworthCMS Bureau Francis Lefebvre
Stephanie AuferilBaker & McKenzie
Sonia BonnabryLexcom
Delphine BouchetArsene – Taxand
Ariane CalloudBaker & McKenzie
Anne-Sophie CoustelCleary Gottlieb Steen & Hamilton
Aurelia de ViryKing & Spalding
Marie-Odile DuparcCMS Bureau Francis Lefebvre
Anne GroussetCMS Bureau Francis Lefebvre
Sandra HazanDentons
Audrey-Laure IllouzFIDAL International/KPMG
Sophie JouniauxBaker & McKenzie
Annette Ludemann-OberValoris Avocats
Marie-Helene RaffinWillkie Farr & Gallagher
Elisabeth RivierePwC/Landwell
Caroline SilberzteinBaker & McKenzie
GCC (UAE)
Fiona McClaffertyDeloitte
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Eveline Beer is a partner at KÜFFNER MAUNZ LANGERZUGMAIER (KMLZ). She is a lawyer and a certified tax consultant.
Eveline Beer started her career in 2004 at one of the Big 4accounting firms. From the outset, her focus was on VAT. In2008 Eveline joined KMLZ, a leading German law firm, special-ising in national and international VAT law and customs.Eveline was made a KMLZ managing associate in 2010 andpartner in April 2013.
Eveline advises multinational companies on both domesticand international VAT issues. The majority of her clients oper-ate in the retail and automotive sectors. Other clients represent-ed by Eveline include equipment manufacturers, while large andmedium-sized businesses, German corporate groups and for-eign companies of all sizes, including DAX 30 quoted compa-nies, rely on her VAT expertise in special cases as well as on aroutine basis.
Eveline’s work on international projects includes undertak-ing VAT reviews, assisting clients with their VAT reporting obli-gations and advising clients on how to reorganise their supplychains. In this respect, she works closely with KMLZ’s network of experienced and leadingtax experts in all member states of the European Union, as well as a large number of addi-tional countries.
Eveline regularly holds in-house VAT seminars for clients and assists them on-site withtheir day-to-day business, as well as in the course of VAT audits. Eveline is a deputy memberof the European Commission’s expert group for VAT-related issues (VAT Expert Group) andregularly publishes articles in professional magazines.
In May 2015 KMLZ opened a second office, in Dusseldorf, with Eveline heading up theteam.
Germany
Eveline Beer
KÜFFNER MAUNZ LANGERZUGMAIER
Speditionstraße 2140221 Düsseldorf Germany
Tel: +49 (0)211/540953-35Fax: +49 (0)211/540953-99Email: [email protected]: www.kmlz.de
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Dr Karen Möhlenkamp is managing partner of WTS and one ofthe leading experts in indirect and consumption tax in Germany.From 2013 onwards the German newspaper Handelsblatt andBest Lawyers USA have honoured her for being one of the bestGerman tax lawyers.
Karen graduated in law at Julius-Maximilians-UniversityWürzburg and worked at the Department of International Lawheaded by Prof. Dr. Ranieri to pass her PhD. After being spon-sored as a scholar at the Max Planck Institute (Frankfurt amMain) for European legal history, she took up employment withan international auditing and tax consultancy firm and with theFederation of German Industry (BDI). At BDI, she addressedthe key interests of the German industry regarding the Germanenvironmental tax reform, restructuring of the VAT Law Codeand local business tax reform to the German House ofParliament (Deutsche Bundestag) and the Federal TaxDepartment and took part in legal proceedings to the FederalConstitutional Court.
At WTS, Karen’s area of focus remains on VAT, energy taxand energy law. She is involved in delivering expert opinions on complex issues and develop-ing optimisation models and reaches a wide audience through numerous publications. As afounding member of the ‘Berlin Tax Discussions’ (Berliner Steuergespräche) and GermanEnergy Tax Conference, and as a member of the German Institute of Certified TaxConsultants (Fachinstitut der Steuerberater), she also deals with tax topics outside WTS.
As the mother of two children she is doing charity work as managing director of theBenedikt Niemeyer Foundation ‘Children Make Music’ programme and is a member of theInternational Lions Organisation, acting in 2012/2013 as president of the Lions ClubDüsseldorf-Leaina.
Germany
Karen Möhlenkamp
WTS
Peter-Müller-Straße 1840468 DüsseldorfGermany
Tel: +49 (0) 211 200 50 – 817Email:[email protected]: www.wts.de
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Germany
Stephanie AlzuhnKPMG
Kristina BexaClifford Chance
Barbara Fleckenstein-WeilandFlick Gocke Schaumberg
Claudia HillekKPMG
Nicole LooksBaker & McKenzie
Bettina MertgenDeloitte
Greece
Effie AdamidouKPMG
Kyriaki DafniDeloitte
Angela IliadisKPMG
Hong Kong
Agnes ChenEY
Elaine ChenClifford Chance
Sarah ChinDeloitte
Tracy HoEY
Ayesha LauKPMG
Yvonne LawDeloitte
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Pallavi heads the Tax and Regulatory services group, which spe-cialises in cross-border transactions, regulatory compliance,transaction tax advisory services, transfer pricing, indirect taxesand compliance and outsourcing.
Pallavi qualified as a chartered accountant in 1990 and hasmore than 25 years of post-qualification experience in the fieldof taxation.
Pallavi’s area of expertise includes inbound and outboundstructuring advisory, including regulatory compliance for bothIndian and overseas investors. She has worked with clients ingetting approvals from the Reserve Bank of India and theForeign Investment Promotion Board.
Pallavi has also advised many clients (including listed compa-nies) on restructuring their operations. Depending on the driv-ers for restructuring, the advice has varied from merger,demerger, slump sale or a combination of these to rationalisa-tion and optimisation of overseas structures.
She has done significant work with corporates on theirdomestic internal restructuring to consolidate value and min-imise related party transactions.
Pallavi is also the People & Culture leader for the India firm; a role she plays in additionto her role as head of tax. She also leads the India – US corridor between the two memberfirms; an initiative aimed at ensuring that clients of the network get distinctive client serviceirrespective of their scale and size in locations other than their home jurisdiction and ensur-ing that relationships are grown, added and shepherded within the network.
Pallavi has a portfolio of clients which cuts across various industries including informationtechnology/information technology enabled services, manufacturing, aviation financial serv-ices and education, among others.
Pallavi is a Fellow Member of the Institute of Chartered Accountants of India. Pallavi is a member of the International Fiscal Association – India Branch. She is also a
member of The Indus Entrepeneurs (TiE) Delhi chapter. She is the co-chair of the PHDChambers committee on International Affairs for North America.
Pallavi is a regular speaker on tax issues and has addressed a number of seminars both with-in India and overseas. She actively contributes to newspapers and professional journals inIndia. She is also a trainer and actively participates in the Grant Thornton InternationalAdvanced Manager’s Programme.
Pallavi is an independent director on the board of Sona BLW Precision Forgings andFilatex. Filatex is listed on the Bombay Stock Exchange and the National Stock Exchange.
India
Pallavi Joshi Bakhru
Grant Thornton
6th Floor, Plot No.19A, Sector 16A, Noida 201301India
Tel: +91 120 7109094Mob: +91 98101 33230Email: [email protected]
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Daksha Baxi joined Khaitan & Co in 2007 to build the firm’sdirect and international tax practice. By the time she joinedKhaitan she had already gained significant experience workingwith global organisations and leading Indian international taxadvisers.
Daksha’s vast experience of working with advisers in severaljurisdictions (for 10 years outside of India and more than 20years in India) brings an added level of comfort to clients andprofessionals. She has significant and valuable expertise onadvising in international tax matters involving a variety of cross-border structures for investments in India by foreign corporatesand private equity investors as well as acquisitions by Indiancompanies outside India. Clients have benefited from herinsight pertaining to India entry strategies involving domestictaxation and interpretation of double taxation conventions.International not-for-profit organisations, educational institu-tions and other philanthropic organisations also benefit fromher expertise. She is well recognised for structuring and settingup of onshore and offshore funds for investments in India.Clients and professionals approach her for her tax expertiseencompassing all aspects of direct tax advisory, global restruc-turing and cross-border M&A transactions, complex tax issuesin equipment procurement and construction contracts, structured finance and employeeequity based compensations ranging from startups to listed companies. She also assists clientsin obtaining advance tax rulings to achieve tax certainty.
Daksha has been recognised by Chambers & Partners as an Indian tax expert for 2013 and2014; by Asia Pacific Leading Lawyers as one of the “most highly acclaimed tax profession-als in India”; by Citiwealth Leaders List as a leading tax lawyer for 2013; and by Who’s WhoLegal 500 for private client work (the only adviser in India recognised for this).
On top of her day-to-day advisory work, Daksha has co-authored numerous articles andpapers on cross-border tax issues and her opinion is regularly sought by media publicationsin India and beyond. She is also a regular speaker at various conferences on taxation organ-ised by the International Bar Association, International Fiscal Association, Society of Trustand Estate Practitioners (STEP), American Bar Association, Foundation for InternationalTaxation and others.
Daksha is a qualified chartered accountant and is an honours graduate in economics fromthe Manchester Metropolitan University, UK)
Daksha is a fellow member of the Institute of Chartered Accountants in England andWales and of the Institute of Chartered Accountants of India, as well as being a member ofthe Society of Trust and Estate Practitioners, the International Fiscal Association and theCore Group of Bombay Chartered Accountants’ Society.
India
Daksha Baxi
Khaitan & Co
One Indiabulls Centre, 13th Floor,Tower 1841 Senapati Bapat MargMumbai 400 013India
Tel: +91 22 6636 5000 Fax: +91 22 6636 5050�Email:[email protected]: www.khaitanco.com
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Pallavi Dinodia is a partner at SR Dinodia & Co CharteredAccountants. The firm is one of the oldest firms in India and isranked among the top 15 firms across the country.
Pallavi has had an outstanding career spanning the past 15years. During the past decade she has specialised in transfer pric-ing and international taxation, gaining a reputation across Indiafor her expertise in the field. She advises corporates, bothdomestic and foreign, helping them to fulfil their complex com-pliance requirements in India. In addition, she acts as a counsel,representing clients before quasi-judicial authorities and theIncome Tax Appellate Tribunal (ITAT) in India on mattersrelated to transfer pricing, dispute resolution, advance pricingarrangements and the avoidance of double taxation.
She has worked extensively with global businesses acrossAsia, the United States and Europe on advisory and transaction-al work, including a stint at a financial services company inZurich as an in-house counsel. She has combined her under-standing of finance and accounting with her expertise acrosscorporate and tax law to play a strategic role in high value trans-actions for her firm. Succession being mired with complexities,she advises large Indian business families, taking into account the aspirations of the new gen-eration joining the business, and helps with putting structures in place which not only pro-vide for smooth succession but are also tax efficient.
Pallavi has represented the Asian region as a board member on the international committeeof one of the leading global alliances of independent auditing, tax, accounting and consultingfirms. She is also an independent director on the board of a very large listed company.
Pallavi authored a best-seller ‘Transfer Pricing Demystified’ published by Bharat LawHouse in 2013, which was the first book on the practical issues related to transfer pricing inIndia. Pallavi is regularly invited to speak at tax conferences and at various chambers of com-merce such as the Federation of Indian Chambers of Commerce and Industry (FICCI) andthe Confederation of Indian Industry (CII). She has been part of the various tax committeesat the Institute of Chartered Accountants of India (ICAI) and has also spoken at numerousICAI events on complex tax issues. She is also a regular contributor to industry publications.
Pallavi graduated with distinction in commerce (Hons) from Lady Shriram College,University of Delhi. She is a fellow member of the Institute of Chartered Accountants ofIndia (ICAI). She also holds a law degree from the University of Delhi. She is a qualifiedInformation System Auditor (DISA) as well as an ICAI certified international tax expert.
India
Pallavi Dinodia
SR Dinodia & Co, CharteredAccountants
K-39 Connaught CircusNew Delhi – 110 001India
Tel: +91 – 011- 4370 3300Email:[email protected]: www.srdinodia.com
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Shefali Goradia is a partner with the firm’s corporate tax practice.She has more than 24 years of experience in international tax.
Shefali specialises in cross-border taxation. She advises multi-national corporations in designing global holding and operatingstructures, inbound and outbound investments, cross-bordermergers, acquisitions and other corporate reorganisations. Sheworks extensively with leading investment and private equityfund houses on developing and implementing domestic andinternational fund structures. She has advised banks in design-ing structured finance products. She advises several companiesin hospitality and pharmaceutical industries on taxation in India.She also advises IT companies on the taxability of software ande-commerce transactions. She has obtained private rulings forseveral clients.
