over 25 years ex pe rience...gional tax advice to large AP inbound MNC’s. • Merged traditional...

over 25 years , e xpe rience

TAX

Q&AS WITH: CHRIS ROBERGEDELOITTESOPHIE BLÉGENT-DELAPILLEDELOITTEANDREW J WILDEDELOITTEWILBERT KANNEKENS ANDLOEK HELDERMANKPMG MEIJBURG & CORICARDO GONZÁLEZ ORTADELOITTEPHILIPPE BELAIRDELOITTESTEVE KIMBLEDELOITTE

FEATURES BY: TRACY HO AND DESMOND TEOEYASEEM CHAWLAASC LEGAL, SOLICITORS &ADVOCATESSIM SIEW MOONEY

WHAT’S INSIDE?

Who do clients really rate as the top practitioners?

ORDER FORM £85 per copy. Please send me the following Expert Guides. Indicate no. of copies in each box:

Aviation 2020 Banking, Finance and Transactional 2019 Best of the Best 2020 Best of the Best USA 2020 Competitionand Antitrust 2018 Construction and Real Estate 2019 Energy, Environment and Mining 2020 Commercial Arbitration 2019

Insurance and Reinsurance 2019 International Trade and Shipping 2017 Labour and Employment 2014 Life Sciences 2019 Litigation and Product Liability 2016 Patents 2019 Rising Stars 2020 Tax 2020 TMT 2015 Trade Mark 2020 Transfer Pricing 2019 White Collar Crime 2020 Women in Business Law 2019 Total £:

METHOD OF PAYMENTPlease find enclosed a cheque payable to ‘EuromoneyTrading Limited’Please invoice me/my company (Purchase Order Number: ____________________________)

Signature: _________________ Date: ____/____/____

YOUR DETAILS

Name:

Position: Company:

Address:

City/State: Post Code:

Country: Email:

Tel: Fax:

For 26 years, Legal Media Group’s Expert Guides have identified the world’s leading lawyers in 30 practice areas. If you regularly interact with the legal profession in a specific practice area anywhere

in the world, you should obtain a copy of the relevant Expert Guide for just £85

3 easy ways Tel: +44 (0) 20 7779 8418 Post to:to order: Email: [email protected]

Tatiana Hlivka, Expert Guides, 8 Bouverie Street, London EC4Y 8AX, UK

TAX EXPERTGUIDES 1

Research managerTatiana HlivkaProject managersMargaret Varela-ChristieRaquel IpoAlexandra StrickProduction managerLuca ErcolaniProduction editorJosh PasanisiManaging director, LMG ResearchTom St Denis CEO, Specialist InformationJeff Davis

To order extra copies or reprints please contact:Tatiana HlivkaExpert GuidesLegal Media Group8 Bouverie StreetLondon EC4Y 8AXUnited KingdomTel: (44) 20 7779 8418Email: [email protected] £85© Euromoney Trading Limited June 2020

No matter contained herein may be reproduced,duplicated or copied by any means without theprior consent of the holder of the copyright, requestsfor which should be addressed to the publisher.Although Euromoney Trading Limited has madeevery effort to ensure the accuracy of thispublication, neither it nor any contributor canaccept any legal responsibility whatsoever forconsequences that may arise from errors oromissions, or any opinions or advice given. Thispublication is not a substitute for professional adviceon specific transactions.

Directors: Leslie Van De Walle (Chairman), AndrewRashbass (CEO), Wendy Pallot, Jan Babiak, KevinBeatty, Tim Collier, Colin Day, Tristan Hillgarth,Imogen Joss, Lorna Tilbian

Cover image © doucefleur/stock.adobe.com

The Queen’s Award for Enterprise 2008

METHODOLOGY 2

ASIA PACIFIC 3

EUROPE 25

LATIN AMERICA AND THE CARIBBEAN 70

MIDDLE EAST AND AFRICA 82

NORTH AMERICA 85

EXPERTGUIDEST H E W O R L D ’ S F I N E S T A D V I S E R S C H O S E N B Y T H E I R P E E R S

TAX

CONTENTS

2 EXPERTGUIDES TAX

METHODOLOGY

EXPERT GUIDESRESEARCH

Expert Guides has been researching the world’slegal markets for over 25 years, and has becomeone of the most trusted resources for internationalbuyers of legal services.

Our guides cover a broad – and growing – rangeof legal practice areas, including:

AviationBanking, finance and transactionalCommercial arbitrationCompetition and antitrustConstruction and real estateEnergy and environmentInsurance and reinsuranceInternational trade and shippingLabour and employmentLife sciencesLitigation and product liabilityPatentsPrivacy and data protectionRising starsTaxTechnology, media and telecommunicationsTrade markTransfer pricingTrusts and estatesWhite collar crimeWomen in business law

Our guides are distributed to and regularly used bythe world’s most prominent decision-makers andfrequent buyers of legal services. Each guide has anextensive distribution list plus additional tailoring toits area of focus.

Each guide is also reprinted in full atwww.expertguides.com

Welcome to the 2020 Guide to the World’s Leading Tax Advisers the international legal market’sleading guide to the top legal practitioners advising on tax law.

When first published in 1994, the Expert Guides were the first-ever guides dedicated to leadingindividuals in the legal industry. Since then we have continued to focus on individuals consid-ered by clients and peers to be the best in their field.

The guides for each practice area are updated every two years. Our research process involvessending over 5,000 questionnaires to senior practitioners or in-house counsel involved in eachpractice area in over 80 jurisdictions, asking them to nominate leading practitioners based ontheir work and reputation. The results are analysed and screened for firm, network and alliancebias. The list of experts is then discussed and refined with advisers in legal centres worldwide.

Our researchers have compiled a list of specialists in 73 jurisdictions for this guide. These spe-cialists have been independently offered the opportunity to enhance their listing with a profes-sional biography. The biographies give readers valuable, detailed information regarding eachadviser’s practice and, if appropriate, their work and clients.

We owe the success of this guide to all the in-house counsel and firms that completed question-naires and met our researchers. Thank you. We hope you find the guide to be a useful tool. Allinformation was believed to be correct at the time of going to press.

Research team

Methodology

TAX EXPERTGUIDES 3

Australia 19

Cambodia 20

China 20

Hong Kong SAR 10, 21

India 11, 21

Indonesia 22

Japan 15, 22

Malaysia 22

New Zealand 23

Philippines 23

Singapore 16, 23

South Korea 24

Taiwan 24

Thailand 24

Vietnam 24


A S I A PA C I F I C

Q&A with:

Chris Roberge of Deloitte 6

Features for:

Hong Kong SAR, by Tracy Ho and Desmond Teo of EY 8

India, by Aseem Chawla of ASC Legal, Solicitors & Advocates 11

Singapore, by Sim Siew Moon of Ernst & Young Solutions 16

4 EXPERTGUIDES TAX

ASIA PACIFIC REGIONAL PROFILE

Deloitte Asia Pacific Regional Profile

35/F, One Pacific Place, Admiralty, Hong KongTel: +852 2852 6600Email: [email protected]: @DeloitteWebsite: Deloitte.com/tax Offices: Offices in more than 120 cities in over 20 countries in the AsiaPacific RegionNumber of professionals: 672 partners and over 10,000 client serviceprofessionals

Deloitte Asia Pacific brings together our tax and legal professionals toprovide a seamless and one-stop-shop client experience across geo-graphical boundaries and offer them one door to the future. Whetherthey are the Head of Tax, Head of Mobility, General Counsel, CFO, orothers, we assist our clients to navigate through uncertainties, connectfor impact and make confident decisions.

We are the only fully integrated firm in AP including all major mar-kets (Australia, New Zealand, Japan, China, South East Asia, Korea andTaiwan. To our clients, this means ease of access to an increased numberof professionals and opportunities regardless of where they are located.

Deloitte AP leads the region in providing a full spectrum of taxservices that extends beyond traditional tax services and includes legalservices, immigration services, tax and finance outsourcing, and taxrelated technology services.

Of particular importance is the investments we have madearound our world class business operations and technology plat-forms. Our global and regional delivery centers, such as the AsiaPacific International Center of Excellence (AP ICE) and our AP Re-gional Headquarter Center serves as a one-stop-shop advisory pow-erhouse for inbound and outbound investors. Global TransferPricing Center in India, various compliance centers in south eastAsia, China and India, and various Country Services Groups (in-cluding China, Japan and Korea), are additional examples of ourplatforms used to support our clients on their most pressing busi-ness needs.

While collaboration has been a theme word that Deloitte AP hasbeen living out in recent years, innovation and digitalization are play-ing an accord as Deloitte orchestrates its efforts in advancing tradi-tional offerings as well as developing digital capabilities. Inrecognizing our efforts in innovation, Deloitte has topped the list of“Most Innovative Companies” in various countries across AP and hasbeen appreciated by various alliance stakeholders (SAP, AWS, Sales-force etc.) as “an innovative partner” in recent years.

With collaboration, innovation and digitalization at the core, De-loitte AP has demonstrated its capabilities to provide innovative solu-tions to complex issues and empower clients to make tax and businessdecisions with confidence. We make an impact that matters.

With over 10,000 Tax & Legal partners and professionals, Deloitte

Tax & Legal teams are dispersed in more than 120 cities of 20+ coun-tries and regions in Asia Pacific.

We operate as one firm across Asia Pacific by combining our prac-tices in Asia Pacific. The power of a single member firm provides sim-pler access to more resources and with more consistency and qualityof services across AP.

Deloitte has always been appreciating its alliance partners to en-sure we bring our best capabilities and insights to our clients. This hasled Deloitte to view itself as part of an eco-system with partners in-cluding Apple, Salesforce, SAP, Alibaba, etc. across AP.

Asia Pacific Tax & Legal, has recorded uninterrupted growth againthis year which allows us to continually invest in the future of tax ser-vices. This includes investments in delivery platforms, technology andnew market offerings.

Innovation is at the core to the growth of our business. Some keyexamples are as follows:• We have designed and built a customized client digital platform.

Through this digital platform, we communicate with our clients,collect information, manage projects, provide news and insights,and provide data analytics. This platform then synchronizes withmany of our tax solutions and provides centralized data manage-ment (cloud) and links to direct and indirect tax complianceneeds. This platform transforms the traditional interaction into amodern, digitally empowered, relationship that significantly im-proves efficiency and accuracy.

• Through our alliances (SAP, Alibaba etc.) we have created tax solu-tions that focused on future ready tax businesses.

• Our legal practice is using technology and digital platforms to rev-olutionize how law departments prepare contracts, review con-tracts (AI etc.), track filings, store data, and undertake duediligence (automated contract review).

• Our automation tax tools allow for robotic processing (RPA) of in-direct tax returns and direct links to tax authorities saving thou-sands of man hours and human errors.

• Our Bridge your GAAP and other tools allow for automatic prepa-ration of statutory financial statements from diverse financialdatabases and multiple business codes as required for tax filingpurposes.We have also been innovative in how we identified unique client

needs. Some examples are:• Created the Regional Head Quarters program that provides AP re-

gional tax advice to large AP inbound MNC’s.• Merged traditional expatriate tax services with immigration ser-

vices on a large scale.• Created our own offshore and onshore delivery centers that focus on

the efficient and high-quality delivery of recurring tax processes.Amongst other things we are unique in that we provide:

• Immigration services


TAX EXPERTGUIDES 5

Q&A ASIA PACIFIC

• Legal services• Tax technology consulting services• Finance, tax and payroll outsourcing services

Our key service offeringsOur key service offerings include:

Business Tax: Corporate Tax Compliance and Reporting; Tax Controversy; BusinessTax, High Net Worth Individuals Consulting; International Tax Con-sulting; Tax Implications of Business Changes

Transfer Pricing (TP): TP Documentation and Reporting; TP Controversy; TP Consulting

Mergers and Acquisitions: Tax Due Diligence, Transaction Tax Structuring; Tax Transaction Exe-cution; Post-Merger Integration

Global Investments and Innovation Incentives: Government Grants and Incentives; Research & Development and IPTax; Incentives Controversy

Tax Management Consulting: Global Tax Compliance and Reporting; Tax Function Strategy andOperations Consulting; Tax Technology Consulting

Business Process Solutions: Tax Compliance and Reporting; HR and Payroll processing; FinancialAccounting and Operations; Business Process Technology

Indirect Tax:VAT and GST Consulting, Compliance, Reporting, AutomationGlobal Trade Advisory

Global Employer Services: Global Mobility Compensation and Tax; Reward, Employment Taxand Share Plans; Immigration; Mobility Advisory, Technology andAnalytics

Deloitte Legal: Employment and Benefits Law; Commercial Law; Legal ManagementConsulting; Corporate Mergers and Acquisitions Law

Recent wins: Due to client confidentiality we cannot disclose specific wins.

Awards:

2019 International Tax Review Awards – 10 awards: • Regional Impact Cases of the Year: Indonesia, Malaysia • National Tax Firms of the Year: Indonesia, Malaysia, Singapore• Transfer Pricing Firms of the Year: India, Indonesia, Thailand• National Tax Litigation & Disputes Firms of the Year: Taiwan,

Thailand

The M&A Deal of 2019 by the M&A Advisor

The Legal 500Top rankings and recommendations to Deloitte Legal practices inAustralia, Cambodia, China, Thailand & Singapore.

This document has been prepared solely for the purpose of publishing in the 2020 Guide to the World’s Leading Tax Advisers and may not be used for any other purpose. This documentand its contents may not be reproduced, redistributed or passed on, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written consent.

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”).DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in re-spect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services toclients. Please see www.deloitte.com/about to learn more.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms or their related entities (collectively,the “Deloitte organization”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances oryour business, you should consult a qualified professional adviser.

No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of DTTL, its memberfirms, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this com-munication. DTTL and each of its member firms, and their related entities, are legally separate and independent entities.

© 2020. For information, contact Deloitte Global.


6 EXPERTGUIDES TAX

ASIA PACIFIC Q&A

Q&A with Chris RobergeTax partnerDeloitte AP

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?A convergence of three key events have transformed Asia Pacific:• Rise of the AP domestic consumer• Shifting of trade routes due to geopolitics and diverging economic

growths• COVID-19

What was the most notable effect of that change?The most notable affect is the adoption of “change is the new norm”mind-set. All of these things have forced people to embrace change,seek flexibility and agility, and look for continuous improvement andgrowth. With respect to tax, this has resulted in taxpayers and advisorsneeding nimbleness, flexibility and quick reflexes as tax authoritiesquickly change long standing policies.

Where is the market moving in this practice area?The market is adopting technology as one of the solutions to be flexi-ble and quick. Technology allows for mobility and quick scalability asthe business grows or is modified. In light of COVID 19 it also re-sulted in less disruption to the tax function.

What kind of impact will this have on your work?This is impacting our work by accelerating our adoption of technol-ogy. It is becoming more of a necessity to address our constantlychanging clients’ needs.

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?BEPS will have an impact as it will shift taxes amongst countries. Thiswill both necessitate the change of business structures and approachesas well as tax legislation as countries need to maintain their tax base.We also anticipate a growth in consumer-based taxes (digital levytaxes, pillar 1, indirect taxes) which will also challenge some of thefundamental long-standing taxation policies.

If these come into force, how will the industry look in the future?There will be an increase in transactional based taxes vs profit-basedtaxes. This will result in a change in tax advisor capabilities and tech-nology tools to address this.

How would you describe the tax controversy landscape in yourregion/jurisdiction?In development. Across the region there is varying degrees of capabili-ties by tax authorities, adherence to rules of law/due process, clarity inprocedures, and relationships with taxpayers. All have the objective toaddress these issues but are doing so at a different pace.

Do you expect tax procedures in your region to move towardscommon standards or diverge in the future?The acceptance of OECD policies (MLI, OECD Treaty, BEPS) is be-coming more widely accepted in AP and as such there is tolerance forcommon standards. There is very regular sharing amongst tax author-ities on policies and procedures as they all work to gain efficiencies.

However, more common standards does not mean less disputes asthe standards will always have local interpretation and localizationamendments.