Shefali is a regular writer and lecturer on international taxtopics. She had contributed the India chapter – ‘Is there a Permanent Establishment?’ – forthe 63rd IFA Congress held in Vancouver in 2009. She was also appointed as the co-gener-al reporter for the IFA Congress held in Mumbai, India in 2014 on the topic: ‘Cross-borderoutsourcing – issues, strategies and solutions’.
Shefali was voted as one of the region’s preeminent advisers for taxation in the 2011Asialaw Leading Lawyers survey. She featured in the Guide to the World’s Leading Banking,Finance and Transactional Lawyers 2012 as one of the outstanding practitioners in the fieldof investment funds and is also listed in The International Who’s Who of Corporate TaxLawyers and The International Who’s Who of Private Funds Lawyers consecutively from 2009-2014. She was recognised as among the eight best Indian tax advisers by The Legal 500 andthe Tax Directors Handbook 2009. Shefali represented India in Legal Media Group’s Guide tothe World’s Leading Tax Advisers and was recognised as among the top 10 tax advisers in Indiain World Tax (2004-2006).
India
Shefali Goradia
BMR & Associates LLP
BMR House36 B, Dr R K Shirodkar MargParel, Mumbai 400 012India
Tel: +91 22 6135 7170Fax: +91 22 6135 7070
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Malini is a senior member with the firm’s indirect tax practice inMumbai and specialises in indirect taxes such as service tax,VAT, excise and customs duties. She has also dealt extensivelywith related regulations such as the Foreign Trade Policy andthe special economic zone (SEZ) regulations. Malini has beenwith the firm since January 2005. Before joining the firm, sheworked in the tax and regulatory practices at Big 4 firms. Shealso worked in-house for three years with an internationalpower company and a leading India-based services company.
With more than 20 years of experience as an indirect tax spe-cialist, she has worked with companies across industries such asmanufacturing, power, IT/ITeS financial services, infrastruc-ture and retail. More specifically, she has been involved in advis-ing clients during various stages of their operations, includingset-up, capacity expansion, construction, ongoing operations and internal restructuring,among others. Her role has spanned the provision of advisory services, providing pre- andpost-litigation strategic advice including representing companies before tax and regulatoryauthorities, assisting in counterparty negotiations on tax matters and representing to the cen-tral and state governments on tax policy matters. She has worked with both domestic andinternational players on matters pertaining to all key indirect taxes in India.
Malini is a graduate in law from the National Law School of India University, Bangalore,and is also a member of the International Bar Association.
Malini is also part of the GST Working Committee of advisers constituted by theGovernment of Maharashtra.
India
Malini Mallikarjun
BMR & Associates LLP
BMR House36 B, Dr R K Shirodkar MargParel, Mumbai 400 012India
Tel: +91 22 6135 7025
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Rajeshree is a partner with BMR & Associates’s corporate taxpractice in Mumbai. With a specialisation in tax advisory andtransaction tax matters, she has more than 20 years of experi-ence in advising clients on their cross-border acquisitions andimplementing the India business strategy for multinationalsincluding implementing the integration strategy post-acquisi-tion. She has also advised multinationals including Fortune 500companies in the areas of tax and transfer pricing, and has assist-ed large Indian companies in implementing their transfer pric-ing across jurisdictions in the ITES sector. She works with someof the larger portfolio investors investing in India includingsome of the large institutional investors in managing their taxcompliance and litigation in India.
Rajeshree spent almost a decade with the tax practices of Big4 firms before joining BMR & Associates in October 2004 right from its inception and hascontinued to be a part of the core team since then.
Rajeshree is part of the Direct Taxation Committee with the Bombay Chamber ofCommerce where she is a co-chairperson. In this capacity, she has represented India businesshouses and multinationals on various tax issues before the Central Board of Direct Taxes.Rajeshree is also a member of the EU Chamber of Commerce. She is a qualified charteredaccountant and a company secretary.
India
Rajeshree Sabnavis
BMR & Associates LLP
BMR House36 B, Dr R K Shirodkar MargParel, Mumbai 400 012India
Tel: +91 22 61357050
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Nanda joined DHC as partner providing tax and regulatoryservices. DHC is an exclusive member firm of Baker TillyInternational.
Nanda’s previous experience is with a leading law firm,Amarchand & Mangaldas & Suresh A Shroff (AMSS), Mumbai.She was heading the tax practice of AMSS. She also has experi-ence of working at PwC, having worked in the firm’s Mumbaioffice for more than a decade.
Over the years, Nanda has developed substantial experiencewithin the field of corporate and international tax, focusing oncorporate tax and regulatory advisory services, business restruc-turing, including mergers and acquisitions. She also advisesclients with their tax litigation matters including strategising theapproach for large litigation matters. Her clients include Indiancompanies as well as multinationals, including Fortune 500companies.
With an experience of around 25 years, she strives for highclient satisfaction based on sound practical solutions, which areimplementable. Nanda is a qualified chartered accountant andholds a general law degree.
Nanda regularly contributes articles to tax publications andconducts conferences in the profession. She has also co-authored chapters on corporate andinternational tax topics.
India
Nanda Shah
Desai Haribhakti & Co.Chartered Accountants
701, Leela Business Park,Andheri-Kurla Road,Andheri (E), Mumbai – 400 059India
Tel: +91 22 6672 9999Direct: +91 22 6672 9833Mob: +91 9820331541Email: [email protected]: www.dhc.co.in
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India
Manisha GuptaDeloitte
Karishma PhatarphekarKPMG
Saloni RoyDeloitte
Parizad SirwallaKPMG
Krupa VenkateshDeloitte
Indonesia
Ay Tjhing PhanPwC
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Cliona is a partner with William Fry Tax Advisors, the Irishmember firm of Taxand. She is a key member of the firm’sForeign Direct Investment group. She advises multinational andcorporate clients on a wide range of issues. She focuses her prac-tice on the establishment of operations in Ireland, cross-bordertax planning, mergers and acquisitions, corporate tax compli-ance and international and domestic reorganisations, and repre-sents a number of the firm’s key clients.
Before joining William Fry Tax Advisors, Cliona started hercareer in KPMG training as a chartered accountant and a char-tered tax adviser. Cliona is a member of the Irish TaxationInstitute and is a fellow of the Institute of CharteredAccountants in Ireland. She is also a member of Taxand’sGlobal Knowledge Leaders group, ensuring that enhanced serv-ices are delivered to multinational clients. She is a frequent con-tributor to tax publications.
Cliona is ranked in the Chambers Global 2015 as a leadingindividual on corporate tax matters.
Ireland
Cliona Donnelly
William Fry Tax Advisors,Taxand Ireland
2 Grand Canal SquareDublin 2Ireland
Tel: +353 1 639 5280Email: cliona.donnelly@
williamfry.comWebsite: www.williamfry.com
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Sonya is a partner with William Fry Tax Advisors, the Irishmember firm of Taxand. She has more than 15 years’ experienceof advising clients across a range of sectors on tax issues includ-ing in the areas of inward investment, intellectual property (IP)and international tax structuring, corporate reorganisations, realestate transactions, and mergers and acquisitions. She advisesboth domestic and multinational corporations on Irish tax mat-ters including corporate tax, VAT and stamp duty. She is a keymember of the firm’s Foreign Direct Investment group.
Sonya is a member of the Law Society of Ireland and theIrish Tax Institute. She is also a director of the Irish branch ofthe International Fiscal Association. Sonya is a frequent speakeron tax topics and a contributor to tax publications. She is theco-author of the Irish chapter in the Miller Thompson publica-tion entitled ‘Tax Litigation, Jurisdictional Comparisons’ (FirstEdition 2013).
Sonya is ranked in the Chambers Global 2015 as a leadingindividual on corporate tax matters.
Ireland
Sonya Manzor
William Fry Tax Advisors,Taxand Ireland
2 Grand Canal SquareDublin 2Ireland
Tel: +353 1 639 5212Email:[email protected]: www.williamfry.com
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Ireland
Catherine GalvinMatheson
Lorraine GriffinDeloitte
Louise KellyDeloitte
Susan KiltyPwC
Joan O’ConnorDeloitte
Catherine O’MearaMatheson
Deirdre PowerDeloitte
Renata SlobodovaPwC
Joanne WhelanDeloitte
Italy
Fulvia AstolfiHogan Lovells
Maria Antonietta BiscozziEY
Paola CamagniStudio Camagni e Associati
Aurelia CasaliDLA Piper
Silvia ConfalonieriEY
Alessandra Di SalvoDeloitte
Barbara FainiBaker & McKenzie
Laura GualtieriTremonti Vitali Romagnoli Piccardi e Associati
Nicoletta MazzitelliEY
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Italy
Maricla PennesiBaker & McKenzie
Cristina PeritiStudio Fantozzi & Associati
Vania PetrellaCleary Gottlieb Steen & Hamilton
Giuliana PolaccoBaker & McKenzie
Barbara RossiDeloitte
Chiara TomassettiDeloitte
Monica ZafferaniDeloitte
Latvia
Marina BickovskaBDO Tax
Vita LiberteVarul
Lithuania
Vita SumskaiteKPMG
Jurate ZarankieneTax Link Baltic
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“Like balloons, human beings have to change altitude if theywish to change direction in the winds of life.”
Bertrand Piccard
As Valérie Tollet’s career has soared to new heights, this quote hasguided her personal philosophy. As a partner in DeloitteLuxembourg’s Cross-Border Tax-Mergers & Acquisitionsdepartment, she has also helped others – clients as well as herteam and colleagues – to “change altitude” over the past 14 years.
She is experienced in structuring deals for both listed andprivate clients, and particularly for pan-European and interna-tional real estate and infrastructure funds. She assisted manyinvestors in establishing their real estate vehicles in Luxembourg– both regulated and non-regulated – and advised on severalreal estate acquisitions in Europe. Before joining Deloitte inOctober 2012, Valérie worked with PwC both in Brussels andLuxembourg.
Not only is Valérie a highly recognised tax leader in realestate, but she is also reputed for her strong skills in many tax fields, including private wealthmanagement, private equity, financial services industry, infrastructure, and corporate tax.Valérie is an active member of several ALFI (Association of Luxembourg Fund Industry) RealEstate Investment Funds working groups.
Valérie is someone who truly inspires the next generation of women and men. Within herteam and the 350 professionals in the tax department, she has created a team spirit, fosteringinnovation and positive competitiveness. She is an active member of the Deloitte DiversityInitiative and acts as the human resources lead for the M&A department.
When she joined Deloitte Luxembourg, she had an ambitious aim: for the real estate taxdepartment to reach 15% growth each year. Fast forward three years: she succeeded in meet-ing this goal. Thanks to her interpersonal skills, in-depth understanding of clients and theirindustries, pragmatism, and sense of humour, she is a trusted adviser to her clients and aleader to her team. She continually builds these relationships to help Deloitte Luxembourgand her clients “change altitude” and soar to greater heights year-on-year.
Luxembourg
Valerie Tollet
Deloitte
560, rue de NeudorfL-2220 Luxembourg
Tel: +352 451 45 2252Email: [email protected]: www.deloitte.lu
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Malaysia
Theresa GohDeloitte
Adeline WongWong & Partners (Baker & McKenzie member firm)
Poh Geng WongDeloitte
Irene YongShearn Delamore
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Malta continues to position itself as a viable and attractive des-tination for business and investment, in part by virtue of itscompetitive tax regime. The chargeable income of a Maltesecompany – which includes its taxable income and capital gains –is taxed at 35%.
A number of entities, if structured appropriately, may beexempt from tax, including: • cooperative societies; • certain collective investment schemes; • most retirement funds or retirement schemes; and • organisations of a public character.
A company incorporated in Malta is treated as domiciled andresident in Malta, and is subject to tax on its worldwide incomeand capital gains. A company that is not incorporated in Malta isresident in Malta if its management and control are exercised inMalta. The test of management and control is usually applied byreference to the place where the shareholder and director meetingsare held and where the company’s important decisions are made.
Like other taxpayers, a company that is resident but notdomiciled in Malta is subject to tax on chargeable income andcapital gains arising in Malta and on chargeable income arisingoutside Malta and remitted to Malta, but not on capital gainsarising outside Malta that are received in Malta. That a foreigncompany has a branch in Malta does not, in itself, constitute res-idency. A company that is neither resident nor domiciled inMalta is taxable on chargeable income and capital gains arisingin Malta, unless such income and gains are subject to a specificexemption.