Is the global drive towards regulation going to affect taxpractice? If yes, in which areas?Regulation will result in more reporting. Additional reporting also re-sults in more auditing and disputes. As a result, our tax practice willgrow more round data management for reporting needs and tax con-troversy to deal with the upcoming audits and disputes.

What do you see as direct impact of COVID-19 in your practice?COVID-19 will result in an initial slowdown of our business overallfollowed by a recovery as we assist our client get back to normal assoon as possible.

We also expect there will be business model changes as companiesrestructure to address demand changes as well as supply chainchanges. These will all necessitate tax changes.


TAX EXPERTGUIDES 7

Q&A ASIA PACIFIC







8 EXPERTGUIDES TAX

ASIA PACIFIC THOUGHT LEADERSHIP

Asian family enterprises – beyondthree generations

Tracy Ho and Desmond TeoEY Asia-PacificHong Kong and Singapore

Shirt sleeves to shirt sleeves in three generationsIt is often cited that 70% of wealthy families typically lose their wealthby the second generation, and 90% by the third1, and this is seenacross different societies.

In comparison, the average age of an S&P 500 company today isunder 20 years, down from 60 years in the 1950s, according to CreditSuisse. And this trend is anticipated to continue. As per growth strat-egy consulting firm Innosight, it is anticipated that about 50% of theS&P 500 will be replaced over the next 10 years.

The above reflects the need for companies, multinational corpora-tions (MNCs) or family enterprises alike, to reinvent themselves and stayrelevant, as disruptions from globalisation, technology and most re-cently, the 2020 COVID-19 pandemic has changed the market environ-ment dramatically, forcing businesses to evolve faster than ever before.

Peeling through the layersTraditionally, for many family enterprises, there is often a desire tokeep the family business and management within the family, ratherthan relying on external talent who sometimes may otherwise be bet-ter qualified or suited for the job. With this expectation placed on thenext generation, some of them in the past may also feel the pressureor a personal duty to join the family business even though they maynot be interested in running the business.

The tenure of the management in a family enterprise is typicallylonger, compared to say CEOs of a publicly owned company. Whilethis is good for the family enterprises as decisions can be made for themedium to long-term interest of the family and the business, thetrade-off is that without an infusion of new blood and fresh ideas, thebusiness risk stagnation may happen overtime when they do not reinvent themselves.

Lastly, in the past, it was not uncommonfor family members to join family enterprisesstraight from school. This meant that theymay not have gained broad experiences fromworking outside the family enterprise. Thismay explain why some family enterprises mayfind it challenging to identify or respond toshifts in technology, business models andconsumer behaviour.

Moving up the economic ladderFamilies in Asia are moving up the economicladder and, building their businesses and

wealth. This can be attributed to the rise of wealth creation in Asia inthe past three decades .• The opening up of China and the phenomenal growth of China’s

economy to become the world’s second largest economy, not onlycreated opportunities for exports of Chinese-made goods but alsothe export of services. This has also fuelled the China market’s do-mestic consumption which contributed further to its growth giventhe size of its domestic population.

• The emergence of new businesses and business models from theFourth Industrial revolution, saw some Asian groups grown to be in-dustry leaders. This created new wealth within Asia, which led toother knock-on successions as many of these successful entrepreneurscontinued to further invest into other successful ventures.

• The above, along with globalisation and broader-based growth ofaffluence in Asia, contributed to the growth of Asian family enter-

prises, and a number have gone on to be listedin local and overseas stock exchanges.

Digital transformationIn these current times of unprecedented busi-ness disruptions, businesses are no longer un-dergoing an evolution. Rather, we are seeing arevolution where many business models arebeing transformed or overhauled in order tostay relevant in a new economy, catering tothe new generation of consumers who are in-creasingly born during and post internet era.

Centre to the above is digitalisation. Digi-tal transformation is a journey and often tak-ing the first step is difficult. With many of the

EY PRIVATE’S MISSION:TO UNLOCK THEAMBITIONS OF

AMBITIOUS. WE AREHOPEFUL MORE ASIAN

FAMILY ENTERPRISESSUCCEED BEYOND THE

THIRD GENERATION.

H O N G K O N G S A R

TAX EXPERTGUIDES 9

THOUGHT LEADERSHIP ASIA PACIFIC

next generation born in an internet age, they are digital natives com-fortable with the new economy, the technologies and opportunitiespresented.

Where the next generation is involved in the business, this hashelped many family enterprises to adapt and digitally transform, espe-cially during the COVID-19 pandemic which hastened the digitaljourney if the businesses are to survive in a post-COVID-19 world.

Handing over of the reinsIn the past couple of years, we are seeing more next generation start-ing to take a more active role in the family enterprise and investingthe family’s wealth often in a more institutionalised manner, probablydue to a convergence of factors:• The patriarchs and matriarchs are advancing in age• There is a return of the next generation to the family enterprises,

after working outside and having gained expertise and experiences• The network that the next generation has built socially and profes-

sionally is starting to take root.• Emergence of the new economy, where the next generation often

relate better to and have an interest in.We are also seeing the transition occur earlier. In the past, the

handing over the reins may take place upon certain events such as thepassing of the patriarch or matriarch. There is now an increasingtrend where the next generation is taking over while the patriarch ormatriarch is still capable and can tap on their deep experiences to pro-vide the guidance and stewardship as needed.

Well thought out wealth transition planWith globalisation, families are increasingly holding investments andassets outside their home jurisdiction. Coupled with increased mobil-ity of the business owners and their family members, complexitiessuch as inheritance tax issues can arise due to estate duty and inheri-tance tax rules in different countries. These may apply on differenttypes of assets ranging from shares in companies to immovable prop-erty. For example, estate duty may be imposed when an individual isnot resident in a particular jurisdiction but holds moveable propertysuch as shares, artwork or fine wine within that jurisdiction.

With broader experiences and networks, families are increasinglymore aware of the need for proper succession and estate planning tofacilitate a successful transfer of their wealth and business to the nextgeneration. These include:• Putting in place a family governance framework, where there is a

family constitution for family members to abide by. This alsoaligns with the family and family enterprise’s values and vision forthe future.

• Timely implementation of arrangements and structures to addressestate duty and inheritance tax implications from assets held do-mestically and overseas by the family.

• Having a framework that nurture and reward next generation fortheir entrepreneurial and innovative efforts in the face of globalisa-tion and disruption. This involves attracting, motivating and re-taining the next generation to be involved in the family enterprise.

Single family offices – a choice that is now feasibleWealth transition and succession planning is a journey and requiredifferent tools, such as trusts, family holding companies, family con-stitution, etc.. The single family office is an additional tool that is usedfor wealth transition, and often used in conjunction with trusts and

family holding vehicles. It provides more structure and rigour asAsian families’ needs become more complex, more sophisticated solu-tions are demanded.

With the development of single family offices, retaining ownershipof the family enterprise no longer necessarily means having the nextgeneration to run the family enterprises. For example, professionalmanagement teams may be brought in to run the family enterprisesday- to-day operations, while the next generation can work in thefamily office to manage the investment portfolio, as well as providestrategic oversight on the family enterprises. This also allows for exter-nal expertise to be brought in to run the family enterprise, while ac-cording strategic oversight to the family to meet the long-term goalsof the family and the business.

Even with COVID-19 pandemic in 2020, we anticipate this trendof single family offices to continue because: -a) Families look towards seizing the window for investments during

this period, due to:• Portfolio rebalancing• Making opportunistic investmentsThe nimbleness of a single family office to switch between investmentfocus and asset classes is a key advantage. This is due to the wide andflexible mandate of a single family office, as well as the flatter organi-sation that also means decisions can be made much quicker.

b) Single family offices manage “patient” capital and this meant thatthey can afford to wait before deploying its assets under manage-ment (AUM) to make investments. They can also have a muchlonger investment horizon than many financial institutions and in-vestment funds. This allows family offices to take contrarian in-vestment positions and invest in times when others are exiting.

c) Many investment vehicles of family offices often enjoy tax exemp-tion on qualifying income. For example, as Singapore’s tax exemp-tion covers interest income, Singapore- based family offices areable to provide the needed financing or acquire distressed debtsand enjoy tax-free returns on interest income earned.

d) Where overseas families are seeking diversification through immi-gration overseas, single family offices have been instrumental asthey are able to accord the family members this opportunitythrough employment passes, permanent residence and even citi-zenship.While the COVID-19 crisis has introduced some headwinds in op-

erationalising family offices, due to the above, we are seeing familiescontinue to press forward on their family office plans.

For over 30 years, EY Entrepreneur of The Year® celebrates theachievements of exceptional entrepreneurs in over 60 jurisdictions fortheir bold thinking and drive in the creation of products and servicesthat shape how we live, work and play. This is just one part of a long,distinctive history of EY supporting the world’s most successful en-trepreneurs while serving 80% of the world’s top 500 family enter-prises.2 With the above trends observed, and as we continue to workwith family enterprises in Asia, we are hopeful that the current “nextgeneration” will move the needle and that we see more Asian familyenterprises succeed well beyond the third generation.

1 “The Asian Family Office – Key to Intergenerational Planning”publication

2 Source: 2019 EY and the University of St Gallen Global FamilyBusiness Index


10 EXPERTGUIDES TAX

ASIA PACIFIC ATTORNEY BIOGRAPHIES

Tracy has been the Asia Pacific Business Tax Services (“BTS”) Leaderover 3 years. Before this role, she had been the Tax Managing Partnerof EY Hong Kong and Macau for more than 6 years.

She has been voted as one of the “leading tax advisers” in Hong Kongby the Legal Media Group Guide to the World’s Leading Tax Advisersin each edition since 2007. She regularly contributes articles andpresents tax seminars on latest tax development and changes.

Tracy has been a partner of 16 years and is experienced in providingtax consulting advice for conglomerates which are active in inboundand outbound investments activities. Tracy is based in Hong Kong andworks closely with her fellow partners of various EY offices outsideHong Kong in advising client’s cross border supply chain anddistribution models. Her roles on these significant engagementsincluded direct tax planning, advising on the information possiblyrequested by and assistance in explaining the business models andtransactions in question to the Hong Kong tax authorities (“IRD”).

Tracy is often approached for advice on seeking agreement with theIRD on transactions with significant tax implications. Examplesincluded – a refund claim on past withholding tax paid of overUS$60M, a deduction claim on approximately US$200M of paymentsto group companies operating outside Hong Kong, etc.

In her role of Asia Pacific Area BTS Leader, Tracy drives the relevant taxservices growth across 6 Regions – APAC FSO, ASEAN, Greater China,Japan, Korea and Oceania which covers more than 20 countries. EY isa globally connected tax planning and advisory practice. BTS combinesPrivate Client Services, Tax Policy and Controversy, QuantitativeServices, Customer Tax Operations Reporting Services, Business TaxAdvisory services enabling to provide insightful, multi-country taxadvisory services in a connected and consistent manner throughoutevery stage of the tax life cycle; planning, accounting, compliance andcontroversy.

Tracy HoEY22/F, CITIC Tower1 Tim Mei AvenueCentral, Hong KongTel: (852) 2846 9065Email: [email protected]: www.ey.com


TAX EXPERTGUIDES 11


Multilateral Instrument: Whither anefficient antidote to tax dodging

Aseem ChawlaASC Legal, Solicitors & AdvocatesNew Delhi

BackgroundMultilateral Instrument (‘MLI’) is a result of the Organization of Eco-nomic Co-operation and Development induced actions within theBase Erosion Profit Shifting (‘BEPS’) project framework. The aim ofthe measures undertaken in this project was to develop a mechanismthat would impede international profit shifts to countries applyingpreferential tax rates & assist in undertaking effective measures aimedat tightening the tax systems of the countries involved in the imple-mentation of the project. The report established fifteen areas of studywith the goal of providing the tools for counteracting tax avoidanceby organizations operating within foreign capital structures to differ-ent countries participating in the implementation of the project.

The BEPS Plan comprised the following areas: tax challenges of thedigital economy; neutralising the effects of hybrid mismatch arrange-ments; designing effective controlled foreign company rules; limitingbase erosion involving interest deductions and other financial payments;countering harmful tax practices more effectively, taking into accounttransparency and substance; preventing the granting of treaty benefits ininappropriate circumstances; preventing the artificial avoidance of per-manent establishment status; upgrading transfer pricing mechanisms;making mutual cooperation procedure more effective; as well as devel-oping a multilateral agreement under Action 15, highlighting the frame-work to achieve modification of already existing bilateral tax treaties.

Functioning and StructureAs a Multilateral International Agreement, the MLI Convention allowsfor amendments to double taxation agreements concluded by a givencountry, without the necessity of negotiating a new international taxagreement. In consequence, the MLI provi-sions envision introduction of a mechanism ofa single multilateral legal instrument that al-lows amendments to the bilateral tax agree-ments while giving some degree of flexibility tothe countries to enforce its views on the subjectmatter. The Convention has been divided inseven parts – two general ones (introductionand final provisions) as well as five detailedones (hybrid entities and instruments, includ-ing anti-double-taxation methods, abuse ofdouble taxation agreements, preventing theavoidance of permanent establishment status,making dispute resolution mechanisms moreeffective).

Paving a way for the Minimum StandardsSome provisions of the MLI reflect a minimum standard, namely inArticle 6 (Preamble), Article 7 (Principle Purpose Test) and Article 16(Mutual Agreement Procedures). As such, this can be complied within different ways. In some cases, Article 6 of the MLI itself providesfor different ways of meeting the minimum standard. If two contract-ing states to a treaty implement a minimum standard in differentways, it may give rise to inconsistencies in the tax treaty. For instance,India has expressed reservation in Article 16, Mutual Agreement Pro-

cedure (MAP), which is a minimum standardbut at the same time, it has affirmed to imple-ment MAP in a resident state, thus fulfillingthe minimum standard requirement throughimplementation of bilateral notification andconsultation process.

Concept & Efficacy of the Covered TaxAgreement Article 6 of the MLI modifies existing taxtreaties to include a preamble text that clarifiesthe purpose of the double tax treaty as notbeing solely to eliminate double taxation, but todo so without creating opportunities for non-taxation or reduced taxation through tax eva-

I N D I A

WITH GAAR ALSO INPLACE, IT WOULD BEINCUMBENT FOR THE

ENTITIES TO ORGANISEITS AFFAIRS, WITH

IMPECCABLEHOUSEKEEPING

12 EXPERTGUIDES TAX


sion or tax avoidance (including through treaty-shopping arrangementsaimed at obtaining relief provided in the tax treaty for the indirect bene-fit of residents of third jurisdictions). In terms of the latest amendmentsmade vide Finance Act, 2020, the suggestive text of the preamble nowfinds place in the Income Tax Enactment itself, with amendment ofclause (b) of sub-section (1) of section 90 of the Act so as to provide that“the Central Government may enter into an agreement with the Govern-ment of any country outside India or specified territory outside India for,inter alia, the avoidance of double taxation of income under the Act andunder the corresponding law in force in that country or specified territory, asthe case may be, without creating opportunities for non-taxation or reducedtaxation through tax evasion or avoidance (including through treaty-shop-ping arrangements aimed at obtaining reliefs provided in this agreement forthe indirect benefit of residents of any other country or territory)”.

International treaties are to be interpreted in good faith in accor-dance with the ordinary meaning to be given to the terms of the treatyin their context and in the light of their object and purpose, the modi-fication of the purpose of the tax treaty set out in its preamble mayinfluence the interpretation of the tax treaty.

Article 6 is a minimum standard for protection against the abuseof treaties. A party may, therefore, reserve the right for the text not toapply to an existing tax treaty only if that treaty already containspreamble language that describes the same intent or applies morebroadly. In the Indian scenario, Article 6, is likely to create a paradigmshift as it would render the favourable interpretation by the SupremeCourt of treaty shopping, in the case of Union Of India And Anr vsAzadi Bachao Andolan And Anr (2003) 263 ITR 0706 (SC), thereby al-lowing tax avoidance as useless. The preamble as envisioned under theMLI frowns upon the practice of tax avoidance resulting from doubletaxation avoidance.

Anti-Abuse Measure- Emergence of Principle Purpose TestArticle 7 of the MLI presents an anti-abuse provision in the form ofthe so-called Principal Purpose Test (‘PPT’). The PPT states thattreaty benefits shall be denied if it reasonable to conclude, having re-gard to all relevant facts and circumstances, that obtaining that bene-fit was one of the principal purposes of any arrangement ortransaction that resulted directly or indirectly in that benefit, unless itis established that granting that benefit in these circumstances wouldbe in accordance with the object and purpose of the relevant provi-sions of the Covered Tax Agreement.

In addition, Article 7 contains an optional Simplified Limitationon Benefits (‘SLOB’) clause, which provides that most treaty benefitsshall be denied to taxpayers other than individuals unless such othertaxpayers fulfil one of a number of criteria. The purpose of the clauseis to prevent treaty shopping by denying treaty benefits to companiesthat are not engaged in the “active & bonafide business”.

According to Article 7(15) of the MLI, a party may opt out of thePPT provision set out in Article 7(1) but only if it fulfils the minimumstandard set out by the MLI in another way, by adopting a combina-tion of a detailed Limitation of Benefit (‘LOB’) provision and rules toaddress conduit financing structures, for instance, given that a de-tailed LOB provision requires substantial bilateral customization, theMLI does not include such a provision. Moreover, a party to the MLIthat has chosen the SLOB clause may opt out of Article 7 entirely withrespect to existing tax treaties where the other contracting stateprefers to apply the PPT alone, provided that it endeavours to reach amutually satisfactory solution that meets the minimum standard.India has decided to apply PPT on an interim basis and would gradu-ally shift towards the SLOB.

PPT vis-à-vis General Anti-Avoidance Regulations The PPT provisions are similar to the General Anti-Avoidance Rule(‘GAAR’) provisions under chapter X-A of the Indian Income Tax Act,1961, and therefore a conceptual overlap between the application of thePPT and GAAR is possible. The PPT is applicable only on cross bordertransactions, whereas GAAR is applicable on both domestic and cross-border transactions. GAAR is applicable to arrangements whose taxbenefit is higher than INR 30 million but there is no monetary limit toapply PPT to transactions. Further, the key element of the PPT is “treatybenefit” which significantly varies from GAAR’s which is “tax benefit”.GAAR is invoked when the “main purpose” is to avoid tax, however,PPT shall be invoked when “one of the principal purposes” is to obtaintax benefit. It is also important to remember that invoking the PPT pro-visions to deny treaty benefits does not require the tax officer to go theapproval panel as required while invoking GAAR.

Recent Tax Ruling- Denial of Treaty Benefits The Authority for Advance Ruling (‘AAR’) in the case of Bid ServicesDivision (Mauritius) Ltd. (Applicant), a Mauritius based Companyand a subsidiary of a South African listed company, held that taxtreaty benefit under the India-Mauritius tax treaty cannot be availedas the Mauritius Company was established merely to route funds forSouth African based holding Companies.

FactsAirport Authority of India (AAI) with the approval of Government ofIndia, selected the Applicant in Consortium with other entities as ajoint venture partner to undertake development, operation and main-tenance activities at the Mumbai Airport. AAI also entered into anOperation, Management and Development Agreement with MumbaiInternational Airport Private Limited (‘MIAL’) to undertake the saidactivities at Mumbai Airport.

The Applicant entered into a Shareholder Agreement for a contrac-tual relationship with MIAL and other joint venture partners/share-holders of MIAL. As a shareholder of MIAL in the agreement, theApplicant agreed to subscribe and acquire twenty seven percent oftotal issued and paid-up share capital of MIAL. The Applicant subse-quently entered into a Share Purchase Agreement (SPA) with anotherIndian entity shareholder of MIAL wherein the applicant agreed totransfer to said shareholder, fifty percent of its stake held in MIAL.

IssueWhether the capital gains arising from the sale of shares of MIAL heldby the Applicant to another Indian entity shareholder, pursuant to aSPA would be liable to tax in India under the provision of Article13(4) of India-Mauritius tax treaty.

AAR’s RulingThe AAR noted that the Applicant served as a conduit for routingfunds for South African based holding companies. Further, the sharesof MIAL though were bought in the name of the Applicant but thebeneficial owners were the holding companies in South Africa. TheApplicant kept on noting and endorsing decisions of the holdingcompanies in the board meetings without any contribution or discus-sion about the decision-making process.

The Hon’ble AAR observed that the Applicant did not have any in-dependent infrastructure or resources and was interposed for thedominant purpose of avoiding tax in India.

The Hon’ble AAR applied the doctrine of “substance over form”and followed the observations of the Hon’ble Supreme Court in the

I N D I A

TAX EXPERTGUIDES 13


celebrated case of Vodafone International Holdings B.V. vs Union ofIndia, 341 ITR 1, held that treaty benefits should be denied, if a non-resident achieves indirect transfer through abuse of legal form andwithout reasonable business purpose, which results in tax avoidance.

In SummaryMLI has not been designed per se to impede fair business practices butwould act as a barricade to enjoying tax benefits in situations wherethe chief purpose of obtaining such benefit has been the driver(s) ofthe business arrangement. This would have consequences and wouldsignificantly affect the manner in which affairs and arrangementsgoing forward are organized by the business entities. For a businessenterprise to contest and rely upon the settled principle that the legal

effect of an arrangement must be seen through as such and accord-ingly, tax consequences would be determined, may not be the clinch-ing argument in the post BEPS/MLI world. With GAAR in place also,it would be absolutely necessary for the entity to organise its offshorecounter-part affairs, with some impeccable housekeeping.

Additionally, India has opted for PPT only for the time being andintends on gradually shifting towards the SLOB by means of bilateralnegotiations. The interaction of PPT with GAAR during the interimperiod still hinges on an unfound plain and the subjective nature ofboth might create highly contentious situations. GAAR might beviewed as being wider in terms of its coverage but it is the PPT whichactually might yield some unforeseen consequences. Clearly, we all arein for interesting taxing times!

I N D I A

14 EXPERTGUIDES TAX


Achievements & Accolades Daksha has been recognised consistently for 15 years by variousadjudging surveys as one of the top and most highly acclaimed anddistinguished tax experts in India by:

• Chambers & Partners• Legal 500• ITR- Women in Tax Leaders Guide• Euromoney publications • Who’s Who Legal • A-List of Top 100 Practitioners in India (2019) of the India Business

Law Journal

Clients benefit from her commercial and business-like approach, deepunderstanding and impeccable knowledge of tax provisions and out ofthe box thinking to provide solutions with clarity and tax risk mitigatingstrategies.

Experience & Expertise • Over 35 years of experience in advising clients, focused on providing

cross border tax solutions • Advising on global structuring & restructuring involving Indian assets • Structuring of Indian inbound and outbound mergers and

acquisitions • Working with UK, US, European, Singapore, Australian and other law

firms across jurisdictions to advise their global and multi-jurisdictional clients

• Providing solutions for employee equity based and equity linkedremuneration- domestic and cross border

• Providing succession and estate planning strategies with deepunderstating of trust structures to meet the bespoke requirements ofprivate client practice

• Providing bespoke solutions for education sector investments andtransactions

• Structured instruments for funding of investments • Structuring of resolution process for stressed assets including under

the Insolvency and Bankruptcy Code • Currently, Head of International Tax at Cyril Amarchand Mangaldas • Before that, started, headed and built taxation practice at Khaitan &

Co • Prior to that, participated in finding most innovative cross border tax

solutions at Nishith Desai Associates

Sectors • Infrastructure including specific tax advice on EPC Contracts • Financial services sector • Manufacturing sector• Real estate sector • Venture capital and investment funds industry• Digital economy sector including intangible assets & IP holding

structures• Start-ups

Daksha Baxi Cyril Amarchand Mangaldas

Peninsula Corporate Park,Ganpatrao Kadam Marg,Lower Parel, Mumbai400 013, IndiaTel: (91) 98201 87619Email: [email protected]: www.cyrilshroff.com

I N D I A

Aseem Chawla is India Bar Council member & Fellow member ofInstitute of Chartered Accountants of India and is certificate holder ofComparative Tax Policy & Administration program of HarvardKennedy School. He is candidate for “Vienna Certificate in Double TaxTreaties” under the auspices of WU Vienna University of Economicsand Business, Austria. He is also an accredited TEP, STEP, U.K.

Aseem’s experience includes advising large Indian and multinationalcorporate houses on tax matters, including international tax, inboundand outbound investment structuring, and cross-border tax issues. Hehas represented clients on tax litigation matters before variousappellate forums. He is also well regarded for estate planning,inheritance & family governance, trusts & private clients matters forhigh net-worth families.

Aseem has been consistently adjudged over the years, as one of leadinginternational tax experts in the Asia Pacific region by Chambers andPartners, Asialaw Leading Lawyers & Expert Guide surveys. He is alsoidentified by Who’s Who Legal, as a leading tax lawyer in India andfinds mention in the “World’s Leading Tax Advisors”. Aseem has beenacclaimed as an “innovator who provides creative solutions for hisclients. He is internationally recognized as an expert in the field andstands out for the first-rate counsel he delivers to clients. He impressesmarket commentators with his adept handling of contentiouscorporate tax matters, including tax appeals and related litigation.”Aseem’s name finds mention in “100 Legal Luminaries of India”published by Lexis Nexis.

Aseem is actively involved in leadership capacity at variousprofessional bodies and business chambers and is regularly invited tovarious domestic and international tax forums and industry chambers.Aseem is the Vice-Chair of the South Asia/Oceania and IndiaCommittee, Section of International Law (ABA). He is Vice Chair ofthe Task Force for Legal Services of the Confederation of IndianIndustry (CII). He is Joint General Secretary of Society of Indian LawFirms (SILF).

Aseem is visiting faculty with the Institute of Chartered Accountants ofIndia (ICAI) on international taxation & white collar crimes. He isnominated by the Government of India, as Non-ExecutiveIndependent Director on Board of one of the largest State-OwnedGeneral Insurance Companies.

Aseem’s views are often sought by print and electronic media. He hasseveral authorships to his credit including Wolters Kluwer’spublication on “A Compendium of Advance Rulings on Income Tax”. Hehas contributed in IFA Cahiers, 2013 (Annual Congress held inCopenhagen), as country reporter for India on “Exchange ofInformation”. He is lead contributory author of tax treatise, “A GlobalAnalysis of Tax Treaty Disputes”, published by Cambridge tax law series.He is currently co-author of International Bureau for FiscalDocumentation’s (IBFD) Global M&A Tax Research Platform.

Aseem Chawla ASC Legal, Solicitors &AdvocatesE-200, Greater Kailash-I110 048, New DelhiIndiaTel: (91) 11 46056282;

(91) 11 46054868Email: [email protected]

I N D I A

TAX EXPERTGUIDES 15

ATTORNEY BIOGRAPHIES ASIA PACIFIC

Dinesh is a stalwart in the industry and has over the decades beenrecognised by his peers as amongst the top tax advisors in India. Hisability to relate the business strategies of clients to the tax andregulatory environment has been recognised as unique and has playeda critical role in developing solutions for clients.

Prior to founding Dhruva, he held a series of leadership positionsacross several large professional service organisations in India. He wasthe Deputy CEO of KPMG India, Chairman of KPMG’s tax practice,Deputy CEO of RSM & Co and Head Tax and Regulatory atPricewaterhouseCoopers (PwC)

He is a member of the National Executive Committee of FICCI and isthe former Chairman of its Taxation Committee. Dinesh is currently amentor to the Taxation Committee of FICCI. He has also worked withthe Government of India on several policy committees. He was amember of the Rangachary Committee constituted by the PrimeMinister of India to deal with tax reforms in the IT/ITES sector and forevolving Safe Harbour Rules.

Dinesh KanabarDhruva Advisors1101 & 1102, One Indiabulls Centre,11th Floor, Tower 2B, 841, SenapatiBapat Marg, Elphinstone Road (West),400 013 Mumbai, IndiaTel: (91) 22 6147 1000 1900Email: [email protected]: www.dhruvaadvisors.com

I N D I A

Eric is a partner in the private client and tax team and focuses oninternational corporate tax.

His practice involves advising clients on a broad range of internationaltax planning and corporate tax advisory matters including investmentfunds, M&A, cross-border transactions, real estate investments andtechnology matters. He specializes in structuring investment fundsfocusing on the Asia-Pacific region, and has significant experience instructuring funds using a Singapore treaty platform to invest into theAsia Pacific region. Eric has advised clients in over $50 billion ofinternational corporate, real estate and private equity transactions.

In addition, he regularly advises ultra-high-net-worth individualson Japan income and inheritance tax planning and is particularlyknowledgeable in the taxation of and use of foreign trusts in regardsto Japan.

His clients include leading investment funds in the Asia region, MNCs,technology companies, and ultra-high-net-worth Japanese and foreignindividuals.

Having worked in Asia for over 20 years, he is well-versed in thetaxation of cross-border transactions across the Asia-Pacific region,involving the US, Japan, Singapore, Korea, Australia, Indonesia,Philippines, Vietnam and China.

Chambers’ Asia-Pacific guide says about him, Eric is the “well known”leader of the tax practice who is highly proficient in dealing with cross-border tax matters including tax planning. Chambers ranks him inBand 1 and Euromoney has listed him in its World Leading TaxAdvisors experts guide.

Eric is a founding member of ALTA, Asia-Pacific’s Leading Tax Advisors.

Singapore office:80 Raffles Place#25-01 UOB Plaza 1Singapore 048624Tel: (65) 6922 3726Email: [email protected]

Eric N RooseWithers12F, Toranomon Kotohira Tower1-2-8 Toranomon, Minato-KuTokyo 105-000JapanTel: (81) 3 3500 3752Email: [email protected] Website: www.withersworldwide.com

J A PA N

16 EXPERTGUIDES TAX


A trusted tax advisor

Sim Siew MoonErnst & Young Solutions LLPSingapore

I have been practicing tax for more than 35 years. My original ambitionwas to be a medical doctor so that I can take care of the well-being ofpeople. By a twist of fate, I became an accountant – specifically, a taxaccountant and advisor. My career became that of taking care of the financial well-being of businesses and individuals.

What does it take to be recognized as a trusted tax advisor? I believethe requisite attributes are largely similar to those of a trusted medicaldoctor. For every client and colleague whom I encounter in the courseof my work, I have applied my “doctor’s mindset” to attend dutifully tothem, and this is what I have done throughout my career.

Whether you are currently in a professional firm serving clients orworking in a corporate firm serving internal stakeholders, who in thiscontext, would be your internal “clients”, I do hope the following tentips would be useful to you.

Strong blend of hard and soft skills Having deep tax knowledge is not just a fundamental requirement forour profession, it is a given. Tax legislation is being introduced at a rapidpace. Hence, we must always stay on top of tax legislative changes inorder to bring the latest knowledge to apply to tax issues on hand. Thereis no room to be lax in our learnings. Keeping up to date with new taxlaws will equip all – whether the young or the experienced in the profession – with critical technical knowledge. Layering on your yearsof practical experience to help solve problems in a practical way will further set you apart as a highly skilled advisor.

I would also emphasize that you need to reinforce your soft skills likeinterpersonal skills as well as public speaking skills. You cannot portrayyourself as a technical expert if you cannot articulate what you want toconvey to your clients or stakeholders norinspire confidence for them to work with you.The ability to relate and explain tax concepts ina simple, understandable and friendly mannerwill certainly go a long way in establishing yourreputation in the market.

Empathy While we are dealing with a corporate’s taxaffairs, we are, at the heart of it, dealing withthe board, management and employees of thecompany. Apart from understanding the back-ground to the transaction or situation on hand,we also need to put on an empathy lens – whatare the circumstances surrounding the request?

Does the client need to take urgent leave and hence there is an urgencyto complete the assignment at a faster pace? Or has the client been givena tight deadline to present the findings to the management and hencewe need to work on an expediated manner to help the client deliver thework on time?

Understanding and empathizing with your client’s situation is a keyaptitude in serving our clients.