Despite the default 35% corporate tax rate, as a result ofMalta’s full imputation and tax refund system, the effective taxrate in Malta may be reduced to 5%.
Malta
Kirsten CassarCamilleri Preziosi
Introduction to Malta’scorporate income tax regime
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Malta
Full imputation system Although any shareholder of a Maltese company is, in principle, subject to tax in Malta onany dividends derived from such company, any economic double taxation is relieved throughthe operation of a full imputation system of taxation. Consequently, the tax paid by theMaltese company on the profits that it distributes as a dividend in favour of its shareholder iscredited in full against the Malta tax liability of that shareholder.
The 35% default tax rate applicable to companies is equivalent to the maximum progres-sive rate of tax applicable to individuals. Therefore, a dividend distribution received by eithera corporate or a natural shareholder (resident in Malta or otherwise) would typically result inno further tax payable at the level of the shareholder. In fact, a shareholder that is subject totax at a rate lower than 35% may claim a refund of the excess tax paid in Malta at the level ofthe company. Many states recognise the fact that Malta is one of the few remaining countriesto operate a full imputation system. Consequently, most of Malta’s tax treaties effectivelyenable Malta to continue to operate its full imputation system in a cross-border context.
Tax refund system Over time, Malta has developed its imputation system to allow for a tax refund mechanismapplicable at the level of the shareholders. A shareholder in receipt of dividends distributedout of certain profits of a Maltese company can claim a refund of the tax paid in Malta bysuch company on those profits.
The amount of the refund to which the shareholder is entitled depends on: • the nature of the underlying profits out of which the dividend is distributed by the com-
pany; and • the claiming of double taxation relief by the company on such profits.
In most cases, the refund entitlement of a shareholder would be six-sevenths of the Maltatax suffered by the Maltese company on the profits out of which the dividend is distributed.
However, this rate may be reduced in the following circumstances: • Where the profits out of which a dividend is distributed consist of passive interest or roy-
alties, the refund is reduced to five-sevenths of the Malta tax suffered on those profits. • A tax refund at the rate of two-thirds of the Malta tax applies to dividends distributed out
of certain profits in respect of which the distributing company has claimed a foreign taxcredit to relieve cross-border double taxation. On the other hand, a company in receipt of dividends (or gains) derived from an invest-
ment that qualifies as a participating holding may either: a) elect to apply the participation exemption, in which case such income (or gains) will be
exempt from Malta tax; or b) include such income (or gains) as part of the taxable income of the Maltese company,
which would entitle its shareholder in receipt of a dividend out of those profits to a fullrefund of the Malta tax paid by the company on that income (or gains). No such tax refunds as those referred to above can be claimed in connection with income
derived, directly or indirectly, from immovable property situated in Malta. In addition, incertain situations – for example, where the Maltese company is beneficially owned by Maltaresident and domiciled individuals – income derived by said company on which tax refundsare claimed requires reclassification as investment income and is taxable accordingly.
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Double-tier structures While this is not required, due to the fact that any shareholder is entitled to claim tax refunds,a double-tier structure may have a number of advantages for the taxpayer, such as postpon-ing dividend payments to non-residents, thereby deferring any foreign tax charges withoutincurring any further tax in Malta.
In certain jurisdictions it may also be beneficial to use a double-tier structure to ensurethat the total income (including any tax refund) being received by the non-resident share-holder is received in the form of a dividend, which may be taxed more favourably (for exam-ple, exempt where a participation exemption regime is in place) in its country of residencethan any tax refund. Moreover, no withholding taxes are levied on distribution of the divi-dends or payment of interest and royalties to non-resident shareholders. There are also notaxes or restrictions on export of the dividends from the Maltese company.
Malta
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Dr Kirsten Cassar is an associate forming part of the corporateand finance practice group at Camilleri Preziosi.
Kirsten graduated as Doctor of Laws from the University ofMalta after submitting a thesis on the ‘Developments to Article 7of the OECD Model Tax Treaty and Commentary in light of theOECD 2010 Report on the Attribution of Profits to PermanentEstablishments’. Shortly after, Kirsten embarked on an LLM incorporate and securities law at the University of London.
Kirsten practises in the areas of direct and indirect tax mat-ters, primarily in the provision of domestic and international taxadvisory and tax restructuring services, including providingadvice particularly in the remit of identifying implications of,and devising tax efficient structures for, local as well as cross-border transactions.
Kirsten also regularly assists in advising clients on the corpo-rate law aspects of a wide range of transactions and other areasincluding corporate finance, M&A and capital markets. Thisprovides clients with comprehensive insight on a wide range ofmatters which might have an impact on any particular transac-tion whether strictly related to the fiscal implications of a trans-action or otherwise.
Malta
Kirsten Cassar
Camilleri Preziosi
Level 3, Valletta BuildingsSouth StreetValletta, VLT 1103Malta
Tel: +356 2567 8117Email: kirsten.cassar@
camilleripreziosi.comWebsite:www.camilleripreziosi.com
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Roxana M Gomez-Orta has 20 years of professional experienceand is a member of Baker & McKenzie’s tax practice groupwhich has been recognised as a highly recommended global taxpractice by Chambers Global 2014 and as a recommended taxpractice in Mexico by Chambers Latin America andInternational Tax Review.
She joined the firm in 2001, and was appointed nationalpartner of Baker & McKenzie Abogados in July 2007.
Roxana focuses her practice on tax, administrative and con-stitutional matters. She has advised multinational and local com-panies in connection withtax planning, matters involving unduecollections of contributions by the tax and administrativeauthorities, and tax litigation.
She has published articles in Defensa Fiscal, IDC AsesorJurídico y Fiscal, Puntos Finos, Players, Práctica Fiscal,Corporate Business Taxation Monthly, Maquila Reynosa,Periódico El Norte, Periódico Milenio, Inter-American TradeReport and Tax Notes International, among others.
Roxana has been named one of the leading tax lawyers inMexico by the magazine Defensa Fiscal in consecutive yearsfrom 2007, and as a tax controversy leader by International TaxReview 2014. She is a member of the Academia de Derecho Fiscal de Nuevo León, AC,Chapter Nuevo León and was appointed as member of the board, acting as the treasurer dur-ing 2008-2009. For 2015-2016, she is serving as an advisory member of the board.
She obtained a law degree from the Universidad de Monterrey in 1996 and further obtaineda master’s degree in tax law from the Universidad Autonoma de Nuevo Leon in 2001.
Roxana speaks both English and Spanish.
Mexico
Roxana Gomez-Orta
Baker & McKenzie
Oficinas en el ParqueTorre Baker & McKenzie Piso 10Blvd Antonio L Rodriguez 1884 PteMonterrey, NL 64650Mexico
Tel: + 52 81 8399 1308Email: roxana.gomez-orta@
bakermckenzie.comWebsite: www.bakermckenzie.com
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Cecilia Montaño is a Deloitte Mexico indirect tax partner andMexican and Latin American service line leader, specialised inforeign trade, customs and indirect tax. She has more than 18years of experience in foreign trade. Cecilia became a DeloitteMexico partner in 2008.
Before joining Deloitte, Cecilia spent several years as a logis-tics and customs compliance manager in the private sector.
Cecilia helps multinational companies identify indirect taxopportunities and has worked with clients around the world onprojects involving due diligence, customs audits and tax strate-gies relative to investments in Mexico, among others.
Cecilia has extensive experience in compliance consulting.She works with clients operating across many industries includ-ing the automotive, pharmaceutical, oil and gas, mining, ener-gy and manufacturing sectors, among others.
She received a bachelor’s degree in foreign trade and cus-toms from the Instituto Teconólogico de Monterrey, and is aboutto conclude a master’s in business administration, with a foreigntrade specialisation, from the same institution.
Cecilia is vice president of the Mexican Importers and Exporters Association (ANIERM),vice president of the Logistics & Customs committee at the Mexican Trade Council(COMCE), and is also an adviser for the National Maquiladora Council (INDEX) and par-ticipates as an active member of the most relevant associations in Mexico related to foreigntrade and customs.
She has a strong relationship with the Mexican government in topics related to foreigntrade and customs and regularly participates strategically with the authorities on relevantprojects.
Mexico
Cecilia Montaño
Deloitte Mexico
489, P 6 Col. Cuauhtémoc6501 Mexico CityMexico
Tel: +52 55 50 80 64 19Email: cmontanohernandez@
deloittemx.comWebsite: www.deloitte.com
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Mexico
Karina Perez DelgadilloPwC
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Suzanne den Breems is a principal in Ryan’s Amsterdam officeand practice leader for European VAT, managing all aspects ofthe firm’s European VAT practice. Suzanne specialises in repre-senting and advocating for global Fortune 500 clients across awide spectrum of industries on various VAT aspects.
Suzanne has played an instrumental role in building Ryan’sEuropean VAT Recovery and Consultancy practice. Founded in2011, the practice has since grown to more than 40 employees,centrally located throughout Europe.
Previously, Suzanne was co-founder and partner of a Dutchtax law firm that specialised in VAT and real estate transfer tax.She was also a manager for an international accounting and taxlaw firm. In the public sector, she served as an officer in theMunicipal Legal Advice Centre.
Suzanne lectures on various tax topics for Ryan clients andthe Ryan Professional Development Programme. Additionally,she is a frequent speaker for the International Air TransportAssociation.
Suzanne was chief editor of the monthly tax law magazine,Fiskaal. She has also written various articles published in theInternational Tax Review and co-authored the Kluwer VATMemo from 2002–2005.
Suzanne holds a master of laws (LLM) degree, with an emphasis in indirect tax law, fromthe University of Leiden and a post-university degree from the Dutch Order of Academic TaxAdvisors, and is accredited in tax assurance from Nyenrode Business University. She is also amember of the Dutch Association of Academic Tax Advisors.
Netherlands
Suzanne den Breems
Ryan
World Trade Center AmsterdamTower G, Level 6Strawinskylaan 6851077 XX AmsterdamNetherlands
Tel: +31 (0) 20 570 3520Fax: +31 (0) 20 570 3525 Email:[email protected] Website: www.ryan.com
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Netherlands
Mounia BenabdallahBaker & McKenzie
Milja Bormann-BakkerDeloitte
Juliana DantasBaker & McKenzie
Marja de BestLoyens & Loeff
Margreet NijhofBaker & McKenzie
Trudy PerieLoyens & Loeff
Agata UcedaKPMG
Monique van HerksenEY
Annet van VeldhuizenPwC
New Zealand
Kirsty KeatingEY
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Norwegian authorities have for a number of years enforced apractice implying that net salary shall be grossed up in accor-dance with Norwegian tax rates, regardless of the tax amountactually paid in countries outside of Norway. Given that theemployee is on an assignment in a country where there is notax on income, or where the income tax is lower than inNorway, the taxation of the employee is based on a hypothet-ical benefit. Consequently, costs for the employer are higher both on the
total tax liability and potentially higher for calculating social secu-rity contributions both for the employer and for the employee. The question has been tried both in lower and higher courts
and in both cases the court ruled in the government’s favour.The question, as such, is of principal character and it may beappealed to the Supreme Court.
Legal basis The Ministry of Finance has clearly stated that the net salaryagreement is a taxable benefit and is considered gained alreadywhen the contract between the employer and employee issigned. The benefit is considered taxable on accrued basis whenthe net salary is paid.The tax authorities’ view is that the employer in Norway is
obliged to calculate the correct gross salary as if the employeewas working in Norway. One argument given is that the term‘net salary’ is not defined in the legislation and that Norwegiantax principles and rates must therefore apply. Avoidance of dou-ble taxation is ensured either under reference to the applicabletax treaty or Norwegian domestic law. The lower and higher court expressed significant doubt
with regard to correct interpretation of the law, but ultimately
Norway
Cathrine Bjerke DalheimKPMG Norway
Method for gross up of netsalary for cross-borderemployees
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Norway
concluded that it shall be the responsibility of the legislators to clarify in law or secondarylaw if the practice is unreasonable. Our opinion is that this is incorrect. As a starting point, there is not a clear legal basis to
deviate from the rule and principle that the taxable basis is an actual benefit given from theemployer, either as a cash salary or as benefits in kind. The principle of legality, general taxprinciples and de lege ferenda considerations weigh considerably against the lawfulness of theadministrative practice followed by Norwegian tax authorities.