Integrity and professionalism In our day-to-day work with existing and prospective clients, we mustuphold integrity and professionalism in our services. It is important that

we must always act in an honest and ethical way. Tax is governed by a different set of legisla-

tion in each country. When you are taking aposition on the tax treatment of a transaction,it must be supportable by the tax legislation.There are times when the tax laws are not clearor appear to be equivocal. If the outcomeappears to be a showstopper for the transac-tion, always think out of the box and seek toexhaust all acceptable avenues. Do not give up,especially if the transaction is important andmaterial to your client. In such cases, with yourclient’s approval, be bold to raise the issue withthe tax authorities to hopefully reach a positiveand amicable solution. Even if the desired

AS ADVISORS, WENEED TO ENGENDER

TRUST IN OUR CLIENTSAND THE TAXREGULATORS

S I N G A P O R E

TAX EXPERTGUIDES 17


outcome cannot be reached, your client will understand that you havedone your best. I have personally worked on many situations in whicha seemingly “impossible” tax outcome was achieved after my clientstook a chance with me to pursue the “impossible”. Don’t underestimateyour ability to pursue the impossible and make a difference. Impor-tantly, you should continue to maintain integrity and professionalismas you seek to achieve these outcomes.

Analytical mindset and sound judgement An analytical mindset and the ability to process think is helpful in ourprofession. By process thinking, I mean, having the ability to not justthink about the obvious issues on hand, but also about the “invisible”issues that should be addressed, Further, the ability to make a judgementcall and to break down the issues into small steps and address the taximplications at each step to arrive at an optimal tax solution will definitely serve your clients well and position you as a preferred advisor.

Humility and mentorship Our profession is one where we are stewarded and mentored by our pre-decessors. The guidance received from our seniors has helped us to achievethe successes we have today. Therefore, be humble and modest of yourachievements and spend time to steward and mentor the next generation.

Leave a memorable legacy by coaching and mentoring the youngergenerations and this would definitely be deeply appreciated. It is notfear but joy when our juniors exceed our own abilities. This is some-thing to be proud of.

Confidence As advisors, we need to engender trust in our clients and the tax regu-lators. As such, we must be confident – not only in the quality of thework we deliver, but also in the way we hold ourselves up to our clients,the tax regulators and our team.

Work ethicOur profession is known to be one involving long hours. We must treatour colleagues with respect and we must dedicate ourselves to our workto deliver our promises to our clients.

Our work ethic must be true to our profession and to our people.While personal life is important, professional life is also equally impor-tant. How we manage our personal and professional lives and strike ahealthy balance between the two is integral to our success. I am happily

married and a mother of five children. This is testimony that you canachieve success at home and at work too.

Teaming and building relationships Our success in our profession is not solely due to our individual effortsonly. It is the collective efforts of our team that make us successful.Therefore, teaming and the ability to lead a team towards success is keyto our overall success.

Spending time to connect and invest in new and existing relationshipswith your peers and clients is a must. Building these relationships isimportant, not just to facilitate work but also to enrich your life, bothprofessionally and personally. Over the years, I have converted many ofmy business relationships into friendships and very proud that I havemany colleagues and clients whom I now regard as friends.

Business mindset I recall being asked before whether, as tax advisors, we are the equiv-alent of the “samurai” or the “merchant”. I believe we are both. Likethe samurai, we are expected to serve in a certain way that representshonour, nobility and service. At the same time, we are also like themerchant supplying services.

Stewardship Our job is to take good care of what we have, whether it is our practiceor our tax function, and leave it in a better state to the next generationthan when we inherited it. The importance of stewardship cannot beundermined.

Conclusion Finally, I urge you to dare to dream. Whether you are just starting yourcareer or in the middle of it, you must set your goal to be the best thatyou can be in your profession. Only then will you be able to achieveyour dream.

I hope my sharing is helpful in your journey to becoming a trustedtax advisor.

The writer is EY Asia-Pacific Tax Policy & Controversy Leader and Partner, Tax Ser-

vices at Ernst & Young Solutions LLP.

The views reflected in this article are the views of the author and do not neces-

sarily reflect the views of the global EY organisation or its member firms.

S I N G A P O R E

18 EXPERTGUIDES TAX


ExperienceSim Siew Moon is a Tax Partner in Ernst & Young Solutions LLP. Shewas the EY Singapore Head of Tax from July 2013 to June 2018. She hasheld the role of EY Asia-Pacific Tax Policy and Controversy PracticeLeader since January 2018.

With over 35 years of experience, Siew Moon serves multinationals andlocal clients and works regularly with various government authoritiesand regulators on tax matters. She provides tax compliance,controversy and advisory services to her clients from a broad range ofsectors. She advises her clients on structuring transactions, includingcross- border deals and mergers and acquisitions. Siew Moon alsoassists her clients in negotiating and applying for tax incentives,applying for advanced tax rulings and tax clarifications as well asdesigning and implementing tax risk management frameworks. Shehas successfully worked on numerous cases of disputes with taxauthorities throughout her career.

As the EY Asia-Pacific Tax Policy and Controversy Leader, Siew Moonworks across all tax services with the EY network of tax policy andcontroversy professionals in Asia-Pacific and globally. She helps clientsto prevent, manage and resolve their tax controversies. She also workswith the EY global tax policy network to advise governments andcompanies on developing and implementing policy initiatives.

Siew Moon is a frequent speaker at both EY and external seminars andwebinars, and contributes articles to leading tax publications on aregular basis.

CredentialsSiew Moon graduated from the National University of Singapore witha Bachelor of Accountancy (First Class Honors) degree in 1983. Shehas been awarded a certificate of completion for the Comparative TaxPolicy and Administration Program, John F Kennedy School ofGovernment at Harvard University, Executive Education. She has alsocompleted the Journey to the Boardroom Program with HarvardBusiness Publishing Corporate Learning.

Siew Moon is a Fellow Chartered Accountant of the Institute ofSingapore Chartered Accountants, a Fellow CPA of CPA Australia, andan Accredited Tax Advisor, Income Tax and GST, of the SingaporeChartered Tax Professionals.

Sim Siew Moon (Mrs. Nicole Chung)EYOne Raffles Quay North Tower, Level 18Singapore 048583Direct: +65 6309 8807Mobile: +65 8188 2977Fax: +65 6532 7662Email: [email protected]: www.ey.com

S I N G A P O R E

TAX EXPERTGUIDES 19

EXPERT LISTINGS ASIA PACIFIC

A U S T R A L I AVivian ChangAshurstSydney

Gary ChiertKPMGSydney

Michael CloughKing & Wood MallesonsMelbourne

Peter CollinsPwCMelbourne

Andrew J de WijnAickin ChambersMelbourne

John De Wijn QCOwen Dixon Chambers WestMelbourne

Kristen DeardsBanco ChambersSydney

Nathan DevesonMinterEllisonSydney

Mark FriezerClayton UtzSydney

Martin FryAllensMelbourne

Stewart GrieveJohnson Winter & SlatteryMelbourne

Clint HardingArnold Bloch LeiblerSydney

Richard HendriksGreenwoods & Herbert Smith FreehillsSydney

Lisa HespeOwen Dixon Chambers WestMelbourne

James Hmelnitsky SCSixth Floor Selborne/WentworthChambersSydney

Betsy-Ann HoweK&L GatesSydney

Prashanth KainthajeJohnson Winter & SlatterySydney

Ian KellockAshurstMelbourne

Chris KinsellaMinterEllisonSydney

Toby KnightAllensMelbourne

Amrit MacIntyreBaker McKenzieSydney

Geoffrey MannAshurstMelbourne

Peter McCulloughAshurstSydney

Carmen McElwainMinterEllisonMelbourne

Craig MilnerAllensSydney

James MomsenMinterEllisonSydney

Peter MurrayHall & WilcoxMelbourne

Andrew O'BryanHall & WilcoxMelbourne

Frank O'LoughlinOwen Dixon Chambers WestMelbourne

Michael PerezKing & Wood MallesonsMelbourne

Barbara PhairAshurstSydney

Mark Richmond SCEleven WentworthSydney

Claudio CimettaDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 3 9671 7601Email: [email protected]: www.deloitte.comSee page 4 for regional profile

James FabijancicDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 3 9671 7370Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Brett GreigDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 3 9671 7097Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Mark HadassinDeloitte AustraliaGrosvenor Place, 225 George StreetSydney, NSW 2000Australia Tel: (61) 2 9322 5807Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Greg JanesDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 414 942 589Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Vik KhannaDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 3 9671 6666Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Abs OsseiranDeloitte AustraliaGrosvenor Place, 225 George StreetSydney, NSW 2000Australia Tel: (61) 2 8260 4929Email: [email protected]: www.deloitte.comSee page 4 for regional profile

James PettigrewDeloitte AustraliaGrosvenor Place, 225 George StreetSydney, NSW 2000Australia Tel: (61) 2 9322 5656Email: [email protected]: www.deloitte.comSee page 4 for regional profile

20 EXPERTGUIDES TAX

ASIA PACIFIC EXPERT LISTINGS

Cameron RiderCorrs Chambers WestgarthMelbourne

Elissa RomaninMinterEllisonMelbourne

Ian ScottEYSydney

Rashelle Seiden SCGround Floor Wentworth ChambersSydney

Tim ShermanKing & Wood MallesonsSydney

Richard SnowdenKing & Wood MallesonsSydney

Paul SokolowskiArnold Bloch LeiblerMelbourne

Andrew SommerClayton UtzSydney

Ian StanleyWentworth ChambersSydney

James StrongOwen Dixon Chambers EastMelbourne

Judy SullivanPwCSydney

Brendan Sullivan SCTenth Floor ChambersSydney

Helen M Symon QCCastan ChambersMelbourne

Niv TadmoreJones DayMelbourne

Tom Thawley SCNew ChambersSydney

Jerome TseKing & Wood MallesonsSydney

John WalkerBaker McKenzieSydney

Eugene F Wheelahan QCAickin ChambersMelbourne

Sue WilliamsonEYMelbourne

Angela WoodKPMGMelbourne

David WoodKing & Wood MallesonsMelbourne

C A M B O D I A

C H I N AVaughn BarberKPMGBeijing

Henry ChanEYBeijing

Spencer ChongPwCShanghai

Min GuoGide Loyrette NouelBeijing

Wendy GuoPwCBeijing

Khoon Ming HoKPMGBeijing

Brendan T KellyBaker McKenzieShanghai

Lewis LuKPMGShanghai

Matthew MuiPwCBeijing

Peter NgPwCShanghai

Yongjun Peter NiZhong Lun Law FirmShanghai

Edwin WongPwCBeijing

Dennis XuHendersen TaxandShanghai

Gordon ThringDeloitte Australia477 Collins StMelbourne VIC 3000Australia Tel: (61) 3 9671 7666Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Brett ToddDeloitte Australia477 Collins StMelbourne VIC 3000AustraliaTel: (61) 3 9671 7989Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Kimsroy ChhivDeloitte CambodiaVattanac Capital Tower, Floor 8, Unit 8 #66Preah Monivong Blvd Sangkat Wat Phnom,Khan Duan Penh, Phnom Penh, Cambodia Tel: (855) 23 963 701Email: [email protected]: wwww.deloitte.com/khSee page 4 for regional profile

Vivian JiangDeloitte China30/F Bund Center 222 Yan An Road EastShanghai, 200002China Tel: (86) 21 6141 1098Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Maria LiangDeloitte China30/F Bund Center 222 Yan An Road EastShanghai, 200002China Tel: (86) 21 6141 1059Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Vicky WangDeloitte China30/F Bund Center 222 Yan An Road EastShanghai, 200002China Tel: (86) 21 6141 1035Email: [email protected]: www.deloitte.comSee page 4 for regional profile

TAX EXPERTGUIDES 21


Alan YamPwCShanghai

H O N G K O N GS A RAgnes ChanEYHong Kong

Daniel ChanDLA PiperHong Kong

Pierre ChanBaker McKenzieHong Kong

Rex HoPwCHong Kong

Tracy Ho See bioEYHong Kong

Becky LaiEYHong Kong

Ayesha M LauKPMGHong Kong

Steven R SiekerBaker McKenzieHong Kong

Grace TangEYHong Kong

Richard L WeismanBaker McKenzieHong Kong

I N D I ABijal AjinkyaKhaitan & CoMumbai

Ajay BahlAZB & PartnersNoida

Daksha Baxi See bioCyril Amarchand MangaldasMumbai

Mukesh ButaniBMR LegalNew Delhi

Aseem Chawla See bioASC Legal Solicitors & AdvocatesNew Delhi

Ketan DalalKatalyst AdvisorsMumbai

Arvind P DatarSole practitionerChennai

Nishith M DesaiNishith Desai AssociatesMumbai

Rakesh DharawatBSR & CoMumbai

Hitesh D GajariaKPMGMumbai

Hariharan GangadharanKPMGMumbai

Dinesh Kanabar See bioDhruva AdvisorsMumbai

Sudhir KapadiaEYMumbai

Hiten KotakPwCMumbai

V LakshmikumaranLakshmi Kumaran & SridharanNew Delhi

CA Amit MaheshwariAshok Maheshwary & AssociatesGurgaon

Krishan MalhotraDhruva AdvisorsNew Delhi

Julie ZhangDeloitte China12/F, China Life Financial Center No. 23,Zhenzhi Road Chaoyang DistrictBeijing, 100026, China Tel: (86)10 8520 7511Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Andrew ZhuDeloitte China12/F, China Life Financial Center No. 23,Zhenzhi Road Chaoyang DistrictBeijing, 100026, China Tel: (86)10 8520 7508Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Ryan ChangDeloitte China35/F One Pacific Place 88 QueenswayHong KongChina Tel: (852) 2852 6768Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Sarah ChinDeloitte China35/F One Pacific Place 88 QueenswayHong KongChina Tel: (852) 2852 6440Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Chris RobergeDeloitte China35/F One Pacific Place 88 Queensway Hong KongChinaTel: (852) 28525627Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Alan TsoiDeloitte China35/F One Pacific Place 88 QueenswayHong KongChina Tel: (852) 9305 6090Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Gokul ChaudhriDeloitte India7th Floor, Building 10, Tower B, DLF CyberCity Complex, DLF City Phase II,Gurgaon, National Capital Region of Delhi122022, India Tel: (91) 12 4679 2902Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Shefali GoradiaDeloitte India (Deloitte Touche TohmatsuIndia LLP)Indiabulls Finance Centre, Tower 3, 28th Floor,Senapati Bapat Marg, Elphinstone Road(W),Mumbai, Maharashtra 400013, India Tel: (91) 22 6815 3101Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Vipul R JhaveriDeloitte Haskins & SellsIndiabulls Finance Centre, Tower 3, 28thFloor, Senapati Bapat Marg, ElphinstoneRoad(W), Mumbai, Maharashtra 400013India Tel: (91) 22 6185 4190Email: [email protected]: www.deloitte.comSee page 4 for regional profile

22 EXPERTGUIDES TAX


Amit MaruEYMumbai

Sachin MenonKPMGMumbai

T P OstwalT. P. Ostwal & AssociatesMumbai

Percy PardiwalaSole practitionerMumbai

Sanjay SanghviKhaitan & CoMumbai

Pranav SaytaEYMumbai

Rohan ShahChambers of Rohan ShahMumbai

Himanshu SinhaTrilegalNew Delhi

Rajan VoraSRBC & AssociatesMumbai

I N D O N E S I APonti PartogiHadiputranto Hadinoto & PartnersJakarta

Abraham PierreKPMGJakarta

Wimbanu WidyatmokoHadiputranto Hadinoto & PartnersJakarta

J A PA NKenji AminoEYTokyo

Atsushi FujiedaNagashima Ohno & TsunematsuTokyo

Koji FujitaAnderson Mori & TomotsuneTokyo

Yushi HegawaNagashima Ohno & TsunematsuTokyo

Eiki KawakamiKojima Law OfficesTokyo

Makiko KawamuraDLA PiperTokyo

Shinichi KobayashiBaker McKenzie (Gaikokuho JointEnterprise)Tokyo

Shigeki MinamiNagashima Ohno & TsunematsuTokyo

Kazuya MiyakawaPwCTokyo

Eiichiro NakataniAnderson Mori & TomotsuneTokyo

Atsushi OishiMori Hamada & MatsumotoTokyo

Yo OtaNishimura & AsahiTokyo

Eric N Roose See bioWithersTokyo/Singapore

Koichi SekiyaEYTokyo

Ryutaro UchiyamaTokyo Kyodo Accounting OfficeTokyo

Masaharu UmetsujiKPMGTokyo

Edwin T WhatleyBaker McKenzie (Gaikokuho JointEnterprise)Tokyo

Akihiro YamadaMori Hamada & MatsumotoTokyo

M A L AY S I ANicholas CristKPMGPetaling Jaya

Goh Ka ImShearn Delamore & CoKuala Lumpur

Datuk D P NabanRosli Dahlan Saravana PartnershipKuala Lumpur

K. R. SekarDeloitte Haskins & SellsPrestige Trade Tower, Level 19, 46, PalaceRoad, High Grounds, Bengaluru Karnataka 560001India Tel: (91) 80 6188 6105Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Heru SupriyantoDeloitte IndonesiaThe Plaza Office Tower, 32nd Floor Jl. M.H.Thamrin Kav 28-30Jakarta, DKI Jakarta 10350, Indonesia Tel: (62) 21 5081 8805Email: [email protected]: www.deloitte.com/idSee page 4 for regional profile

Michael TabartDeloitte JapanMarunouchi Nijubashi Building 3-2-3Marunouchi Chiyoda-ku, Tokyo 1008362Japan Tel: (81) 5031016055Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Kwang Gek SimDeloitte MalaysiaLevel 16, Menara LGB, 1 Jalan Wan Kadir,Taman Tun Dr. IsmailKuala Lumpur, 60000, Malaysia Tel: (60) 3 7610 8849Email: [email protected]: www.deloitte.com/mySee page 4 for regional profile

Hooi Beng TanDeloitte MalaysiaLevel 16, Menara LGB, 1 Jalan Wan Kadir,Taman Tun Dr. IsmailKuala Lumpur, 60000, Malaysia Tel: (60) 1 7333 0891Email: [email protected]: www.deloitte.com/mySee page 4 for regional profile

TAX EXPERTGUIDES 23


Adeline WongWong & PartnersKuala Lumpur

N E W Z E A L A N DGeoff BlaikieEYWellington

Brendan BrownRussell McVeaghWellington

Niels CampbellSanderson WeirAuckland

John CantinKPMGWellington

Mathew McKayBell GullyAuckland

Graham MurrayBell GullyAuckland

Geof NightingalePwCAuckland

David PattersonChapman TrippWellington

Rachel PiperKPMGAuckland

Andrew RyanMinterEllisonRudd WattsAuckland

Willy SussmanBell GullyAuckland

Fred WardRussell McVeaghAuckland

P H I L I P P I N E SMa Fides A BaliliSGV & CoManila

Carlos G BaniquedBaniqued & BelloPasig City

Terence Conrad H BelloBaniqued & BelloPasig City

Emmanuel BonoanR.G. Manabat & CoManila

Fulvio D DawilanBDB LawManila

Dennis G DimagibaQuisumbing TorresManila

Benedicta Du-BaladadBDB LawManila

Euney Marie J Mata-PerezMata-Perez Tamayo & FranciscoManila

Rolando V Medalla JrSyCip Salazar Hernandez & GatmaitanManila

Eleanor L RoqueP&A Grant ThorntonCebu

Serafin U Salvador JrSalvador Llanillo BernardoManila

Mark Anthony P TamayoMata-Perez Tamayo & FranciscoManila

Priscilla B ValerRomulo Mabanta Buenaventura Sayoc &De Los AngelesManila

S I N G A P O R ESunit ChhabraAllen & GledhillSingapore

Pieter de RidderMayer BrownSingapore

Lih Jiun ThamDeloitte MalaysiaLevel 16, Menara LGB, 1 Jalan Wan Kadir,Taman Tun Dr. IsmailKuala Lumpur, 60000, Malaysia Tel: (60) 1 2376 2508Email: [email protected]: www.deloitte.com/mySee page 4 for regional profile

Allan BullotDeloitte New ZealandLevel 18 Deloitte Centre 80 Queen StreetAuckland, 1010New Zealand Tel: (64) 9303 0732Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Greg HaddonDeloitte New ZealandLevel 18 Deloitte Centre 80 Queen StreetAuckland, 1010New Zealand Tel: (64) 9303 0911Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Thomas PipposDeloitte New ZealandLevel 13 20 Customhouse QuayWellington, 6011New Zealand Tel: (64) 4495 3921Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Campbell RoseDeloitte New ZealandLevel 18 Deloitte Centre 80 Queen StreetAuckland, 1010New Zealand Tel: (64) 9303 0990Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Bruce WallaceDeloitte New ZealandLevel 18 Deloitte Centre 80 Queen StreetAuckland, 1010New Zealand Tel: (64) 9303 0724Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Richard LapresDeloitte Philippines19th Floor Six/NEO Building5th Avenue corner 26th StreetBonifacio Global City, Taguig,1634Philippines Tel: (63) 2 8581 9000Email: [email protected]: www.deloitte.com/phSee page 4 for regional profile

Alvin Noel SaldañaDeloitte Philippines19th Floor Six/NEO Building5th Avenue corner 26th StreetBonifacio Global City, Taguig,1634Philippines Tel: (63) 2 8581 9000Email: [email protected]: www.deloitte.com/phSee page 4 for regional profile

Daniel HoDeloitte Singapore6 Shenton Way #33-00 OUE Downtown 2 Singapore, 068809 Singapore Tel: (65) 6216 3189Email: [email protected]: www.deloitte.com/sgSee page 4 for regional profile

24 EXPERTGUIDES TAX


Yew Kwong LeungKPMGSingapore

Eric N RooseWithers KhattarWongSingapore

Siew Moon Sim See bioErnst & Young SolutionsSingapore

Pui Ming SohErnst & Young SolutionsSingapore

Allen TanBaker McKenzie. Wong & LeowSingapore

S O U T H K O R E ASoo-Jeong AhnYulchonSeoul

Henry AnSamil PricewaterhouseCoopersSeoul

Je Heum BaikKim & ChangSeoul

Woo Hyun BaikKim & ChangSeoul

Seok Hoon KangYulchonSeoul

Dong Soo KimYulchonSeoul

Hyeon-Jin KimShin & KimSeoul

Seung-Soon LimYoon & YangSeoul

Jay ShimLee & KoSeoul

Sai Ree YunYulchonSeoul

TA I WA N

Dennis LeeBaker McKenzieTaipei

Frank LinLee and LiTaipei

Josephine PengLee and LiTaipei

Richard WatanabePwCTaipei

T H A I L A N DKasem KiatsayrikulEYBangkok

Benjamas KullakattimasKPMGBangkok

Piphob VeraphongLawAllianceBangkok

Yupa WichitkraisornEYBangkok

V I E T N A M

Hwee Chua LowDeloitte Singapore6 Shenton Way #33-00 OUE Downtown 2 Singapore, 068809 Singapore Tel: (65) 6216 3290Email: [email protected]: www.deloitte.com/sgSee page 4 for regional profile

Michael VeltenDeloitte Singapore6 Shenton Way #33-00 OUE Downtown 2 Singapore, 068809 Singapore Tel: (65) 6216 5039Email: [email protected]: www.deloitte.com/sgSee page 4 for regional profile

Jee Won KwonDeloitte Anjin9F., One IFC, 10, Gukjegeumyung-ro,Yeongdeungpo-g Seoul, Seoul 07326, South Korea Tel: (82) 2 6676 2416Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Al ChangDeloitte Taiwan20th Floor, Nan Shan Plaza No. 100Songren Rd, Xinyi Dist, Taipei TWTaiwan Tel: (886) 2 27259988Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Austin ChenDeloitte Taiwan20th Floor, Nan Shan Plaza No. 100Songren Rd, Xinyi Dist, Taipei TWTaiwan Tel: (886) 2 27259988Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Ye-hsin LinDeloitte Taiwan20th Floor, Nan Shan Plaza No. 100Songren Rd, Xinyi Dist, Taipei TWTaiwan Tel: (886) 2 27259988Email: [email protected]: www.deloitte.comSee page 4 for regional profile

Anthony Visate LohDeloitte ThailandAIA Sathorn Tower, 23rd-27th Floor 11/1South Sathorn Road, Yannawa, Sathorn. Bangkok, 10120, Thailand Tel: (66) 2034 0112Email: [email protected]: www.deloitte.com/thSee page 4 for regional profile

Tom McClellandDeloitte Vietnam18th Floor, Times Square Building 57-69FDong Khoi Street Ho Chi Minh City, District 1, Vietnam Tel: (84) 9139 29301Email: [email protected]: www.deloitte.com/vnSee page 4 for regional profile

TAX EXPERTGUIDES 25

Austria 51

Belgium 51

Cyprus 52

Czech Republic 52

Denmark 52

Estonia 53

Finland 53

France 35, 54

Germany 55

Greece 56

Hungary 57

Ireland 57

Italy 41, 57

Latvia 59

Lithuania 59

Luxembourg 59

Malta 59

Netherlands 44, 59

Norway 60

Poland 61

Portugal 62

Romania 63

Russia 63

Spain 64

Sweden 48, 65

Switzerland 50, 66

Turkey 67

Ukraine 67

United Kingdom 67


E U R O P E

Q&A with:

Sophie Blégent-Delapille of Deloitte | Taj 31

Andrew J Wilde of Deloitte LLP, the UK Deloitte member firm 33

Features for:

Netherlands, by Wilbert Kannekens 44and Loek Helderman of KPMG Meijburg & Co

26 EXPERTGUIDES TAX

EUROPE REGIONAL PROFILE

Deloitte DCE and SpainRegional Profile

Neues Kranzler EckKurfürstendamm 23Berlin, 10719GermanyTel: (49) 30 2546801

Plaza de Pablo Ruiz Picasso 1Torre PicassoMadrid, 28020SpainTel: (34) 915145000

Website: www2.deloitte.comNumber of professionals: c.6,500

Deloitte DCE GmbH was created by the combination of the prac-tices of Deloitte Central Europe, Germany, France, Luxembourg,and Austria. Together with the practice in Spain, nearly 6,500 pro-fessionals support clients in the areas of tax and legal.

Globalization and dematerialization have deeply transformedcompanies’ economic and regulatory environment. Boundarieshave faded while tax and legal nationalisms have increased; thevalue chain has gone global while regulatory tools have remainedlocal. In an environment where economy and regulations are con-stantly confronted, Deloitte advises its clients in building tax andlegal governances, enabling them to sustainably improve their com-petitiveness.

Deloitte believes that taxation and law are essential to compa-nies’ top management. Success or failures of many key choices de-pend on their understanding, at the very heart of the operationaldecision-making process. This is why we advise our clients over thelong term so as to improve their performance by understandingtheir tax and legal issues, which support key business concerns.

All of the above practices can be delivered across the region andclose to where our clients are doing business. Our complete and bal-anced geographical coverage makes it possible to mobilize the bestresources right where our clients operate. It allows us to help ourclients the ability of our firm to select teams that are well versed inthe diversity and complexity inherent in international groups.

DCE is innovative because we have largely invested in techno-logical tools and resources in all aspects of tax and legal services.Whether our clients need automation, robotics, data analytics, De-loitte can provide a range of solutions to match the reality andcomplexity of the fast-changing environment of businesses.

Centers of Excellence in Central Europe also support local teamsin delivering global engagements, in particular in tax compliance,with consistent quality and reliability.

Our key service offeringsOur services encompass the whole range of solutions for ourclients, in the following major offerings:• Business Tax, including compliance in corporate, operating part-

nership, fund tax, high net worth and family office tax, opera-tions transformation, planning, advisory and controversyservices;

• International Tax, including compliance, advisory, and tax con-troversy services cross-border;

• Transfer pricing, including documentation, controversy and advi-sory services;

• M&A, including due diligence, transaction tax structuring, and taxtransaction execution and post-merger integration;

• Global Investments and Innovation Incentives, government grants,credits and incentives;

• Tax Management Consulting, including tax technology consulting,enterprise tax integration, and tax function strategy and opera-tions consulting;

• Business Process Solutions, including tax compliance, HR and pay-roll, financial accounting and operations, and business processtechnology;

• Indirect Tax, including compliance, operations, trade, controversy,technology and data management, and advisory services;

• Global Employer Services, including Global Mobility compensa-tion and tax, Immigration, Reward & Share Plans; and

• Legal, including Legal Advisory Services, Legal Managed Services,and Legal Management Consulting

Recent wins: • Tax management consulting is assisting with digitization of a lux-

ury multinational.• Legal Management Consulting has helped a leading financial ser-

vices company, as well as two prominent multinational leaders inthe manufacturing sector to identify their legal risks and transformtheir legal operating model.

• Tax Technology Consulting has lead the implementation of trans-formative technology tools to optimize the tax department of aprominent retail enterprise.

• Indirect Tax: assisting a leading energy company and multinationalbanking entity in the implementation of the VAT Analytics tool, atechnology that allows for high-quality and consistent analysis anddata management

Awards: Deloitte won multiple awards in the European Tax Awards by ITR in2018, 2019 and 2020.

2020• Tax firm of the year for Austria, Central and Eastern Europe,

Luxembourg• Transfer Pricing firm of the year for Austria and Spain• European Tax Firm of the Year• European Tax Compliance & Reporting Firm of the Year• European Tax Innovator Firm of the Year

D C E ( G E R M A N Y, F R A N C E , C E N T R A L E U R O P E , A U S T R I A A N D L U X E M B O U R G ) A N D S PA I N

TAX EXPERTGUIDES 27

REGIONAL PROFILE EUROPE

2019• Transfer pricing firm of the year for Austria, Baltic States, Hungary,

and overall European Transfer Pricing firm of the year • Tax firm of the year for Hungary, Central and Eastern Europe,

Luxembourg and Poland;• European Court of Justice Firm of the Year (Indirect Tax)• European Tax Compliance and Reporting Firm of the Year• European Tax firm of the Year• European Tax Technology Firm of the Year• European Transfer Pricing Practice Leader of the Year

Spain• Best Transfer Pricing Firm in Spain (International Tax Review

2018)• Best Compliance Firm in EMEA (International Tax Review 2018)• Best Tax Department in Spain (Iberian Lawyer 2019)• Best Big Four Firm by total number of transactions (Thomson

Reuters, Mergermarket, and TTR M&A League Tables)• Best Professional Patent Services Firm (Finance Monthly Global

Awards)




Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and related services. Our global network of member firms and related entities inmore than 150 countries and territories (collectively, the “Deloitte organization”) serves four out of five Fortune Global 500® companies. Learn how Deloitte’s approximately 312,000 peoplemake an impact that matters at www.deloitte.com.