Practical consequencesInstead of including the actual paid taxes in the host country and accruing this to the pointof payment in accordance with the cash basis, Norwegian authorities require that the netsalary is grossed up in accordance with Norwegian tax rates in advance of any actual tax pay-ments. The marginal tax rate in Norway is 47.2% (including employee social security rate of8.2%) and the employer social security rate is 14.1%. As an example, a Norwegian employee on assignment in Dubai, where there is no tax on
salary income, will not pay any tax on the salary income in Norway given that he fulfills cer-tain criteria. Social security contributions must, however, be paid. In a case like this, the con-sequence for the Norwegian tax authorities view will be as follows:
Income Employer soc sec Employee soc sec Total$250,000 (net) 35,250 20,500 55,750$472,000 (grossed up) 66,552 38,704 105,256
The difference in payable social security amounts is $49,500.
Cost saving opportunitiesAs the current administrative practice is supported by two court cases, the latest ruled July 62015, it is not an option to deviate from the practice and guidelines given by the Norwegiantax authorities. However, it is important to emphasise that the employers social security con-tribution may be avoided if the payroll is placed outside of Norway and the employee is nota member of the Norwegian social security scheme.
Litigation set to continueAs the current situation in many contexts implies unreasonable and unnecessary costs for theemployer, it is important to review the companies’ tax policy in cases where the employer hasa significant number of assignees from Norway to other countries, especially if the assigneeswork in countries with significantly lower tax rates than in Norway. The higher court decision is not legally binding, as the deadline for appeal has not yet
expired. It remains uncertain at this point if the case will be appealed and, if appealed,whether it will be approved for a Supreme Court decision. Due to the principle character ofthe question and the doubt expressed in the previous courts, we believe it is likely that thecase will be approved for entry if appealed.
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Cathrine Bjerke Dalheim is an attorney-at-law. She is a partnerin KPMG Law Advokatfirma and head of global mobility serv-ices in Norway. She has more than 17 years of experience withcross-border employments. She has worked with global mobili-ty since 1998. She started working for KPMG in 2000 and, before this, she
worked at Norsk Hydro, corporate expatriate services. The global mobility services team is specialised in advising
employers and employees on global mobility, cross-border busi-ness trips and short-term and long-term secondments. Her fieldof expertise covers international tax and social security planning,cost projection, strategic HR and policy advice, employmentlaw, and pension and insurance related topics. Cathrine has substantial experience in advising multinational
corporations, headquartered both inside and outside ofNorway, on international tax matters. Through her deep andvaried experience with strategic global mobility, she also hasknowledge within corporate tax, transfer pricing and VAT,enabling her to evaluate risk exposure under the differentemployment structures. Since 2004, she has built a separate service, specialised in
assisting foreign companies with temporary business activities in Norway and the servicescomprise of handling all employers’ obligations such as payroll, registration of employees,immigration, corporate tax compliance, VAT representation and so on. During her years in KPMG, she has covered different roles, such as head of markets for
the firm, COB for the law firm and being a member of the Executive Committee. Cathrine is admitted to practise before the courts in Norway.
Norway
Cathrine Bjerke Dalheim
KPMG Huset /KPMG Law Advokatfirma
Sørkedalsveien 60306 Oslo Norway
Tel: +47 4063 9055Email:[email protected]: www.kpmg.com/no
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Tonje Christin Norrvall is attorney-at-law and partner in KPMGLaw Advokatfirma, as well as taking the lead on internationalprivate clients (IPC). Tonje has more than 27 years of experience with tax and
global mobility, starting as consultant and group leader with theNorwegian tax authorities, as tax manager with Norske Shelland, since 2003, tax partner at KPMG in Norway. Tonje has substantial experience in advising multinational
corporations on international tax and social security aspects, aswell as in executive remuneration planning and preparation ofincentive plans. She also gives advisory services to high networth individuals. Tonje assists clients in concluding non-bind-ing advice agreements with the Norwegian tax authorities withrespect to share transactions. Tonje has vast experience as the lead partner on numerous
global engagements. She is also an experienced speaker and aboard member of KPMG. Tonje is admitted to practice before the courts in Norway.
Norway
Tonje Christin Norrvall
KPMG Law Advokatfirma
Sørkedalsveien 60306 Oslo Norway
Tel: +47 4063 9223Email: [email protected]
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Norway
Hanne Skaarberg HolenArntzen de Besche
Philippines
Maria Carmela PeraltaRG Manabat (KPMG)
Benedicta Du-Baladad Du-BaladadDu-Baladad
Poland
Aneta Blazejewska-GaczynskaEY
Dominika CabajDLA Piper
Renata DluskaMDDP
Kalina Figurska-RudnickaMDDP
Karina Furga-DabrowskaDentons
Iwona GeorgijewDeloitte
Karolina GizickaEY
Aneta GniewkiewiczPaczuski & Taudul Tax Advisors
Patrycja GozdiowskaSSW (Spaczynski, Szczepaniak i Wspolnicy)
Katarzyna JanikIndependent
Katarzyna Klimkiewicz-DeplanoAdvicero/Green Real Accounting
Sylwia MigdalEY
Dorota PokropEY
Monika PoterajDLA Piper
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Poland
Elzbieta SerwinskaMDDP
Ewelina Stamblewska-UrbaniakCrido - Taxand
Joanna StawowskaDeloitte
Marta SzafarowskaMDDP
Agnieszka TalasiewiczEY
Portugal
Rose AreiasPwC
Catarina BelimVieira de Almeida
Serena Cabrita NetoPLMJ
Carla Castelo TrindadeIndependent
Clotilde Celorico PalmaEduardo Paz Ferreira
Rita ChambelVieira de Almeida
Susana ClaroPwC
Maria CravoBTOC Tax
Tania de Almeida FerreiraCuatrecasas Goncalves Pereira
Claudia Reis DuarteUría Menéndez
Raquel FernandesCMS Rui Pena & Arnaut
Conceicao GamitoVieira de Almeida
Maria Ines AssisPLMJ
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Portugal
Marta Machado de AlmeidaRogerio Fernandes Ferreira & Associados (RFF)
Rita MagalhaesVieira de Almeida
Alexandra MartinsKPMG
Catarina MatosEY
Patricia MatosDeloitte
Joana Nunes dos ReisDeloitte
Tania PereiraIndependent
Marta PontesUría Menéndez
Monica Santos CostaEY
Teresa Teixeira MotaVieira de Almeida
Maria TorresPwC
Isabel Vieira dos ReisGarrigues - Taxand
Romania
Angela RoscaTaxHouse Taxand Romania
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Russia
Raisa AlexakhinaDeloitte
Irina DmitrievaWhite & Case
Elena Dremova (Puginskaya)PwC
Maria KostenkoBaker & McKenzie
Natalia KuznetsovaPwC
Ekaterina LazorinaPwC
Alexandra LobovaEY
Ekaterina MalyginaPwC
Maria MikhaylovaPwC
Galina NaumenkoPwC
Irina PaninaKPMG
Yana ProskurinaPwC
Natalia VozianovaPwC
Anna ZverevaDentons
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Felicia is a director in KPMG’s Transfer Pricing practice and theFinancial Services Transfer Pricing lead in Singapore.She has extensive experience in providing transfer pricing
advisory services to multinational corporations across a multi-tude of industries in Singapore, the United States and the AsiaPacific region. Felicia has advised her clients on transfer pricingplanning and documentation projects to determine properarm’s-length compensation for tangible property, intangiblesand intercompany services. She has also assisted in the prepara-tion of cost allocation studies for global/regional headquartersand was involved in audit defence assistance and transfer pricingrisk analyses. In addition, Felicia has been involved in the negotiation and
implementation of unilateral and bilateral advance pricingarrangements (APAs) and mutual agreement procedures(MAPs). She has led several value chain management projectsand advised clients on complying with the OECD-BEPS guid-ance. Felicia is a regular speaker on global transfer pricing atclient seminars and published a number of articles on transferpricing issues.She holds a bachelor’s degree in law and a bachelor’s of commerce (double major in
accounting and finance) from the University of Western Australia, and is an accredited taxpractitioner with the Singapore Institute of Accredited Tax Professionals.
Singapore
Felicia Chia
KPMG in Singapore
16 Raffles Quay#22-00 Hong Leong BuildingSingapore 048581
Tel: +65 6213 2525Fax: +65 6220 9419Email: [email protected]: www.kpmg.com.sg
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Hwee Leng is a partner of the Indirect Tax practice and has sub-stantial experience in GST-related matters both as a regulatorand a business adviser. She has assisted businesses in respondingto audit queries from the Inland Revenue Authority ofSingapore (IRAS), in seeking tax rulings and advising on taxand penalties risk management. Hwee Leng has also beenactively involved in advisory, compliance work, reviews and liti-gation support for various industry sectors.Before joining KPMG, Hwee Leng was a senior tax officer
with the IRAS for 15 years. She was involved in tax policy mat-ters on GST, corporate tax, advance income tax ruling, interna-tional taxation, transfer pricing and tax treaties. In IRAS, HweeLeng was part of the GST implementation team that drafted thecirculars on the laws, regulations and GST guidelines for busi-nesses and the public. She is also involved in the audit of GST-registered businesses, setting up of GST policy, fine-tuning theGST system and overseeing amendments of GST laws, imple-mentation of the GST rate increase in Singapore and conduct-ing trainings on GST.In her current role, Hwee Leng serves as a GST Assisted
Self-help Kit (or ASK – introduced by the IRAS as a self-assess-ment package designed to help GST-registered businesses effectively manage their compli-ance) reviewer and indirect tax adviser for public, multinational and local organisations. Sheis a frequent speaker at GST seminars for clients and the public, and a training instructor withthe Singapore Institute of Accredited Tax Professionals.Hwee Leng is also a regular contributor to the International Tax Review (ITR) and
KPMG International’s indirect tax publications. She is also one of the contributors for‘Goods and Services Tax – Law & Practice’, which provides practical advice on the adminis-trative and compliance aspects of GST in Singapore. For the past two years, including thisyear, ITR has recognised Hwee Leng as a leading indirect tax adviser in Singapore.She has a bachelor’s degree in accountancy (second honours) from the National
University of Singapore and a master’s in public administration/international tax programmefrom Harvard University. Hwee Leng is also a fellow of the Institute of CharteredAccountants in England and Wales.
Singapore
Gan Hwee Leng
KPMG in Singapore
16 Raffles Quay#22-00 Hong Leong BuildingSingapore 048581
Tel: +65 6213 2813Fax: +65 6220 9419Email:[email protected]: www.kpmg.com.sg
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Singapore
Nicole FungPwC
Ken Loon OngDrew and Napier
Dawn QuekBaker & McKenzie.Wong & Leow
Chai Sui FunPwC
South Africa
Julia BoltarGroup 621
Christel BritsEY
Cinzia de RisiEY
Roula HadjipaschalisKPMG
Nazrien KaderDeloitte
Anthea ScholtzDeloitte
Annemarie SchroederDeloitte
Virusha SubbanBowman Gilfillan
Yasmeen SulimanKPMG
Natasha VaidanisKPMG
Suzanne van der MerweDeloitte
Louise VoslooDeloitte
Patricia WilliamsOn Your Side
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Spain
Maria Antonia AzpeitiaBaker & McKenzie
Isabel Lopez-BustamanteDeloitte
Belen Palaobln palao abogados
Natalia PastorKPMG
Alejandra PuigDeloitte
Ana RoyuelaBaker & McKenzie
Montserrat TrapeKPMG
Sonia VelascoCuatrecasas Goncalves Pereira
Esther Zamarriego SantiagoGarrigues - Taxand
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Ulrika is a partner at Svalner Skatt & Transaktion, and is one ofthe leading indirect tax advisers in Sweden. For more than 15years she has advised Swedish and foreign companies, fromsmall to listed companies in a wide range of business sectors.Ulrika’s main focus areas are telecom, energy, retail, automo-tive, health care, transportation and cargo handling, pharma-ceutical and public service. Ulrika is often engaged to assist inlobbying and preparation of draft laws.Another main focus area is litigation. Ulrika is advising and
representing clients in litigations mainly within the area of indi-rect tax. Ulrika is also regularly enlisted as a lecturer at conferences
and seminars.Before joining Svalner Skatt & Transaktion, Ulrika’s previ-
ous roles included a stint as a tax lawyer at Ernst & Young, aswell as at the Swedish Tax Agency and District Court.Ulrika holds an LLM from Uppsala University. She speaks
(and works in) both Swedish and English and has publishedarticles in various publications.