28 EXPERTGUIDES TAX


Deloitte NSE Regional Profile

Deloitte NSE LLPNorth and South Europe & Middle East1 New Street Square, London, EC4A 3HQ, United KingdomTel: +44 (0) 20 7936 3000Email: [email protected]: twitter.com/deloitteuk?lang=enWebsite: United Kingdom – www2.deloitte.com/uk/en.htmlIreland – www2.deloitte.com/ie/en.htmlNetherlands – www2.deloitte.com/nl/nl.htmlBelgium – www2.deloitte.com/be/en.htmlSwitzerland – www2.deloitte.com/ch/en.htmlIceland – www2.deloitte.com/is/is.htmlNorway – www2.deloitte.com/no/no.htmlFinland – www2.deloitte.com/fi/fi.htmlMiddle East – www2.deloitte.com/ae/en.html

Offices: United Kingdom: London, Cambridge, Gatwick, Milton Keynes , Read-ing , Southampton, St Albans , Bristol , Cardiff, Birmingham , Not-tingham , Manchester, Liverpool, Leeds, Newcastle, Aberdeen,Edinburgh, Glasgow, Belfast, Jersey, Guernsey, Isle of ManIreland: Cork, Dublin, Limerick, Galway, Belfast(Nordics) Iceland: Smáratorg, Reykjanesbær, Grundarfjörður,Snæfellsbær, Akureyri, Húsavík, Egilsstaðir, Höfn í Hornafirði, Vest-mannaeyjar, Hveragerði, Neskaupstaður(Nordics) Norway: Bergen, Drammen, Fagernes, Flekkefjord, Førde,Gjøvik, Gol, Grenland, Hamar, Kristiansand, Lyngdal, Knarvik,Haugesund, Grimstad, Gran, Florø, Oslo, Sogndal, Stavanger,Steinkjer, Trondheim, Tønsberg(Nordics) Sweden: Göteborg, Malmö, Stockholm, Anderstorp, Emma-boda, Funäsdalen, Järpen, Jönköping, Kalmar, Karlskrona, Linköping,Luleå, Nybro, Oskarshamn, Smålandsstenar, Sundsvall, Umeå, Vim-merby, Värnamo, Västervik, Växjö, Åre, Östersund(Nordics) Finland: Helsinki, Tampere, Turku(Nordics) Denmark: København, Aalborg, Aarhus, Kolding, Silkeborg,Odense, Nuuk, EsbjergNetherlands: Brada, Eindhoven, Leeuwarden, Arnhem, Groningen,Maastricht, Alkmaar, Amsterdam, Hoorn, Zwolle, Utrecht, Middel-burg, Dan Haag, RotterdamBelgium: Brussels, Antwerp, Bruges, Charleroi, Ghent, Hasselt, Kor-trijk, Leuven, Liege, Roeselare, TournaiSwitzerland: Zurich, Geneva, Basel, Berne, Lugano, Vaduz, Lausanne(DCM) Italy: Ancona, Avellino, Bari, Bergamo, Bologna, Brescia,Cagliari, Catania, Chiavenna, Firenze, Genova, Milano, Napoli,Padova, Palermo, Parma, Roma, Torino , Treviso, Udine, Verona, Vi-cenza, Alba, Varese(DCM) Greece: Athens, Thessaloniki, Heraklion

(DCM) Malta: Malta(Middle East) Bahrain: Manama (Middle East) Egypt: Alexandria, Cairo (Middle East) Iraq: Erbil, Baghdad(Middle East) Jordan: Amman(Middle East) Kuwait: Kuwait City(Middle East) Lebanon: Beirut (Middle East) Libya: Tripoli (Middle East) Oman: Muscat(Middle East) Palestinian Ruled Territories: Ramallah(Middle East) Qatar: Doha (Middle East) Saudi Arabia: Al Khobar, Jeddah, Riyadh(Middle East) UAE: Abu Dhabi, Dubai, Fujairah, Ras Al-Khaimah,Sharjah(Middle East) Yemen: Sana’a

Number of professionals: NSE – 8,800 Tax & 600 Legal; ME – 500 Tax& Legal

About North and South Europe & Middle EastAs our clients operate in a more globally connected way than ever be-fore, we have been taking steps to create fewer, more integrated mem-ber firms across our global network.

In June 2017 Deloitte member firms in Belgium, Denmark, Fin-land, Iceland, the Netherlands, Norway, Sweden, Switzerland, and theUnited Kingdom combined to become Deloitte North West Europe(Deloitte NWE). A year later, Ireland joined too.

Having access to talented people with a rich mix of skills and per-spectives across different countries meant we could better serve ourclients, provide more opportunity for our people, and make a biggerimpact in the communities in which we operate.

In June 2019, Deloitte Central Mediterranean (DCM) – compris-ing Italy, Greece and Malta – joined Deloitte NWE to create DeloitteNorth and South Europe (Deloitte NSE).

On 1 June 2020, Deloitte Middle East (DME) will officially becomepart of Deloitte NSE – bringing together over 9,900 tax and legal pro-fessionals across 26 different countries (and 45,000 across all busi-nesses).

About Tax & LegalDeloitte offers clients a broad range of fully integrated tax services.Our approach combines insight and innovation from multiple disci-plines with business and industry knowledge to help your companyexcel globally.

Deloitte Legal combines market leading lawyers, consultants andtechnology experts to provide clients with new solutions to legalproblems. Enabling our clients to experience the ‘future of law, today’.

As a global tax leader today, our client’s reality is a fast-changing

N O R T H S O U T H E U R O P E & M I D D L E E A S T ( N S E & M E )

TAX EXPERTGUIDES 29

REGIONAL PROFILE EUROPE

landscape, from which new ideas, demands, and operating modelsemerge. Leading through this change and complexity is our priority.We support our clients in the most complex tax regions across multi-ple jurisdictions.

When we bring our commitment and expertise to tax and legalmatters, we make a difference to our clients, our people and society.

The Tax and Legal businesses in the Deloitte North South Europe(NSE) region have helped to drive growth across the wider firm. Withthe addition to our firm of the Middle East, which is experiencing aonce-in-a-generation economic transformation, further stronggrowth is anticipated in Deloitte NSE.

To make a difference you need to think differently. Our people arealways looking to change things for the better. We help our clients in-novate and experiment with new technologies to do just that. There isno better motivation than seeing the impact we make.

We are helping a number of clients with transformation projects,seeing their accounting systems take off into a new automated digitaltax world.

Tax is leaping forward in the digital world, using AI, automationand technology to seek improvements and clarity in compliance andadvisory offerings. As an eminent leader in tax technology, we canhelp our clients to combat the most difficult and complex issues thatarise as tax authorities move to a fully autonomous world.

Global Network – Deloitte being a large network of professional ser-vice staff all having access to knowledge and information globallyhelps us help our clients tackle the most complex of tax issues.

Skilled Workforce – Our network of over 9000 professionals use theirexpertise to help clients navigate the complexities of tax authorities,giving key insights to keep our clients businesses moving forward.

Relationships Tax Authorities – We have strong relationships withgovernment tax authorities, making it easier for clients to seek sup-port.

Our key service offerings• Business Process Solutions• Domestic Business Tax Planning, Advisory and Controversy• Enterprise Tax Integration• Fund & Partnership Tax Compliance• Global Mobility Compensation and Tax Compliance• Government Grants, Credits & Incentives• High Net Worth and Family Office Tax Compliance, Planning &

Advisory• Immigration Services• Indirect Tax Compliance and Advisory• International Tax Compliance, Advisory and Controversy• Legal Managed Services• Legal Management Consulting • Legal Advisory Mobility Advisory, Technology and Analytics• M&A Tax Services • Mobility Advisory, Technology and Analytics• Reward, Employment Tax, and Share Plans Compliance and Advi-

sory• Transfer Pricing Documentation, Controversy and Advisory• Tax Function Strategy and Operations (TMC)• Tax Technology and Data Management• US multistate taxes

Recent wins: Our UK Indirect Tax team won an engagement for the sale of the De-loitte SIGNAL product to help a multinational ride-hailing companynavigate the COVID-19 environment.

One of the leading innovators and providers of advanced air con-ditioning solutions has engaged Deloitte in a five-year contract cover-ing T&L, GTCE, Consulting, FA & Risk Advisory services.

Deloitte NSE have won an opportunity with the largest musicstreaming service to implement benchmarking in 13 regions, includ-ing Europe, Americas, Asia Pacific and Japan, to support global trans-fer pricing documentation. This is a great example of cross-geographywinning as relationships in a number of NSE geographies led to thesuccessful securing this contract.

Awards: 2020: Tolley’s Tax Awards – Best Indirect Tax/VAT Tax Practice2019: ITR European Tax Firm of the Year 2019: ITR European Tax Compliance & Reporting Firm of the Year2019: ITR Tax Firm of the year in Switzerland, Denmark, Finland,Malta2019: ITR Transfer pricing firm of the year Switzerland, Ireland 2019: ITR Tier 1 for status for Tax, Transfer Pricing and Tax Contro-versy in Belgium2019: ITR European Tax firm of the year2019: ITR European Tax Technology firm of the year2019: ITR European Tax compliance and reporting firm of the year2019: ITR European Transfer Pricing practice leader of the year

Eminent Leaders:

Geographic LeadersNSE & UK: Matt Ellis, managing partner for Tax and Legal for De-loitte UK and for Deloitte North and South Europe DCM & Italy: Alessandro LualdiDeloitte Middle East: Nauman AhmedNordics & Denmark: Niels JosephsenBelgium: Tom DeclercqCyprus: Pieris MarkouFinland: Lari Hintsanen Greece: Maria TrakadiIceland: Bjarni Thor BjarnasonIreland: Lorraine GriffinMalta: Marc Alden Netherlands: Willem BlomNorway: Rolf SaastadSweden: Frida HaglundSwitzerland: Reto Gerber

Clients & Industries LeadersAndy Wilde – Deloitte NSE C&I LeaderBas Castelijn – Netherlands C&I LeaderMichele Crisci – DCM C&I LeaderMartin Krivinskas – Switzerland C&I LeaderAlex Law – Middle East C&I Leader Karolien Martens – Belgium C&I LeaderVincent McCullagh – Ireland C&I LeaderFernand Rutten – Belgium C&I LeaderRichard Williams – UK C&I LeaderSara Stentz Zahle – Nordics C&I Leader


30 EXPERTGUIDES TAX








TAX EXPERTGUIDES 31

Q&A EUROPE

Q&A with Sophie Blégent-DelapilleTax & Legal leaderDeloitte | Taj

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?The OECD and the European Union have imposed new standardsof tax transparency, which require proof that the tax paid corre-sponds to the rate applied in the country in which the company op-erates. These new standards challenge the finance departments andtheir CFOs, which must communicate to tax administrations muchmore precise and consolidated tax data on larger volumes.

Therefore, the most significant development is linked to our ca-pabilities in advising large companies to deal with the technologytransformation of the tax environment, inhouse and with externalstakeholders: use of smart data, implementation of new digital plat-forms and tools, automation of information sent on line to the taxauthorities, big data compliance obligations.

What was the most notable effect of that change?We have had to onboard and train new talent profiles, much morehybrid than before, in addition to the skilled and knowledgeable taxand legal professionals.

We now also employ engineers, consultants, robotics specialistsand our member firms all have new support functions such asChief Technical Officers, Chief Digital Officers, Innovation man-agers. Moreover Deloitte is globally implementing a new revolutionin terms of digital platform to produce compliance worldwide, setup a digital collaborative workspace with our clients, and offer newadvisory use cases leveraging on innovative digital tools. The visionneeds to be implemented in a way that allows not only technical de-ployment but also to re-imagine most of our processes as advisors.

Where is the market moving in this practice area?Our Tax Management Consulting and Legal Management Consult-ing practices see a vast field of opportunities as clients need to con-stantly be more agile (to face crisis like the present Covid 19depression), competitive and upgraded to face the new pace oftechnology changes imposed by the Administrations. More andmore large multinationals request end to end advice, ranging fromstrategic definition of their transformation needs, benchmarks withbest in class organizations and ability to improve their maturitymodel, to the actual implementation of tools and new processes.

We also note clients (especially under the influence of the USmarket) contemplating to ask for a full “operate” service, i.e., hav-ing their service provider take on board talent (versus in-house em-ployees) to carry out a vast range of compliance tax and legalactivities.

What kind of impact will this have on your work?Deloitte, in DCE and in Spain, but more generally in all of Europe,has a very strong advisory practice, based on eminence, excellence

and a vast range of professionals with deep knowledge. Interveningin the Management Consulting area, whether tax or legal, requiresto be even more a business partner to our clients, and discuss thekey aspects of the service not only with the tax and legal specialistsin-house, but also with other key stakeholders such as head of IT,head of Finance, Corporate Governance officers, and more gener-ally business leaders who want to make sure that tax and legal en-ables and augments the way of doing business. Therefore, ourprofessionals are capable of embracing the diversity of profiles andteam with clients as never before.

DCE and Spain member firms have also had to determine thebest ways of building the new digital tools, with mainly four alter-natives, which are not exclusive one from the other: partner withexternal IT companies, work with the Deloitte central IT teams,hire in-house technology specialists (within our services lines suchas legal, TMC, global mobility tax etc.), and with innovative De-loitte groups (Digital Factory, the Garage etc.) stemming from ourbest in class Consulting and Advisory practices, who work forclients and for our Tax and Legal teams.


32 EXPERTGUIDES TAX

EUROPE Q&A

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?We can clearly anticipate that there will be changes in the tax regula-tions. All governments will be facing a double challenge: on one hand,finding resources to finance huge expenses derived from COVID-19.Increase of taxes can easily reach this objective, as well as a trend toprotectionism (Customs Duties). The fight to attract taxation betweenthe countries with large company headquarters and the countrieswhere the customer base resides will lead to a frenzy of antagonistlaws which will trigger double taxation.

On the other hand, such an increase needs to be balanced to allowbusinesses to get back to the activity, to invest and not to suffer fromthe tax burden. In this respect, we can expect for example change inthe rule of offsetting tax losses. Government will more than ever scru-tinize the adequacy of transfer pricing rules.

How would you describe the tax controversy landscape in yourregion/jurisdiction?The tax controversy landscape in our region has clearly increased dur-ing the last decade. There are more and more claims and litigationsregarding taxes due to the speed over which tax provisions areadopted, in order to respond to the public opinion or budget needs,and constraints of EU legislation. Numerous tax provisions are beingchallenged by the EU court, here again, often due to new tax provi-sions enacted by local Member States Governments & Parliamentswithout taking time to analyse all the consequences.

In addition to the increase of cases, we have also noted an in-creased level of aggressiveness in the way discussions are conducted.Less inclined to discuss a balanced solution, the Tax Authorities keeptheir position due to the government pressure, which leads to an in-creased level of tax controversy in front of the Courts.

Do you expect tax procedures in your region to move towardscommon standards or diverge in the future?We expect some degree of convergence due to the EU reforms andcommon goal to confirm that companies apply sustainable tax poli-cies. The various CBCR and Mandatory Disclosure Rules apply to allEU companies in a similar way. However, same as SAF-T in its time,the wish to common standards, leading to common procedures, isoften contradicted by the will of Member State governments to im-pose their own local specificities.

Is the global drive towards regulation going to affect taxpractice? If yes, in which areas?Our tax practices now have common foundations in technical skillsand can to some extent advise companies around the entire region.However, as noted above, as long as States consider tax as a differ-entiator to improve either competitiveness or warrant protection-ism, local domestic knowledge will be needed, and I don’t see thischanging in the foreseeable future.

What do you see as direct impact of COVID-19 in yourpractice?There are several direct impacts to our practices in our Region:

Some areas of practice, such as M&A, have experienced a suddendecrease, however we anticipate that some strategic buyers and PrivateEquity Houses will be keen to look at targets available at low marketprices. However, the need to have visibility on performance will prob-ably mean a slow recovery generally, mid-2021. Similarly, large com-panies have deferred any large reorganization, which was consideredas “non-essential”. Our clients indicate that these transformation andreorganization plans will pick up this summer or in the fall.

The other practice areas are much more resilient.Some practices will thrive, as the world gets a wakeup call to

“too much” globalization, many groups are exploring a more re-gional approach to industrial relocations. The crisis is sanitary butalso accelerates the focus on the imperious need to be more sus-tainable for the planet. As a result, “short circuits” will be analysedcompared to manufacturing products on the other side of theplanet. These strategic changes are complex, and complexity re-quires to carefully analyse the tax and legal consequences, thereforeour practices anticipate many areas to assist our clients.

The crisis has also accelerated digital economy. Pre-Covid, thedigital taxes were already a significant focus point at the level of Eu-ropean governments, to align an old fashion tax system to the neweconomy and get tax payments in a more efficient way in their view.

As mentioned, we can expect that governments will increasetheir tax audits to finance their deficits. Courts are just starting toreopen, tax litigation will pick up after a 2 months full stop.

One can also expect that the need for tax transparency and sus-tainability will increase: we expect that governments will pressurecompanies to explain/justify how they contribute to the resourcesof the countries where they carry out their activities.



Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and related services. Our global network of member firms and related entities inmore than 150 countries and territories (collectively, the “Deloitte organization”) serves four out of five Fortune Global 500® companies. Learn how Deloitte’s approximately 312,000 peoplemake an impact that matters at www.deloitte.com.





TAX EXPERTGUIDES 33

Q&A EUROPE

Q&A with Andrew J WildeInternational Tax partnerDeloitte LLP, the UK Deloitte member firm

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?Across the entire NSE & ME practice, we’ve seen two major changes –around both technology/digitisation and a related change in the im-pact of that on the legal market.

The increase in technology enabled and digital tax offerings is theresult of responding to legislative change and to reflect the changingneeds of clients in the light of COVID-19. The most significant in ourinternal practice has been in the growth of Deloitte Legal (which sitswithin our Tax & Legal practice), and in particular the decision togrow Deloitte Legal in the UK.

Deloitte Legal combines market-leading lawyers, consultants andtechnology specialists to provide clients with new solutions to legalproblems, for example by providing assistance in harnessing the con-siderable benefits created by advances in legal technology.

What was the most notable effect of that change?With the growth of Deloitte Legal in the UK, we now have the capa-bility to help clients transform how they access legal advice and im-plement regulatory changes as a result. As a result, we can now offerboth traditional legal support but also new end-to-end solutions thatincorporate both our legal advice and the ability to implement any re-quired transformation within the organisation.

Where is the market moving in this practice area?Multinational groups are currently operating in a period of un-precedented change. Today’s international tax teams need access topractical solutions to manage this change encompassing technologyand best practice, while balancing against available resources. Taxteams are having to juggle implications of international tax reforms,Brexit, increased regulations and reporting requirements alongsideinternational growth agendas while keeping on top of their compli-ance obligations.

Similarly, in the legal market, there is a constant drive for organisa-tions and their in-house legal teams to do ‘more for less’ and clientsface the dual complexities of a heightened regulatory environmentand an increasingly globalised business landscape. This means thatGeneral Counsels and other buyers of legal services must considermore cost-effective ways of accessing support other than the tradi-tional way of instructing external lawyers who charge by the hour butalso consider how a broader set of skills can be helpful to plan for andrespond to regulatory change. We feel this is better achieved throughmulti-disciplinary practices like Deloitte than traditional law firms.

What kind of impact will this have on your work?The rise of technology and the broader digitisation of tax has affordedour tax practice significant opportunities. It has also presented somechallenges, such as thinking differently about our current and future

talent pool, and the shape, size and model of our own business. This willalso be a challenge for clients. Automating a number of ‘traditional’ taxor legal services which thereby reduces costs/offers savings to organisa-tions means we have to think differently about value articulation, pricingtransparency and how our tax practice needs to adapt to remain relevantand profitable. The market impact here is most significant around legalservices where technology had been under-deployed generally.

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?As a result of the COVID-19 crisis, there is a strong likelihood that wewill see a significant increase in taxes across the region. Governmentshave been supporting their economies but at some stage someone willneed to pick up the bill. We will continue to see an environmentwhere states spend more on health and social care, amidst an in-creased burden of public debt as a result of the crisis. Whilst it is diffi-cult to predict precisely how the tax burden may increase, systems willneed to adjust to cope as a result and we expect to see significant leg-islative change. Already we see a part of our region–the Middle East–where the largest economy has significantly increased consumptiontaxes.

If these come into force, how will the industry look in the future?With increased digitalisation of national revenue systems, which willbecome more sophisticated, clients will need more support to address


34 EXPERTGUIDES TAX

EUROPE Q&A

how these changes are accommodated and administered. Digitisationwill be critical in helping us and our clients respond to these increaseddemands.

How would you describe the tax controversy landscape in yourregion/jurisdiction?For the most part, across our region it remains quite complex. In terri-tories where there are developed regulatory bodies, we’re seeing an in-crease in tax disputes. The impact of this means clients need specialistsupport to help them through these challenges. This is a highly com-plex, high risk but high value area of work for advisers and we have amarket leading suite of services designed to support clients at all stagesof the controversy lifecycle from pre-dispute through to litigation.

Do you expect tax procedures in your region to move towardscommon standards or diverge in the future?As a result of the work being undertaken by OECD, around Pillar 1and 2, we do expect more common standards being introduced acrossthe region. However, the COVID-19 crisis is also likely to see coun-tries taking a national approach, implementing specific domesticmeasures in order to offset the debt arising from the pandemic.

Is the global drive towards regulation going to affect taxpractice? If yes, in which areas?Tax authorities, the OECD and others are all driving towards in-creased real time reporting, transparency and disclosure resulting in

more companies needing to be transparent about their tax affairs.Whilst the business community and general public at large are likelyto have greater visibility of organisations’ tax affairs, this does not nec-essarily translate to an increase in understanding or appreciation ofthe role tax plays within an organisation and its contribution to soci-ety. This will likely mean that more challenge is placed on businessesto explain their tax affairs to tax authorities and stakeholders moregenerally and they will need support in doing that.

What do you see as direct impact of COVID-19 in your practice?We are seeing a shift of activity to those projects which can conserveor yield cash for the business. We are also seeing some acceleration ofcompliance work to make sure companies satisfy their complianceobligations despite the resourcing challenges at present. Legal services,employment law, distressed transactions/restructuring,refinancing/cash flow/liquidity are areas in which we’re seeing anuptick. Industries are being impacted, with both negative and positiveeffects on sectors within. More so now than ever we recognise theneed to stay close to our clients, to help them navigate the respond,recover and thrive stages. We’ve innovated and are developing ways toengage and interact with clients through virtual workshops andGreenhouse Lab propositions, as well as thinking differently to howwe share content with our clients and the external market. Traditionalface-to-face large-scale conferences are being replaced with smaller,community based, targeted virtual round table discussions, using arange of different technologies to ensure the best client experience.







TAX EXPERTGUIDES 35

ATTORNEY BIOGRAPHIES EUROPE

Christophe Aldebert joined CMS Francis Lefebvre Avocats in 1989 andwas co-opted as an equity partner in 2000. He specialises in indirecttaxation: VAT, payroll tax and Organic (French pension and disabilityinsurance).

He regularly assists major national and international groups in thebanking, real estate and industrial sectors and in their M&A andrestructuring operations, and also advises several local authorities andprofessional bodies. He has particular expertise and experience inlitigation matters before French administrative courts and the Court ofJustice of the European Union.

Christophe is a lecturer at the University of Paris II (Panthéon – Assas)and at the University of Montpellier. He regularly participates asspeaker at several conferences. He is a member of the InternationalFiscal Association (IFA) and of the MEDEF (French Confederation ofBusiness Enterprises) Tax Committee.

He holds a post graduate degree in Business Law from the Universityof Montpellier (DJCE) and besides he has been top of his year for aprofessional tax law specialisation certificate.

Christophe AldebertCMS Francis Lefebvre Avocats2 rue Ancelle92522 Neuilly-sur-Seine France Tel: (33) 1 47 38 55 82Email: [email protected]: www.cms.law

F R A N C E

Stéphane is a tax partner at CMS Francis Lefebvre Avocats since 2007.He coordinates the tax litigation and controversy group of the firm ondomestic and international tax issues. He headed the CMS tax practicegroup from 2009 to 2014.

Stéphane graduated in political sciences from the Paris Institute ofPolitical Studies (Sciences Po) and attended the ENA, the Frenchcollege for top government officials, from 1991 to 1993. He has spent15 years in top positions within the French government. He is a formermember of the State Council (France’s highest administrative court)and was also adviser on tax policy to the Minister of Economy, Financeand Industry from 1997 to 2000. He was financial counsellor at theFrench embassy in Japan from 2003 to 2007.

Stéphane is a recognised expert in handling high-profile tax litigationbefore domestic courts, including France constitutional court, andinternational courts such as the ECJ or the ECHR. He also hasextensive experience on international taxation and the interpretationand application of tax treaties.

He teaches tax law and tax litigation at Sorbonne Law School(University Paris I Panthéon-Sorbonne) and is a regular speaker inconferences and seminars. Stéphane has also written many articles ondomestic and international tax issues in tax reviews published inFrench, English and Japanese.

He is a member of the board of the French branch of InternationalFiscal Association (IFA) and of the organisation representing taxlawyers in France (IACF), that he headed between 2014 and 2017. As amember of the International Tax Group (ITG), Stéphane belongs tothe editorial advisory board of International Tax Law Reports (ITLR).

He has been ranked Tax Lawyer of the Year 2010 in France by BestLawyer. He is ranked each year among the leading individuals in taxlitigation in France by Chambers and Legal 500.

A French native speaker, he is fluent in English and speaks someJapanese.

Stéphane AustryCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 55 59 Email: [email protected]: www.cms.law

F R A N C E

36 EXPERTGUIDES TAX

EUROPE ATTORNEY BIOGRAPHIES

Michel is a partner within the tax department. He began his career in1993 at the firm’s corporate tax group, before joining Linklaters in2000 (Paris and London). Following his return to CMS FrancisLefebvre Avocats, Michel chaired the tax practice in the New Yorkoffice from 2002 to 2007.

Michel advises on merger and acquisition, cross-border restructuring,corporate finance and real estate. He is acting for multinationals, funds(including sovereign), financial institutions. He advises high-net-worth individuals for international planning (including internationalsportsmen and artists). He is also active in litigation and audits.

Michel represents l’Association Française des Fiduciaires for tax mattersrelating to fiducies. He is also the international organisations liaison(Europe) of the tax committee for the IBA. In addition, Michel is anactive member of the American Bar Association (ABA), theInternational Bar Association (IBA), the International FiscalAssociation (IFA) and the Tax Review.

Michel was a member of the European Commission’s Growth 2020programme, set up by the finance minister for proposing reforms tofoster the growth in France. He was the co-reporter for France at the2010 annual IFA conference on “tax treaties and tax avoidance:application of anti-avoidance provisions”. He is a former officer of taxcommittee of the IBA (2010-2011); former co-chair of theinternational tax committee of the international law committee of theNew York State Bar Association (NYSBA) (2007); former member ofthe steering committee – New York branch of the IFA; and formerchair of the carbon finance working group of Paris (Europlace).

Michel regularly writes articles in Tax Note International, Euromoneyand French publications such as Les Echos. He frequently appears inmedia and professional publications in France and abroad.

Michel seats on the Board of the Association Ecole Jeannine Manuel. Heis also part of the admission jury to Science Po within the Programmededicated to students living in socially deprived areas (Conventiond’Education Prioritaire).

He used to be a lecturer on international/European taxation andcorporate tax at Paris Dauphine University from 1998 to 2000.

Michel holds a postgraduate degree in international tax law from theUniversity of Paris XI/HEC. A French native speaker, he is also fluentin English.

Michel ColletCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 55 21 Email: [email protected]: www.cms.law

F R A N C E

Agnès joined the tax department of CMS Francis Lefebvre Avocats in1995 after five years at Ernst & Young. Specialising in internationaltaxation, she handles cases in corporate taxation focused oninternational tax planning (intra-group flows, tax treaty optimisation,transfer pricing), M&A and reorganisations, tax structuring ofcomplex international contracts, and international compensation ofexecutives.

She works primarily for French companies, advising them in theirinternational expansion. For four years she was based in São Paulowhere she gained strong experience in dealing with Franco Brazilianand Latin America matters. Since then, she regularly advises Frenchgroups regarding their projects in emerging countries including Indiaand China.

She is a member of the International Fiscal Association (IFA) and theInternational Bar Association (IBA). She is also a French foreign tradeadviser (CCE), is the co-head of the international tax committee of theCCE and heads the CCE working group on Brazil taxation. She is aspeaker at many international tax conferences and regularly publishesin French tax reviews.

She holds a master’s degree in business law and taxation from theUniversity of Paris II – Assas (1990) and graduated from the ParisInstitute for Political Sciences (1988). A French native speaker, Agnèsspeaks Portuguese and Spanish in addition to English.

Agnès de l’Estoile-CampiCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 56 63 Email: [email protected]: www.cms.law

F R A N C E

TAX EXPERTGUIDES 37


Pierre-Jean joined CMS Francis Lefebvre Avocats in 1986. He formerlyhas been with Coopers & Lybrand (1981-1984) and Ernst & Whinney(1984-1986). He specialises in transfer pricing and private clients,having 30 years’ experience in those areas, with the invaluable supportour firm’ team of 10-plus economists. His other practice areas arecross-border transactions, including M&A, financing, refinancing,restructuring, financial leasing, and European and internationaltaxation.

His second area of expertise is private clients: legal and tax regimes,including family law (international aspects), immigration law, assetsprotection, wealth transfer techniques, inheritance, assets protectionand separation of assets, matrimonial status, real propertyinvestments, trusts impacts within civil jurisdictions, tax auditprotection and litigation.

Pierre-Jean is a member of the Institute for Tax Advisers (IACF), theInternational Fiscal Association (IFA) and the International BarAssociation (IBA). He is also the honorary vice president of the trustscommittee of the IBA.

He is a lecturer on international taxation at the University of Paris II –Assas and also a speaker at conferences on topics such as transfer ofdomicile, trusts and assets reorganisation. He is the author of severalpublications edited by the IBFD, including 20 files of internationalcases published by Litec, The Regime of Partnerships and The Regimeof Permanent Establishments, as well as others (published, forexample, by Editions Francis Lefebvre and Pedone) in English andFrench (e.g. Monaco Tax and Legal Guide and Transfer Pricing). Heregularly contributes to reference books on International TransferPricing. He is a correspondent for the International Transfer PricingJournal.

Pierre-Jean is domiciled and based in Monaco where he has a licenceof counsel in international taxation.

He holds a master’s degree in business law from the University of ParisII Assas (1981) and is a graduate from the ESLSCA Business School(1979). A French native speaker, He speaks English and Germanfluently, as well as Italian.

Pierre-Jean DouvierCMS Francis Lefebvre Avocats2 rue Ancelle92522 Neuilly-sur-Seine France Tel: (33) 1 47 38 56 76 Email: [email protected]: www.cms.law

F R A N C E

Richard joined CMS Francis Lefebvre Avocats in 1988. He chaired thefirm’s advisory board from 2009 to 2012. He is an expert in Frenchtaxation and mainly manages cases in related to corporation tax, realestate and finance taxation (for French and international listed andnon-listed companies); personal income tax; tax systems for semi-public companies and local authorities.

Richard is also specialised in tax litigation and in tax penal claims. Inthis context, he and his team have spent many years assisting severalgroups, companies and their key individuals, in tax dawn raidprocedures (section L 16B of the French tax code) and in tax criminalprocedures; as a tax litigation lawyer, he also regularly pleads(including in criminal tax). Richard has a long-standing workingrelationship with French tax administration as an expert of thosematters.

Richard regularly publishes articles in specialised publications. He is alecturer at the Universities of Paris I (Panthéon-Sorbonne), Sophia-Antipolis and Montpellier. He is also a member of the Tax LawyersInstitute (IACF) and of the French Association for Corporate LegalAdvisers (ACE).

Richard holds a postgraduate degree in business law from theUniversity of Montpellier (DJCE). A French native speaker, he is fluentin English.

Richard FoissacCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 40 25 Email: [email protected]: www.cms.law

F R A N C E

38 EXPERTGUIDES TAX


Stéphane joined the tax department of CMS Francis Lefebvre Avocatsas a partner in June 2003. He has been advising French and foreignmultinationals in the area of international tax and transfer pricing for30 years. He has been involved in several significant projects ininternational restructuring, global transfer pricing planning, supplychain projects, French and foreign transfer pricing documentation andinternational controversy (including competent authorities,arbitration procedures and APAs). He heads the CMS tax practicegroup and is a member of the Supervisory Board of the CMS FrancisLefebvre Avocats.

Before joining the firm, he was a tax partner with Ernst & Young wherehe headed the French transfer pricing practice and was a member ofE&Y global advisory committee for transfer pricing. He spent fiveyears in New York at the international tax services of the firm, wherehe was responsible for the French tax desk, assisting French and USclients involved in cross-border transactions.

Stéphane was the national reporter for the e-commerce topic at the2001 IFA Congress and a panellist at the 2007 IFA Congress on CostSharing Agreements. He was a “special witness” during the 2012 IFAConference in Boston concerning the OECD transfer pricing report onintangibles. He is a board member of the Chartered Institute ofTaxation, European branch.

He is a frequent contributor to various French and international taxjournals. He has co-authored three books on transfer pricing: Prix deTransfert, Editions Francis Lefebvre (2016); Guide to InternationalTransfer Pricing, Kluwer (2011); and Transfer Pricing Manual,Bloomberg BNA (2008). He lectures on transfer pricing at theUniversity of Burgundy in Dijon. He co-developed, for the CharteredInstitute of Taxation, the transfer pricing syllabus for the advanceddiploma in international tax and teaches at the exam preparationcourse. He is a Permanent Member of the editorial board of TaxManagement International Forum, Bloomberg BNA.