Sweden
Ulrika Grefberg
Svalner Skatt & Transaktion
Smålandsgatan 16111 46 StockholmSweden
Tel: +46 8 528 01 275Fax: +46 8 528 01 260Mobile: +46 76 899 69 10Email:[email protected]: www.svalner.se
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Ylva Hestréus is on the indirect tax team at Deloitte Sweden.She has worked with VAT matters for more than 20 years,including 11 years with the Swedish Tax Agency. Her work withthe Tax Agency included five years as a legal expert focusing onthe financial sector.For the last 12 years, Ylva has worked as a VAT adviser with
continued focus on clients within the financial sector. She is alsoresponsible for Deloitte Sweden’s VAT/financial services indus-try team. Ylva is a trusted adviser for many large companies inthe financial sector and gives advice to medium and large com-panies relative to complex VAT matters, correspondence withthe Tax Agency and so on. Ylva has also worked with VAT issuesfor Swedish and international companies in connection with theacquisitions of groups in Sweden. She is a frequent lecturer atVAT seminars and has authored several articles on VAT. Ylva earned a master’s degree in law from the University of
Stockholm in 1992 and is certified as a tax adviser by FAR, theinstitute for authorised accountancy professions in Sweden. Ylvais also a board member in policy matters of taxation for FAR.
Sweden
Ylva Hestréus
Deloitte Sweden
Rehnsgatan 11SE-113 79 StockholmSweden
Tel: +46 752 46 26 87Email: [email protected]: www.deloitte.se
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Monica joined Grant Thornton Sweden in August 2009 as headof tax.Monica’s previous in-house experience is with IKEA Services
as global head of tax, as well as having held advisory positionswith KPMG and Arthur Andersen/Deloitte. She also has expe-rience of working as an official at the Swedish Tax Agency.In the profession Monica has developed substantial expertise
within the field of corporate and international taxation focusingon inward investments, restructuring and mergers and acquisi-tions.Today, Monica primarily focuses on leading the Swedish tax
practice, which comprises more than 75 tax consultants dealingin all areas of domestic and international taxation.Monica strives for high client satisfaction based on pragmat-
ic and commercial tax advice.Monica is a member of the council of the tax department at
FAR, the institute for the accounting profession in Sweden, aswell as FAR’s tax authorisation committee.
Sweden
Monica Söderlund
Grant Thornton
Sveavägen 20 PO Box 7623 Stockholm, SE-103 94Sweden
Tel: +46 (0)7068 700 02Email:[email protected]: www.grantthornton.se
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Sweden
Mylene BeimingPwC
Lina EngmanSkeppsbron Skatt - Taxand Sweden
Susann LundstromKPMG
Tina ZetterlandKPMG
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Inspired by KPMG’s multidisciplinary approach, Elizabethrecently joined KPMG to lead the firm’s indirect tax practice inWestern Switzerland. At KPMG, Elizabeth works with multinational and national
clients in all sectors with a special focus on energy and commod-ity trading. She works closely with her clients to develop theirglobal Indirect tax strategy taking into account their organisa-tional and supply chain structure and manages their VAT on aglobal basis. She focuses on value creation specifically in the eraof Big Data, an area in which she helps clients transform theirtrade data into value. Elizabeth holds a master’s degree infinance and is an AITI chartered tax adviser (CTA) and associ-ate of the Irish Taxation Institute.Originally, Elizabeth started her career at Ernst & Young in
Beirut as a tax consultant while she was still at university. In2001, she was seconded to Ernst & Young in Dublin where sheworked for nine years. During her career at Ernst & Young,Elizabeth worked for many different clients and industrieswhich contributed to the development of her experience ininternational indirect tax. While in Dublin, in addition to theCTA, she also completed a diploma in investment fund services to better understand theinvestment fund clients she was serving at that time. In 2010, Elizabeth decided to move toGeneva Switzerland as an international VAT manager at PwC, and quickly rose through theranks as a result of her capabilities, hard work and determination. Elizabeth’s international experience helps her understand different cultures and how to
deal with people with different backgrounds. In addition to this, she speaks English, French,Arabic, Armenian and a little Dutch as she is married to a Dutchman.
Switzerland
Elizabeth Barendregt
KPMG
Rue de Lyon 111PO Box 347CH-1211 Geneva 13Switzerland
Tel: +41 58 249 65 02Email: [email protected]: www.kpmg.com
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Switzerland
Marieke BakkerLoyens & Loeff
Maja Bauer-BalmelliTax Advisors & Associates
Sarah DahindenPwC
Nicole Fragniere MeyerGillioz Dorsaz & Associes
Barbara HenzenEY
Michaela MerzPwC
Britta RehfischADB
Corinne ScagnetDeloitte
Taiwan
Sophie ChouEY
Josephine PengLee and Li
Glendy YuanDeloitte
Tunisia
Sonia LouzirDeloitte
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Guler Hülya Yilmaz is a sworn certified financial consultant wholeads the cross-border tax service line and has been responsiblefor the transfer pricing (TP) service line in the Turkish tax prac-tice since June 2006. She started her career as an independentauditor in the audit department of the former Arthur Andersenin 1989 after her graduation from university. Hülya has spe-cialised in international tax consultancy services since she beganher career at Deloitte in 1993 after her post-graduate studies.She has significant experience in tax consultancy and tax plan-ning that involves transfer pricing, legal and international taxaspects. She has also been actively involved in tax structuring formajor M&A projects in Turkey.Hülya became a tax partner in Deloitte Turkey’s tax practice
on June 1 2006 (as the first female tax partner within the Big 4in Turkey). She is also the country leader for the life science andhealthcare industry and is the Tax Learning Leader in DeloitteTurkey. She also has significant experience in serving multination-al firms in the energy sector. She advises multinational clients intax matters related to permanent establishment issues, applicationof tax treaties, restructuring, tax and TP related tax audit cases. Her transfer pricing work covers TP documentation and
planning projects across various sectors; cost allocation analysis and cost-sharing agreements;tax analysis of IP transfer or migration plans; TP audit defence; unilateral APA applications;TP analysis of contract R&D applications; and comparative analysis of the treatment of relat-ed party transactions in the New Turkish Commercial Code versus the Turkish CapitalMarket Law, considering the underlying TP implications. Hülya is experienced in tax modeling and consultancy for energy project companies operat-
ing under the financing models of ‘build-operate-transfer’ (BOT) and ‘transfer of operationrights’ (TOR). She provides transfer pricing consultancy regarding unbundling transactions inthe energy industry (generation, transmission, distribution, shared services and so on) underalternative tax structures. Hülya also provides TP documentation studies for the trading of spe-cific materials in the mining sector (used in power generation) between related parties. She alsohas experience in income and profit attribution in relation to ‘turnkey projects’.Hülya speaks English and Turkish and has working knowledge of French. She holds a
bachelor of arts degree in business administration from Marmara University and a master’sdegree in business administration from the Bogazici University.She is a sworn financial consultant; a member of the Istanbul Chamber of Sworn Financial
Consultants; a member of the Turkish branch of IFA; a member of the Association of ForeignInvestors in Turkey (YASED) working group on life sciences and healthcare; and a memberof the healthcare committee in the American Business Forum in Turkey, part of the AmericanChamber of Commerce (AmCham) Turkey.
Turkey
Güler Hülya Yılmaz
Deloitte
Deloitte Values HouseMaslak Mahallesi, Eski BüyükdereCad. No:1Maslak No 1 Plaza34398, Maslak – Sarıyer, IstanbulTurkey
Tel: +90 212 366 60 72Mobile: +90 533 275 70 03Email: [email protected] Website: www.deloitte.com
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Turkey
Duygu GultekinBaker & McKenzie
Uluc OzcanErdikler - Taxand
Guler Hulya YilmazDeloitte
Ukraine
Victoria ChornovolDeloitte
Viktoria FomenkoDentons
Vita ForsiukJurimex
Iryna MarushkoLavrynovych & Partners
Svitlana MusienkoDLA Piper
Tatiana ZamorskaKPMG
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Roopa Aitken is a corporate tax partner at Grant Thornton UKwith significant experience of advising multinational groups ona wide range of tax matters.Roopa has had more than 19 years of experience advising a
range of business types and sizes on tax matters. She specialisesin EU claims and related tax issues and has advised many clientson the compatibility of UK law with EU law. Most recently shesuccessfully advised in the Philips Electronics case which washeard by the Court of Justice of the European Union. Roopa’s wider tax team and colleagues provide advice con-
cerning all tax matters including indirect taxes and private clientin addition to corporate tax, thereby ensuring that all aspects ofher clients’ tax affairs are catered for.Many of the matters which Roopa advises on have cross-bor-
der implications affecting a client’s business in numerous juris-dictions. Roopa is able to draw upon the expertise and experi-ence of colleagues in the Grant Thornton International teamsfrom around the world to deliver seamless advice.Roopa works closely with her specialist colleagues across all
of Grant Thornton’s service lines to ensure her clients haveaccess to the full breadth of advice and counsel available to sup-port their businesses’ developments and wider growth aspirations.Roopa is a regular presenter at tax conferences and has published numerous technical arti-
cles on tax issues. She is on the UK branch committee of the International Fiscal Associationand the team has a strong reputation in the market, winning ‘Best International Tax Team’at the 2012 Lexis Nexis awards and ‘Best Team in a National Practice’ at the Taxation awards2014.
UK
Roopa Aitken
Grant Thornton
30 Finsbury SquareLondon EC2P 2YUUK
Tel: +44 (0)20 7728 3195LinkedIn:uk.linkedin.com/in/roopaaitkenEmail: [email protected]:www.grant-thornton.co.uk
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Karen is a partner in Osborne Clarke’s tax department and leadsthe firm’s employee benefits practice. She has more than 20years’ experience advising a broad range of clients on the design,implementation and communication of the full range ofemployee benefits and share schemes.Karen works for a diverse range of clients from owner man-
aged businesses through to global multinationals. She isrenowned for her ability to devise commercially effective remu-neration strategies to incentivise and motivate key individualswithin an organisation. She also advises clients and their interna-tionally mobile employees on tax efficient remuneration packages.Karen acts on a broad range of corporate transactions and
advises remuneration committees in relation to all-employeeand senior executive equity schemes.Karen qualified as a lawyer in 1995 and joined Osborne
Clarke as a partner in 2001. She is ranked as a leading individ-ual by the legal directories for her work on employee benefits.Karen is an active member of the Share Plan Lawyers
Organisation, and is a member of the Share SchemesCommittee for the Quoted Companies Alliance. She is theauthor of the directors’ remuneration chapter of Sweet &Maxwell’s A Practical Guide to Corporate Governance and theshare schemes chapter in Jordan’s Company Administrations.She writes for key tax publications and is a regular speaker at industry conferences. She holds a BA in jurisprudence from Oxford University.
UK
Karen Cooper
Osborne Clarke
2 Temple Back East Temple Quay Bristol BS1 6EG DX 7818 Bristol UK
Tel: + 44 (0) 117 917 3628 Fax: + 44 (0) 117 917 3629 Mobile: + 44 (0) 7753 832 328Email: [email protected]: www.osborneclarke.com
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Liesl Fichardt leads Clifford Chance’s contentious tax practiceand is one of the UK’s leading tax disputes practitioners. Shehas extensive experience in tax litigation, negotiations with rev-enue authorities and settlement of disputes. She possesses con-siderable court and tribunal experience including conductingcases in the Tax Tribunal, the courts of appeal and the Court ofJustice of the European Union. Liesl practiced as a tax barrister for 13 years and previously
acted as a judge in the High Court of South Africa. She is chair-person of the British Branch of the International FiscalAssociation. She is recognised in leading legal directoriesincluding International Tax Review’s Tax Controversy LeadersGuide for her outstanding success and for consistent positivefeedback from clients and peers.Liesl leads arguably the most experienced group of partners
who deal with tax investigations, litigation and dispute resolu-tion. The combination of local expertise and global networkallows Clifford Chance to handle complex disputes effectivelyand efficiently, whether in the UK or any other jurisdiction.Clifford Chance advises multinationals, financial institutions, corporates and high net worthindividuals on a number of tax and VAT matters covering the entire range of tax dispute res-olution including:• 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 courtsof 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
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Erika Jupe is a partner in Osborne Clarke’s corporate tax prac-tice and heads the international tax practice group. She is also amember of Osborne Clarke’s international council. She hasmore than 20 years’ experience advising both UK and multina-tional clients on a broad range of tax issues. Her work includes both standalone tax consultancy work as
well advising on a broad range of transactions including merg-ers and acquisitions, financings, joint ventures and restructur-ings. Her practice covers cross-border tax issues, partnerships,value added tax and international employee tax issues. Erika advises clients across a broad range of sectors and rep-
resents many of the firm’s biggest corporate clients on theirtransactions, with a particular emphasis on life science compa-nies and representing investment funds on formation, invest-ment and restructuring activity.She works with many international clients of the firm, often
representing overseas companies investing in the UK andEurope, or acting for European clients investing further afield.In such cases, she works closely with lawyers in OsborneClarke’s international offices.Erika qualified as a lawyer in 1990 and joined Osborne
Clarke in 1997, becoming a partner a year later. She is a member of the UK branch commit-tee of the International Fiscal Association and is a frequent speaker on tax developments andcontributor to tax publications. She is the author of the chapter on e-commerce in Tolley’sTax Planning.Erika is ranked in the UK legal directories as a leading individual on corporate tax mat-
ters.
UK
Erika Jupe
Osborne Clarke
2 Temple Back EastBristol BS1 6EGUK
Tel: +44 (0)117 917 4260Fax: +44 (0)117 917 4261Email: [email protected]: www.osborneclarke.com
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Francesca Lagerberg is the global leader for tax services at GrantThornton International, the sixth largest global accountingorganisation with $4.7 billion in revenues and operations in 130countries. Additionally, Francesca also serves as a member of theGrant Thornton global leadership team and is responsible forGrant Thornton European member firms and global legalissues. She is the only woman running a global tax practiceamong the six largest global accounting organisations. Before seconding to Grant Thornton International in 2013,
Francesca was the head of tax for the Grant Thornton UK mem-ber firm. She has worked in tax for more than 20 years and hermain focus today is helping the Grant Thornton network growits tax practices and attract, retain and develop talent in thewhole network by encouraging a consistent and inspiring cul-ture in which people can thrive.Under Francesca, Grant Thornton has taken global leader-
ship positions on a number of tax issues important to business,including most recently, global transfer pricing. In her thoughtleadership role, she is a regular commentator on radio and TVand in print, having appeared in numerous major press outlets including the HarvardBusiness Review, the Wall Street Journal, the Financial Times, Reuters, Bloomberg TV andBBC-TV. She is actively involved in lobbying for better, clearer and more proportionate tax legisla-
tion around the globe. She spoke recently on improving the relationship between tax interme-diaries and revenue authorities at the annual conference of the Intra-European Organisationof Tax Administrators. She also is on the UK’s Tax Professionals Forum, chaired by the UK’sfinancial secretary, the role of which is to oversee the implementation of the government’scommitment to reforming the framework for developing tax policy and making tax law.Francesca is a past chairman of the Tax Faculty of the Institute of Chartered Accountants
in England & Wales (ICAEW) and is a past council member of the Chartered Institute ofTaxation (CIOT). She is a fellow of the ICAEW and the CIOT, and is a qualified barristerand coach. She has written and edited many tax publications and has won awards for lectur-ing in tax and for her role in private client tax work.Francesca leads on women in business issues for Grant Thornton including this year’s
research on the path to leadership and is engaged in promoting the commercial case for morediversity at the senior and board level in business.
UK
Francesca Lagerberg
Grant Thornton
Melton Street, Euston SquareLondon NW1 2EPUK
Tel: +44 (0) 20 7728 3454Email:[email protected]: www.grantthornton.com
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Wendy has more than 25 years’ international experience advis-ing clients in the UK and overseas and is a member of the GrantThornton members firms’ Global Transfer Pricing Leadershipteam and is acknowledged in the Euromoney/Legal MediaGroup Guide to the World’s Leading Transfer Pricing Advisersand the Guide to the World’s Leading Women in Business Law.She sits on the Business and Industry Advisory Committee(BIAC) to the OECD and the Joint Transfer Pricing Forumwhich consists of government, tax authority and business repre-sentatives, and has the remit to help solve practical transfer pric-ing issues within the EU.Wendy works with businesses across many industries, special-
ising in those where intellectual property is important. Herwork encompasses transfer pricing documentation (master fileand country file) as well as planning for international expansionand growth, and dealing with the resolution of disputes. Shealso helps businesses navigate the changes arising from theG20/OECD project on base erosion and profit shifting(BEPS).
UK
Wendy Nicholls
Grant Thornton
Grant Thornton House Melton Street Euston Square London NW1 2EPUK
Tel: +44 (0)20 7383 5100Fax: +44 (0)20 7383 4715Email: [email protected] Website:www.grant-thornton.co.uk
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Heather Self is a partner (non-lawyer) in international law firmPinsent Masons’ market-leading tax disputes practice. With morethan 30 years’ experience in tax, she has been an in-house taxdirector and a senior adviser at HMRC and is part of a multidis-ciplinary team advising on a wide range of corporate tax disputes.Heather’s in-house experience was as group tax director at
Scottish Power, which at the time was a FTSE 100 energy com-pany. She had responsibility for all tax matters and advised onnumerous corporate transactions, including the $5 billion dis-posal of the regulated US energy business. At HMRC, sheworked on complex disputes with FTSE 100 companies, andwas a specialist adviser to the utilities sector, where she wasinvolved in policy issues on energy generation and renewables.Her current practice is focused on the large corporate mar-
ket, where she advises companies on technical issues and disputeresolution. Clients have said that the combination of her expe-rience has meant that she can “see things from all sides” and isable to give insights into the behaviour of HMRC as an organ-isation, as well as praising her client engagement.Heather is a frequent speaker and commentator on tax in
print and broadcast media, and regularly appears on pro-grammes such as BBC Breakfast, Wake up to Money and the Today programme. She is amember of the CBI Tax Committee and a CEDR accredited mediator. She also tweets as@hselftax.
UK
Heather Self
Pinsent Masons
30 Crown PlaceEarl StreetLondon EC2A 4ESUK
Tel: +44 (0)161 662 8066Email: [email protected]:www.pinsentmasons.com
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UK
Renata ArdousMazars
Amanda BrownKPMG
Helen BuchananFreshfields Bruckhaus Deringer
Lydia ChallenAllen & Overy
Jane CurranDeloitte
Nikol DaviesTaylor Wessing
Annie DevoyPwC
Karen EcksteinSimpson & Marwick
Sarah FalkFreshfields Bruckhaus Deringer
Alison Foster QC39 Essex Chambers
Heather GethingHerbert Smith Freehills
Sonia GilbertClifford Chance
Zena HanksSaffery Champness
Kendra HannDeloitte
Diane HayPwC
Louise HigginbottomNorton Rose Fulbright
Karen HughesHogan Lovells
Julie HughffKPMG
Kristine JarveEY
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UK
Anbreen KhanDeloitte
Sarah LeeSlaughter and May
Sara LuderSlaughter and May
Jane McCormickKPMG
Gabrielle McParlinEY
Aparna NathanDevereux chambers
Nicola ShawGray’s Inn Tax Chambers
Kelly Stricklin-Coutinho39 Essex Chambers
Fiona WalkinshawDeloitte
Philippa Whipple, QC1 Crown Office Row
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It’s a good time to be a female tax lawyer in the United States.While, most certainly, more needs to be done, women havemade significant progress in the US in recent years.Two women have been commissioners of the IRS: Peggy
Richardson and Shirley Peterson. Peggy was Commissioner forfour years, and Shirley, following her tenure as Commissioner,has sat on a number of large corporate boards of directors. Athird woman, Linda Stiff, also served as an acting IRS commis-sioner.I remember the first time that I met Shirley. She was dressed
in beautifully attractive clothes. It impressed me as a youngfemale tax attorney to meet her. A woman could be both suc-cessful and beautifully dressed.In the US Treasury Department, Danielle Rolfes serves as
International Tax Counsel. In the IRS, two deputy associatechief counsels (international) are female, Anne Deveraux andMargie Rollinson, and two international branch chiefs,Elizabeth Karzon and Barbara Felker, are women. It wasn’t longago that Phyllis Marcus was also an international branch chief.These are talented, as well as important, people. Danielle andBarbara, for example, went to Harvard Law School.There have also been notable and encouraging developments
in the private practice of tax law. The California Bar Tax Sectionhas had eight female chairs of the Tax Section, and the NewYork State Bar Tax Section has had five women serve as chair.Most of this happened in recent years.More needs to be done in the tax world, however. The US
Tax Court, which has 18 sitting judges, has only five femalejudges. These are impressive judges, indeed, but it would seemthere should be more than only five women on the court. JudgeMarvel, for example, recently wrote the court’s opinion in one
US
Jennifer FullerFenwick & West
Women in tax: The USperspective
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US
of the most significant decisions in recent years in the Tax Court, Altera v Commissioner.Altera involves an effort by the IRS to overrule an earlier decision in Xilinx v Commissioner,by issuing a new regulation. Judge Marvel, writing for a unanimous court, held that in thissituation the IRS did not apply proper administrative review procedures and wrote a regula-tion that is contrary to the guiding arm’s-length standard. While as a practitioner I waspleased to see that the taxpayer was successful in this important case, the more impressivething to me was the understanding and intellect that went into the court’s opinion. JudgeMarvel did an excellent job.A few years ago, I had a trial with Judge Cohen in Illinois Tool Works v Commissioner. She
was the Tax Court’s first female Chief Judge. At that time, there were only two other womenon the court. While five female members of the court today suggests some improvement, Ithink there should be more.I was at a dinner in New York last year and met Erika Nijenhuis, a senior tax partner with
Cleary Gottlieb Steen & Hamilton and a past chair of the NYS Bar Association Tax Section.It was great talking with her. It made me think of that term – dare I use it – “old boy’s net-work,” but there we were: two successful tax lawyers, female and beautifully feminine. Twojudges spoke at the dinner, too. Both were female.It is an exciting time for women tax lawyers in the US. Things have improved so much
since the time of Supreme Court Justices Ginsburg and O’Connor who graduated with veryhigh honours from law school but could not get jobs with a law firm because they werefemale. We’ve made great progress, but as I said above, more is needed to continue movingin the right direction and eradicate gender bias entirely.
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Cathleen Bucholtz is the managing director and NationalUnclaimed Property Practice leader for the Unclaimed PropertySolutions Team of True Partners Consulting. Cathleen hasextensive experience in all aspects of unclaimed property includ-ing audit defence, comprehensive diagnostic reviews, statisticalsampling, development of leading practices, and annual compli-ance. Before joining True Partners Consulting, Cathleen heldthe Western Region Unclaimed Property Practice leader forKPMG, and before 2002, was part of the National UnclaimedProperty Team for Arthur Andersen.Cathleen has more than 23 years of experience in unclaimed
property and state and local tax consulting and auditing, andhas represented numerous Fortune 500 clients in the defence ofboth unclaimed property and sales and use tax audits, resultingin hundreds of millions in total client savings.Cathleen also has extensive experience in unclaimed proper-
ty consulting for the healthcare, financial services, insurance,manufacturing, and retail industries.Before entering public accounting in the late 1990s,
Cathleen was a senior sales tax auditor and field audit supervi-sor for the California State Board of Equalisation.Cathleen has spoken before numerous trade and professional
organisations including the Unclaimed Property Professionals Organisation (UPPO),American Payroll Association, Institute for Professionals in Taxation (IPT), and the NationalBusiness Institute (NBI). In addition, she regularly collaborates on unclaimed property semi-nars geared toward the education of individuals in private industry. Cathleen was recently pub-lished in the Spring 2015 issue of the Journal of State Taxation: Frequently Asked QuestionsAbout Unclaimed Property.Cathleen is now serving as the co-chair for the UPPO’s Leadership Development Committee.
Previously Cathleen served as co-chair for UPPO’s Mentors Committee as well as four years asUPPO’s Education Committee co-chair, where she helped develop a multi-track educationalagenda for the organisation’s conferences attended by hundreds of participants annually.Cathleen earned a bachelor’s degree in business economics from the University of
California, Santa Barbara and is a licensed certified public accountant (CPA).
US
Cathleen Bucholtz
True Partners ConsultingLLC
633 West Fifth Street, Suite 6200 Los Angeles, CA 90071 US
Office phone: +1 213 417 2501Fax: +1 213 417 2551Cell: +1 805 558 9285Email:[email protected]: www.tpctax.com
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Elizabeth Erickson is a partner in the law firm of McDermottWill & Emery and is based in the firm’s Washington, DC office.She is a member of the US & International Tax practice group,and focuses her practice on tax controversies, including tax liti-gation.Elizabeth represents clients in disputes before the US Tax
Court, US district courts, the Internal Revenue Service Appealsand Examination Divisions, and the Internal Revenue ServiceNational Office. Substantive issues in dispute in these mattershave included capitalisation and change in method of account-ing issues; captive insurance; accounting for redemption of pre-mium coupons; abandonment loss issues; section 1341 claims;the tax treatment of settlement payments and legal fees, includ-ing tax reporting requirements; transfer pricing issues; and taxadvantaged transactions. She also has substantial experienceassisting clients with alternative dispute resolution techniques atthe pre-filing, exam and appeals stages.Elizabeth is a frequent speaker on tax controversy matters,
and was recognised as a ‘rising star’ in tax controversy in the2014 edition of The Legal 500 United States. She was alsonamed a 2014 ‘Tax Controversy Leader’ by the International Tax Review.Elizabeth is the hiring partner for the Washington, DC, office, and is a former co-chair of
the Pro Bono and Community Service committee for the Washington, DC office.Elizabeth is admitted to practice in the District of Columbia.Her representative experience includes acting in ITOCHU International v American Tire
Distributors; Securitas Holdings v Commissioner; Goodrich Corp v United States; USAA vUnited States and USAA v Commissioner; Capital One Fin Corp v Commissioner; WashingtonMutual v United States; Hercules v Commissioner; and Mary Kay Hold Corp v Commissioner.Elizabeth received her JD (cum laude) from Georgetown University Law Centre, and
bachelor’s (magna cum laude) and master’s degrees in accountancy from Florida StateUniversity.
US
Elizabeth Erickson
McDermott Will & Emery
The McDermott Building500 North Capitol Street, NWWashington, DC 20001US
Tel: +1 202 756 8097Fax: +1 202 756 8087Email: [email protected]: www.mwe.com
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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 World’s Leading Women Business Lawyers (2015).Jennifer was named ‘America’s Best in Tax Dispute
Resolution’ by Euromoney at its 2014 and 2015 AmericasWomen in Business Law Awards Dinner. She also has been onEuromoney’s Women in Business Law shortlist three times forthe award ‘Best in Tax’.Jennifer’s work during 2015 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 the
International Fiscal Association, which is a highly-regardedworldwide association of leading tax advisers, and has appearedregularly in Euromoney’s World’s Leading Tax Lawyers.Jennifer has served as the Northern California chair for the
California State Bar International Tax Committee. She has spokenat and chaired numerous seminars on international tax subjects,while her articles have appeared in Tax Notes Internationalmagazine and in Tax Notesmagazine.Whittier College awarded Jennifer its Alumna Achievement Award in 2013 “for superior
accomplishments in her career”. Later that year, she was elected to serve on the WhittierCollege Board of Trustees, a position she still holds.A tax partner at Fenwick for more than 20 years, Jennifer plays an instrumental role in the
firm’s tax practice. The firm has represented six of the Fortune top 10 companies, more than 50of the Fortune 100 and more than 100 of the Fortune 500 companies in federal tax matters. Jennifer also has 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, ITR’sLeading Lawyers in the Western US, Euromoney’s Guide to the Leading US Tax Lawyers, andInternational Tax Review’s Best Tax Advisers in North America.
US
Jennifer Fuller
Fenwick & West
801 California StreetMountain View, CA 94041US
Tel: +1 650 335 7284Email: [email protected]: www.fenwick.com
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Kathy Keneally serves as the chair of civil and criminal tax litiga-tion in DLA Piper’s global tax group. Before joining the firm,Kathy served as the assistant attorney general for the TaxDivision of the US Department of Justice (DoJ), where sheoversaw the work of more than 350 attorneys in civil, criminaland appellate tax litigation nationwide.During her tenure as the head of the DoJ Tax Division,
Kathy developed and implemented key tax enforcement initia-tives in close cooperation with IRS leadership. She workedclosely with DoJ leadership, US attorneys, and senior officials atfederal and state regulatory agencies, including the FederalReserve Board of Governors, the New York Federal Reserve,the Securities and Exchange Commission, and the New YorkDepartment of Financial Services. As the nation’s top tax pros-ecutor, she oversaw precedential action against financial institu-tions. Attorney general Eric G Holder, Jr recognised Kathy byawarding her the Edmund J Randolph Award for OutstandingService to the US Department of Justice and the Nation, thehighest honour the Attorney General may bestow on a DoJemployee.Kathy focuses her practice on civil and criminal tax contro-
versy matters, government investigations, and white collar criminal defence. She has morethan 30 years of experience representing large corporations, financial institutions, closely heldbusinesses and high-net-worth individuals in civil and criminal tax matters and non-tax crim-inal defence matters. She is an experienced trial lawyer, and has also resolved matters with theIRS and other federal agencies without proceeding to litigation. She also assists clients whoseek to come into compliance ahead of an investigation.Kathy is a leader in the legal community. She has served as a vice chair of the American
Bar Association Section of Taxation, and chaired two of the Section of Taxation’s commit-tees – the Committee on the Standards of Tax Practice and the Committee on Civil andCriminal Tax Penalties. She is now a regent of the American College of Tax Counsel, andserves as a chair of the National Institutes on Tax Controversy and Criminal Tax Fraud.Recently, Kathy was named by Tax Analysts as one of the top 10 people “who left their
mark on policy, practice and administration in 2014”.
US
Kathryn Keneally
DLA Piper
1251 Avenue of the AmericasNew York, NY 10020-1104US
Tel: +1 212 335 4582 Fax: +1 212 884 8559 Email:[email protected]: www.dlapiper.com
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Ginny Buckner Kissling is president of US operations and prin-cipal in Ryan’s Dallas office where she leads 1,500 employeesacross the United States, as well as 230 employees inHyderabad, India. Ginny is responsible for all aspects of servicedelivery operations within the United States and India, whichincludes 19 practices and 81 sub-practices, quality assurance,and business development. She is a technical expert specialisingin providing transaction tax services, including multistate auditdefence representation, research, reverse audits, and transactiontax education on a national basis. In addition to transaction taxservices, Ginny is an industry-recognised expert in the TexasEnterprise Zone Program, which is a business incentive for cap-ital investment and new or retained jobs, and other state andlocal incentives in Texas. Ginny lectures on various tax topics for Ryan clients.
Additionally, she has appeared as a speaker for the Council onState Taxation, Institute for Professionals in Taxation, InterstateTax Corporation, National Business Institute, and New YorkUniversity’s Institute on State and Local Taxation. She has writ-ten articles for the New York University, Institute on State andLocal Taxation and for the Institute for Professionals inTaxation. She received the 2010 Dallas Business Journal’s 40 Under Forty Award and was a 2014
Women in Business honoree. Ginny has served as executive director (1996–2000) and secre-tary/treasurer (1993–1995) for the Dallas/Fort Worth State Tax Association and held sev-eral leadership roles with the Institute for Professionals in Taxation, including chairing theSales and Use Tax Symposium, chairing the Membership Promotion and Public Relationscommittee, and serving as a committee member for its annual conference. Additionally,Ginny served as chair, Development Committee (2009-2011); chair-elect, ExecutiveCommittee (2012); chair, Executive Committee (2013); and Executive Committee boardmember (2014) of the Executive Committee of the University of North Texas Departmentof Accounting Advisory Board. She serves on the advisory board for New York University’sInstitute on State and Local Taxation, and belongs to the North Prestonwood chapter of theNational Charity League. Ginny holds an MSc degree in accounting with an emphasis in taxation and a BSc degree
in accounting, both from the University of North Texas.
US
Ginny Buckner Kissling
Ryan
Three Galleria Tower13155 Noel RoadSuite 100Dallas, TX 75240-5090US
Tel: +1 972 934 0022Fax: +1 972 725 0479Email: [email protected] Website: www.ryan.com
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Helen Lemmon is the principal-in-charge of Ryan’s Pittsburghoffice where she is responsible for quality service delivery of taxservices to multinational companies. She also served as Ryan’spractice leader for the US credits and incentives practice.Previously, Helen was an office managing partner, regional part-ner-in-charge of state and local tax (SALT) services, partner-in-charge of US credits and incentives services, and a locationleader for SALT at a national accounting firm. Before that,Helen was a SALT manager for a Fortune 500 company.Helen has served as a board member and co-chair for the
Existing Business Committee of the Pittsburgh RegionalAlliance, the boards of Girls Hope and Winchester ThurstonSchool, the board of Robert Morris University, the board andexecutive committee of the Pittsburgh Symphony. Helen has lectured on business incentives and credits,
appearing as a speaker for various clients and organisations,including the Council on State Taxation; the Institute forProfessionals in Taxation; New York University, Institute onState and Local Taxation; Tax Executives Institute; and theTexas Taxpayers and Research Association.She previously co-hosted a radio programme, The Business Journal, discussing relevant
business topics with a focus on economic impact. Helen was also featured on Our Region’sBusiness, a business affairs programme co-produced by the Allegheny Conference and CoxBroadcasting that provides business news, information, and commentary related to thePittsburgh region. Helen has written articles for The Tax Executive, Pittsburgh Business Times, Construction
Accounting and Taxation, and Journal of Multistate Taxation. She was the winner of the2010 Top 25 Women in Business Awards by the Pittsburgh Business Times and is a certifiedmember (CMI) of the Institute for Professionals in Taxation. She holds a bachelor of sciencedegree from Indiana University of Pennsylvania.
US
Helen Lemmon
Ryan
One PPG PlaceSuite 2810Pittsburgh, PA 15222US
Tel: +1 412 535 4400Fax: +1 412 535 4403 Email: [email protected] Website: www.ryan.com
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Jane Wells May is a partner in the law firm of McDermott Will& Emery and is based in the firm’s Chicago office. Jane headsthe firm’s State & Local Tax practice group and serves on thefirm’s Management Committee. She focuses her practice onstate and local tax matters.Jane represents businesses in connection with state and local
tax controversies at the audit, administrative and judicial levelsaround the United States. Her clients include companies inmanufacturing, retailing, food and beverage, pharmaceuticals,automotive, healthcare, energy, technology and insuranceindustries. Jane serves as national coordinating counsel to anumber of Fortune 500 companies, providing strategic counseland audit defence on all their state and local tax matters acrossthe country, including litigating in administrative and judicialvenues when necessary. She has successfully litigated state andlocal tax matters raising a variety of statutory and constitution-al issues. Jane has defended numerous internet sellers in severalstates against cases brought under state whistleblower statutes,including the Illinois False Claims Act, alleging fraudulent fail-ures to collect and remit use tax.Jane also advises business clients on tax planning matters and represents athletes and
entertainers in connection with employment contract issues.A member of the Director’s Advisory Group for the State of Illinois, Jane is a regular
speaker at seminars on state and local tax issues. She is a member of the Chicago BarAssociation’s State and Local Tax committee and is admitted to practice in Illinois. Jane hasbeen named a Leading Tax Lawyer in the Legal 500 United States, which states that she has“built a noteworthy local and state taxes practice”. She has also been ranked by ChambersUSA since 2008, which notes that she “is full of energy and brings a wealth of experience tothe work”. Furthermore, say the Chambers rankings, Jane is “excellent from an advocacypoint of view” and is considered a “strategic leader” in state and local tax. She has also beenregularly named an Illinois Super Lawyer in the tax area by Law & Politics.Jane received her bachelor’s degree (with honours) from Wittenberg University in 1980
and her JD from the Vanderbilt University School of Law in 1986. At Vanderbilt University,Jane was senior articles editor of the Vanderbilt Law Review and a member of Order of theCoif and Moot Court Board.
US
Jane Wells May
McDermott Will & Emery
227 West Monroe Street Chicago , IL 60606-5096US
Tel: +1 312 984 2115Fax: +1 312 984 7700Email: [email protected]: www.mwe.com
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Michele is the principal in charge of Deloitte Tax’s (US)Customs and Global Trade practice and sits on Deloitte’sGlobal Indirect Tax Executive Committee which manages a net-work of more than 550 import and export specialists fromaround the world. Michele has more than 25 years of experience advising
clients on numerous global trade matters. Michele specialises inthe operational side of global trade, helping clients assess anddesign their global trade management process including auto-mated solutions. Michele’s deep regulatory and operationalbackground allows her to apply real life practical solutions forher clients, which are not only compliant with a myriad of glob-al trade regulations but are also efficient and effective. Specifically, Michele has extensive experience in advising
Fortune 500 companies in numerous global trade managementareas including; global regulatory import and export require-ments, first sale for export planning and implementation; opti-misation of and compliance in their use of international tradeagreements; customs related party valuation compliance andstrategy; global import and export risk assessments; designingand implementing global import and export compliance programmes and rollout of automat-ed export and import systems and training. Before joining Deloitte Tax, Michele was a partner in Andersen’s US international trade
and customs group. Before Andersen, Michele spent five years as an associate attorney at aChicago-based law firm where she advised clients on numerous customs and internationaltrade related matters. She also worked as a visiting attorney in the international litigationdepartment of a large London law firm. Michele earned her bachelor of science degree from Indiana University, juris doctor degree
from the John Marshall Law School, and master’s of law in international transactions fromthe McGeorge School of Law in Salzburg, Austria and Sacramento, California. Additionally,Michele is a US licensed customs broker.
US
Michele McGuire
Deloitte Tax
111 South Wacker DriveChicago, IL 60606US
Tel: +1 312 486 9845Fax: +1 312 247 9845Mobile: +1 312 927 9845Email: [email protected]
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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 as a rising star in Euromoney’s Guide to the
World’s Leading Tax Advisers. Euromoney selected Larissa forinclusion in the Americas Women in Business Law Awardsshortlist for Best in Tax Dispute Resolution in 2014 and RisingStar: Tax, in 2015.Larissa frequently speaks at conferences for professional tax
groups, including the Tax Executives Institute, InternationalFiscal Association, Pacific Rim Tax Institute, Bloomberg, andthe American Bar Association. She is the ABA International LawTax Liaison.Larissa has published several articles, including recently:
• 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 (February2015)
• 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)• US International Tax Developments, The Euromoney Corporate Handbook 2012• Character and Source of Income from Internet Business Activities, The Contemporary Tax
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 (2014 and 2015) and is first tier in tax, according to World Tax2015. International Tax Review gave Fenwick its San Francisco Tax Firm of the Year awarda total of six times and its US Tax Litigation Firm award a total of three times. InternationalTax Review also named Fenwick its Americas M&A Tax Firm of the Year in 2012.
US
Larissa Neumann
Fenwick & West
Silicon Valley Center801 California StreetMountain View, CA 94041US
Tel: +1 650 335 7253Email: [email protected] Website: www.fenwick.com
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Jean A Pawlow is a partner in the global law firm of McDermottWill & Emery. She serves on the firm’s ManagementCommittee and Finance Committee and she is co-chair of thefirm’s tax controversy practice. US News and Best Lawyersnamed McDermott ‘Tax Litigation Firm of the Year’ for 2014.Jean has been involved in representing businesses and indi-
viduals on significant tax controversy matters for 25 years.Substantive issues in dispute have included transfer pricingissues under Code section 482, tax advantaged transactions, taxaccounting issues, insurance tax matters, the tax treatment offinancial instruments, foreign tax credit and research creditissues, leveraged leases, credit card interchange and originalissue discount (OID), excise taxes, reasonable compensation,estate and gift tax issues, and charitable contribution deduc-tions. She also advises on California and District of Columbiastate tax controversies.Jean has litigated cases before the US Tax Court, the Court
of Federal Claims, US district courts, US Courts of Appeal andthe Supreme Court. She also has extensive experience with IRSalternative dispute resolution (ADR) procedures, including fasttrack settlement, rapid appeals, post-appeals mediation, pre-fil-ing agreements and CAP audits. She frequently representsclients who are being audited by the IRS Global High Wealth Industry Group.Jean is a frequent writer and speaker on tax controversy matters and has appeared on CBS
and CNBC. She is the contributing editor of a 2015 book on global tax controversies. TheLegal 500 has named Jean a leading lawyer every year since 2009, and quoted a client whodescribed her as “a pleasure to work with, clever, an excellent advocate, personable and pos-sessed of an instinctive business understanding”. She has been nationally ranked as a leadingtax litigation lawyer in every edition of Chambers USA since 2010 as “one of the preeminenttax lawyers in the US” and noted for her “dedication to client service”. Jean was also listedin Best Lawyers in America in 2012, 2013 and 2014. She serves on the Tax Committee forthe US Court of Federal Claims Advisory Council and is a fellow of the American College ofTax Counsel.Jean received her bachelor’s degree (with high honours) from University of California at
Berkeley in 1985 and her JD (cum laude) from Harvard Law School in 1988.Her representative docketed cases include: Dine Equity v Commissioner; DiMare v
Commissioner; Estate of Stanton v Commissioner; John Hancock Life Insurance vCommissioner; Siemens v Office of Tax & Revenue; Novitsky v Siemens; AmbassadorBlankenship v Commissioner; USAA v United States and USAA v Commissioner; Goodrich vUnited States; Boeing v United States; Wal-Mart Stores v Commissioner; and Texas Instrumentsv Commissioner.
US
Jean Pawlow
McDermott Will & Emery
500 North Capitol Street, NWWashington, DC 20001US275 Middlefield Road, Suite 100Menlo Park, CA 94025US
Tel: +1 202 756 8297Tel: +1 650 815 7558 (CA) Fax: +1 202 756 8087 Email: [email protected]: www.mwe.com
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US
Darcy AlamuddinDeloitte
Lauren AngeliliCravath Swaine & Moore
Barbara AngusEY
Mary BennettBaker & McKenzie
Kim BlanchardWeil Gotshal & Manges
Kim BoylanWhite & Case
Linda CarlisleMiller & Chevalier
Loren ChumleyKPMG
Erin CollinsKPMG
Manal CorwinKPMG
Carol DunahooBaker & McKenzie
Michelle FerreiraGreenberg Traurig
Kathleen FerrellDavis Polk & Wardwell
Miriam FisherLatham & Watkins
Patricia Gimbel LewisCaplin & Drysdale
Michiko HamadaBDO
Jill-Marie HardingAlvarez & Marsal, Taxand
Geralyn HurdCrowe Horwath
Cynthia (Cindy) HustadDeloitte
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US
Michelle JewettMorrison & Foerster
Maria JonesMiller & Chevalier
Barbara KaplanGreenberg Traurig
Sharon Katz-PearlmanKPMG
Julia KazaksSkadden, Arps, Slate, Meagher & Flom
Kathrine KimballDeloitte
Susan KleinRimon Law
Rachel KleinbergDavis Polk & Wardwell
Dominika KorytekBaker & McKenzie
Mary KuusistoProskauer Rose
Emily LamSkadden, Arps, Slate, Meagher & Flom
Patricia LesserBuchanan Ingersoll & Rooney
Erika LitvakGreenberg Traurig
Beth MuellerDeloitte
Erika NijenhuisCleary Gottlieb Steen & Hamilton
Pamela (Pam) OlsonPwC
Kathleen PakenhamCooley
Emily ParkerThompson & Knight
Kimberley Peterson McGuireDeloitte
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US
Nehal RadiaDeloitte
Patricia Anne RexfordBaker & McKenzie
Kristine RiisbergDeloitte
Kathy SaxtonDeloitte
Jodi SchwartzWachtell Lipton Rosen & Katz
Linda StiffPwC
Patricia SweeneyMiller & Chevalier
Catlin UrbanBaker & McKenzie
Mary VoceGreenberg Traurig
Karen WarnerDeloitte
Jill WeiseDuff & Phelps
Lisa ZarlengaSteptoe & Johnson
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1 Crown Office Row, 7939 Essex Chambers, 78, 79ADB, 68Advicero/Green Real Accounting, 55AFA OOD, 14Allen & Overy, 12, 78Alvarez & Marsal Taxand, 92Arntzen de Besche, 55Arsene – Taxand, 24Avocats Baltus, 12Baker & McKenzie, 12, 17, 21, 24, 27, 38,39, 46, 50, 58, 62, 70, 92, 93, 94
Baker & McKenzie.Wong & Leow, 61BDO, 92BDO Tax, 39Bennett Jones, 15, 16Bird & Bird, 23Blake Cassels & Graydon, 15, 16bln palao abogados, 62BMR & Associates, 31, 32, 33Borenius, 21Bowman Gilfillan, 61Brewer Morris, 3BTOC Tax, 56Buchanan Ingersoll & Rooney, 93Camilleri Preziosi, 42, 45Caplin & Drysdale, 92Castro Barros Sobral Gomes, 14Cleary Gottlieb Steen & Hamilton, 24, 39,93
Clifford Chance, 27, 73, 78CMS Bureau Francis Lefebvre, 24CMS Rui Pena & Arnaut, 56Cooley, 93Cravath Swaine & Moore, 92Crido – Taxand, 56Crowe Horwath, 92Cuatrecasas Goncalves Pereira, 56, 62Davis Polk & Wardwell, 92, 93
Deloitte, 4, 6, 7, 8, 9, 10, 12, 15, 16, 17,24, 27, 35, 38, 39, 40, 41, 47, 50, 55,56, 57, 58, 61, 62, 64, 68, 69, 70, 78,79, 89, 92, 93, 94
Dentons, 15, 24, 55, 58, 70Derraik & Menezes Advogados, 14Desai Haribhakti & Co. CharteredAccountants, 34
Devereux chambers, 79DLA Piper, 38, 55, 70, 85Drew and Napier, 61Du-Baladad, 55Duff & Phelps, 94Eduardo Paz Ferreira, 56Erdikler - Taxand, 70Eurofast Taxand, 18, 20EY, 10, 12, 15, 17, 21, 27, 38, 50, 55, 56,57, 58, 61, 68, 78, 79, 92
Fenwick & West, 80, 84, 90FIDAL International/KPMG, 24Flick Gocke Schaumberg, 27Freshfields Bruckhaus Deringer, 78Garrigues – Taxand, 57, 62Gillioz Dorsaz & Associes, 68Godoy & Hoyos, 17Goodmans, 16Grant Thornton, 28, 65, 71, 75, 76Gray’s Inn Tax Chambers, 79Greenberg Traurig, 92, 93, 94Group 621 Advocates, 61Herbert Smith Freehills, 78HLB Proxy, 21Hogan Lovells, 38, 78Hulgaard Advokater, 21Independent, 55, 56, 57Jun He, 16Jurimex, 70Khaitan & Co, 29King & Spalding, 24Kocian Solc Balastik (KSB), 21
Index of firms
Index of firms
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Index of firms
KPMG, 10, 13, 15, 16, 17, 27, 35, 39, 50,51, 57, 58, 59, 60, 61, 62, 66, 67, 70,78, 79, 92, 93
KPMG Alpen-Treuhand, 11KPMG Huset / KPMG Law Advokatfirma,53
KPMG Law Advokatfirma, 54Küffner Maunz Langer Zugmaier, 25Laga, 12Latham & Watkins, 92Lavrynovych & Partners, 70Law Square, 12Lee and Li, 68Lexcom, 24Liedekerke Wolters Waelbroeck, 12Loyens & Loeff, 12, 50, 68Machado Associados, 14Machado Meyer, 14Matheson, 38Mattos Filho, 14Mayer Brown, 12, 22Mazars, 78McCarthy Tetrault, 15, 16McDermott Will & Emery, 83, 88, 91MDDP, 55, 56Miller & Chevalier, 92, 93, 94Minter Ellison, 10MNP, 15, 16Morrison & Foerster, 93Norton Rose Fulbright, 78On Your Side, 61Osborne Clarke, 72, 74Osler Hoskin & Harcourt, 15, 16Paczuski & Taudul Tax Advisors, 55Pinheiro Neto Advogados, 14Pinsent Masons, 77Plesner, 21PLMJ, 56Proskauer Rose, 93PwC, 10, 12, 15, 16, 17, 35, 38, 48, 50,56, 57, 58, 61, 66, 68, 78, 93, 94
PwC/Landwell, 24Quinones Cruz, 17RG Manabat (KPMG), 55
Rimon Law, 93Rogerio Fernandes Ferreira & Associados(RFF), 57
Ronne & Lundgen, 21Ryan, 5, 49, 86, 87Saffery Champness, 78Shearn Delamore, 41Simpson & Marwick, 78Skadden Arps Slate Meagher & Flom, 93Skeppsbron Skatt - Taxand Sweden, 66Slaughter and May, 79SR Dinodia & Co Chartered Accountants,30
SSW (Spaczynski Szczepaniak i Wspolnicy),55
Steptoe & Johnson, 94Studio Camagni e Associati, 38Studio Fantozzi & Associati, 39Svalner Skatt & Transaktion, 63Tax Advisors & Associates, 68Tax Link Baltic, 39TaxHouse Taxand Romania, 57Taylor Wessing, 78Thompson & Knight, 93Torys, 15TozziniFreire Advogados, 14Tremonti Vitali Romagnoli Piccardi eAssociati, 38
Trench Rossi e Watanabe – in associationwith Baker & McKenzie, 14
True Partners Consulting, 82Uría Menéndez, 56, 57Valoris Avocats, 24Varul, 39Vieira de Almeida, 56, 57Wachtell Lipton Rosen & Katz, 94Weil Gotshal & Manges, 92White & Case, 58, 92William Fry Tax Advisors Taxand Ireland,36, 37
Willkie Farr & Gallagher, 24Wong & Partners (Baker & McKenziemember firm), 41
WTS, 26
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