Stéphane graduated from the Paris Institute of Political Studies in 1986and obtained a Maîtrise and a DESS in business and tax law from theUniversity of Paris V (1985). A native French speaker, he is also fluentin English.

Stéphane GelinCMS Francis Lefebvre Avocats2 rue Ancelle92522 Neuilly-sur-Seine France Tel: (33) 1 47 38 44 00Email: [email protected]: www.cms.law

F R A N C E

Bruno Gibert joined CMS Francis Lefebvre Avocats in 2001. Hespecialises in international taxation, with a particular focus on transferpricing matters. On this last domain, he heads the transfer pricinggroup of CMS.

He has 16 years’ experience in the government service, where he was incharge of international tax affairs (negotiation of tax treaties withforeign countries, OECD and EU work, and competent authority). Heused to be co-chairman of the OECD Forum on Harmful Tax Practices(1996 to 2001). Chairman of the EU Joint Forum on Transfer Pricingsince 2002, he also chairs the French Branch of the International FiscalAssociation (IFA) and the Tax Committee of the Club des Juristes(French Lawyers Club).

In 2015, he has been appointed by the French government as anindependent person of standing for the EU arbitration convention.

He is the author of a report to the French government on tax securityin France in 2004 and co-author of two other reports to the Frenchgovernment, one on intangible assets (2006) and one on how toimprove the commentary on French tax law (2010). He is also the co-author of the chapter on rulings of a book on French tax procedures(published in 2005 and updated in 2008), a book on transfer pricing inFrance (Ed F Lefebvre, 3rd edition 2016) and the author of the chapteron France of the book Transfer Pricing and Dispute Resolutionpublished in 2011, last edition 2017, and of the chapter on the mutualagreement procedure of a book on the OECD Model Convention (Ed.Francis Lefebvre 2013). He regularly publishes articles on internationaltax matters in French and international publications.

After graduating in political sciences at the IEP Paris (Sciences-Po) in1979, Bruno completed his education with a Master in corporate andtax law at the University of Paris II (Assas) before entering the ENA. AFrench native speaker, he is fluent in French and English.

Bruno GibertCMS Francis Lefebvre Avocats2 rue Ancelle92522 Neuilly-sur-Seine France Tel: (33) 1 47 38 42 19 Email: [email protected]: www.cms.law

F R A N C E

TAX EXPERTGUIDES 39


François Hellio joined CMS Francis Lefebvre Avocats in 1990. From1993 to 1998 is worked at the Berlin office of the firm and became apartner in 2001. From 2009 to 2012, he was a member of the firm’sAdvisory board. He is specialised in tax matters in connection withinternational and domestic acquisitions and restructurings, and also intransfer pricing. He is currently a co-ordinator of the CMS Franco-German desk.

François is a regular author of various articles about internationaltaxation in French and international publications (German or Swissnotably). Examples include: co-author of the French tax part of a bookpublished in Germany on international aspects of the SocietasEuropaea (SE), Jannott/Frodermann (CF Müller-Verlag, 2014); co-author of the France dedicated chapter of Mennel-Förster, a referencework on international taxation in Germany (NWB-Verlag, 2012).

He teaches at the Universities of Strasbourg and Vienna (LLM ofinternational taxation). François studied at the French business schoolHEC (1988) and graduated at the University of Panthéon-Sorbonne inParis (1992).

A French native, François is fluent in English and German.

François HellioCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 40 62Email: [email protected]: www.cms.law

F R A N C E

Lionel joined the firm in 1989, and was co-opted as Equity Partner in1997.

He is part of the firm’s tax department, where he is an expert in directtaxes. As such, he manages mainly files in the following subjectmatters: taxation of national and international mergers andacquisitions, restructurings; tax integration structures, real estatetaxation and taxation of financial products (banking and insurancesectors). He also deals with litigious matters.

Lionel is an active member of the Institut des Avocats Conseils Fiscaux(IACF) and Association Française des Avocats Conseils d’Entreprises(ACE).

He regulary writes articles on tax law. ( in Droit Fiscal) He has, forexample, participated to the Mémento Groupes de sociétés 2018-2019,published by Editions Francis Lefebvre.

He holds a postgraduate degree in Tax Law (Paris II, 1980). He is aLecturer in Tax at the University of Paris I (Panthéon-Sorbonne).

A French native, Lionel is also fluent in English.

Lionel LencznerCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 41 66 Email: [email protected]: www.cms.law

F R A N C E

40 EXPERTGUIDES TAX


Edouard is a partner of CMS Francis Lefebvre Avocats, practising inthe tax group. From 1994 to 2000, he practised in the firm’s New Yorkoffice which he became a member in 1997.

He advises tax aspects of transactions (mergers and acquisitions,private equity transactions and corporate restructurings) with a focuson cross-border transactions, tax audits and controversies, andrelocation of activities to France. He is acting for multinationals,partnerships, financial institutions and high-net-worth individuals.

Edouard is a member of the International Fiscal Association (IFA), theInternational Bar Association (IBA), the American Bar Association(ABA), the French Association for Corporate Legal Advisers (ACE) andthe French Tax Lawyers Institute (IACF).

He has contributed to OECD publications and published articles in theJournal of International Taxation and the Tax ManagementInternational Journal. He was the co-reporter for France at the 2009annual IFA conference, “Is there a permanent establishment?” and theauthor of the Business Operations in France portfolio, published byTax Management. He is a regular speaker in international taxconferences.

Involved in the not-for-profit world, Edouard is a board member ofUnited Way L’Alliance which focuses on education.

Edouard holds a master’s degree in business administration, financeand taxation, and received his postgraduate degree in business taxationfrom the University of Paris IX Dauphine. A French native speaker, heis fluent in English.

Edouard MilhacCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 55 21 Email: [email protected]: www.cms.law

F R A N C E

François has been a partner with CMS Francis Lefebvre Avocats since2003. He mainly focuses on corporate tax in an international context,assistance to corporate clients under audit and tax controversy.

Prior to joining CMS Francis Lefebvre Avocats, he worked with theFrench law firm of Ernst & Young for 10 years, providing corporate taxand legal services. In January 1996, he was transferred to the firm’sinternational tax services in New York, where he was responsible forthe French desk, advising clients on the tax aspects of internationalfinancing, acquisition planning, transfer pricing planning and passiveinvestment structuring. Prior to joining Ernst & Young, he spentseveral years with Coudert Brothers in Paris, where he practised Frenchcorporate tax law.

He is a contributor to various French and international tax journals.

François is a visiting professor in international taxation at Paris-Descartes University.

He is an attorney-at-law admitted to the Bar of the Hauts-de-Seine. Hegraduated from the École des Hautes Études Commerciales (1988) andobtained a DESS in international tax law (postgraduate degree) in1988 from the University of Paris XI. A French native speaker, he isfluent in English.

François RontaniCMS Francis Lefebvre Avocats2 rue Ancelle92522 Paris France Tel: (33) 1 47 38 40 59 Email: [email protected]: www.cms.law

F R A N C E

TAX EXPERTGUIDES 41


Giulio Andreani is a tax adviser who has a significant experience in taxlitigation; tax issues related to restructuring and insolvency; and M&Atax structuring (both domestic and international).

He was equity partner of Deloitte until 2004, when he joined DLAPiper. In 2017, he became partner of Dentons’ global tax practicestarting from 2017.

He defended the national airline Alitalia before the tax courts and wasexpert witness in the Federconsorzi bankruptcy, one of the biggestItalian financial disarrays. In addition, he provided advice relating tothe crisis faced by Biancamano and Aimeri Ambiente, involving amajor tax transaction and fiscal debt restructuring.

He was named tax adviser of the year by both LegalCommunity (2014-2015-2016 and 2018) and Top Legal (2009 and 2016).

As a professor of tax law, he regularly speaks at conferences, and holdstraining sessions for professional bodies, in relation to tax issues andinsolvency law.

For the past 25 years he has chaired the master’s degrees in tax law atLuiss University in Rome and the School of Economics and Finance(SSEF), a specialist institution attached to the Ministry of Finance. Hehas authored around 250 articles and 10 handbooks on the subject oftax.

He has contributed to several journals and newspapers, includingRassegna Tributaria, Corriere Tributario, Il Giornale dei DottoriCommercialisti, Contabilità Finanza e Controllo, the leading economicnewspaper Il Sole 24 Ore, and Il Fisco (of whose scientific committeehe is also a member).

Giulio is recommended by Chambers & Partners as one of the leadingtax lawyers in Italy.

WWL says: Giulio Andreani is “one of the best tax advisers and attorneysin Italy”, praised for his “deep knowledge of Italian and internationaltaxation” as well as his “ability to simplify difficult cases and present themeffectively before the courts”.

Giulio AndreaniDentonsPiazza degli Affari, 120123 MilanItalyTel: (39) 02 726 268 00Email: [email protected]: www.dentons.com

I TA L Y

Head of the Firm’s tax department, Raul-Angelo advises Italian andinternational clients on tax law and tax planning, cross-border taxationand transfer pricing, M&A transactions, private wealth management,trusts and estate planning matters. Raul-Angelo has routinely advised andadvises corporate and private clients in pre-litigation and litigationconcerning cross-border tax and transfer pricing matters. His clientsinclude leading global investment banks, Italian and foreignmultinationals, and prominent HNWIs, families and family offices. He isqualified in Italy as a barrister (Avvocato) and a certified tax expert(Dottore Commercialista) and holds an LL.M. in international taxation(with honors) from Leiden University in the Netherlands.

He frequently lectures at post graduate master programmes andseminars, both in Italy and abroad. He has been national reporter for Italyat the American Bar Association at the 2007 Foreign lawyers Forum, andItalian representative at the International Bar Association WorldwideConferences in Vancouver (2010) and Dubai (2011). He has also beenspeaker at different congresses and seminars held by the InternationalFiscal Association, both in Italy and abroad; he was a panellist at the IFA2011 Paris conference on a seminar dealing with the treaty aspects ofimmovable property and at the IFA 2016 Madrid conference on aseminar on the international tax aspects of venture capital funds. He isalso a frequent speaker and lecturer at Italian and foreign universities andat international tax seminars in Italy and abroad.

Raul-Angelo Papotti has published extensively on international taxtopics, on issues such as group taxation, tax treaties, international and EUtax law, the taxation of financial instruments and trusts, and contributedto journals such as the Bulletin for International Fiscal Documentation(IBFD), Intertax (Kluwer Law International), Derivatives and FinancialInstruments (IBFD), the British Tax Review (Sweet & Maxwell), Trustsand Trustees (Oxford University Press), Tax Notes International, Rivistadi Diritto Tributario (Giuffrè), Corriere Tributario (Kluwer LawInternational), Bollettino Tributario and others. He is also a frequentpublisher in daily financial and juridical newspapers in Italy such as IlSole24ore, Italia Oggi, Milano Finanza and MF. He is also co-author of abook on the Italian Patent box regime, edited by EGEA.

Raul-Angelo previously worked at the Firm’s London office for six yearsand has gained a wealth of experience in advising American and Englishbanks, multinationals and investment funds operating in Italy.

He is a member of the Italian branch of the International FiscalAssociation, of the Society of Trust and Estate Practitioner, of theAmerican Bar Association and of the International Bar Association,where he also serves as officer with the Taxes Committee. He is also aninternational fellow of ACTEC and an Academician with the InternationalAcademy of Estate and Trust Law, where he serves on its Council.

Raul Angelo PapottiChiomentiVia Giuseppe Verdi 220121 MilanItalyTel: (39) 02 7215 7855Email: [email protected]: www.chiomenti.net

I TA L Y

42 EXPERTGUIDES TAX


Maricla Pennesi is the European and Italian Tax coordinator in AndersenTax & Legal. She has more than 30 years of experience on internationaltaxation, business reorganisation, digital economy, and tax risk manage-ment, providing assistance to multinational corporations on matters oftensubject to tax litigation such as the existence of hidden permanent estab-lishments, profit allocation, and transfer pricing.

Maricla is assisting foreign multinationals in several cases of transfer pric-ing and hidden permanent establishment challenges. Recently she focusedher expertise on Compliance and good Governance of tax risks and relatedimplications for top executives and managing directors and also on im-plementing an effective tax-control framework to improve multinationalrisk-assessment procedures and strengthen their corporate governance.

Maricla is the author of several publications, including – to name the mostrelevant one – La stabile organizzazione. Aspetti critici ed evoluzione sultema, published by Wolters Kluver, and many other articles featured in do-mestic and international tax magazines such as Il Sole 24 Ore, Italia Oggi,Finanza e Mercati, Corriere Tributario, Milano Finanza, International TaxPlanning, Tax Analyst, New European Economy, International Tax Review,and more. Over the last few decades, she has been teaching national andinternational taxation at such qualified tax masters as Bocconi and Cat-tolica Universities and at Business Schools as Ipsoa/Wolter Kluwer and ilSole 24 Ore. Moreover, Maricla is often invited as a speaker at seminarsand meetings for national and international organizations. Maricla was alecturer of European law at the Polytechnic University of Marche

Maricla is a member of the Business Industry Advisory Board, which is anadvisory body for the OECD on tax matters; the Tax Committee of theAmerican Chamber of Commerce in Italy, where she serves as chairman,and the International Taxation Commission at Chartered AccountantsMilan Association.

Maricla is highly recommended as one of the most reputable internationaltax experts within the Italian market in main legal directories such asChambers, Legal 500, Women in Tax. She is the winner of the prestigiousinternational Client Choice Award as the best Italian tax advisor withincorporate tax. Top Legal highlights, ‘Maricla Pennesi provides essential, ofhigh-intellectual contribution to any operation’, and ranks her within bandtwo for international taxation and extraordinary transactions. The meritof her career path and awards was also recognised by one of the most im-portant associations worldwide – PWA, which admitted her as member ofReady-for-Board Women.

Maricla graduated cum laude in economics and holds a PhD in interna-tional law and economics. She is a chartered accountant and auditor andhas completed the leadership and management certification course at Har-vard University, Graduate School of Business Administration (US).

Maricla PennesiAndersen Tax & LegalCorso Magenta, 8220123 MilanItalyTel: (39) 02 48100471Email:[email protected]: www.andersentaxlegal.it

I TA L Y

Antonio Tomassini is the head of the Italian tax department, as well asof the European tax disputes team and he’s member of the DLA Piperglobal tax committee. He specializes in tax litigation, as well asinvestment funds, international taxation, wealth planning andcriminal tax law. He assists clients in some of the most complex andimportant national and international tax litigation before National,European and Supreme Courts and before tax authorities withininvestigation, settlements, rulings and MAP.

Previously, he was head of tax in a leading Italian firm and before thathe served as an Officer for the Italian Tax Authorities, dealing with taxinspections and criminal investigations in taxation, customs andmoney laundering matters.

PHD and professor of tax law and coordinator of various masterprograms, he regularly contributes for “Il Sole 24 ore” and he is authorof more than one hundred monographs and articles for national andinternational scholar magazines, including, among others, “corrieretributario”, “rassegna tributaria”, “rivista di diritto tributario”, “rivistatrimestrale di diritto tributario”.

He is ranked by Legal 500 EMEA, Chambers Europe, Chambers Globaland International Tax Review amongst the most reputable Italian taxprofessionals.

Full member of STEP, member of the scientific committee of “CorriereTributario”, admitted to practice to Supreme and European Courts.

Antonio Tomassini DLA PiperVia della Posta 720123 MilanItalyTel: (39) 02 80 618 1Email: [email protected] Website: www.dlapiper.com

I TA L Y

TAX EXPERTGUIDES 43


Alberto Trabucchi is a tax advisor with more than 20 years’ experiencein business taxation and international tax law, mainly focusing on thetax aspects of IAS/IFRS-adopters, banks and other financial entities,financial instruments, transfer pricing and M&A. He also providesassistance to domestic and international groups in case of taxcontroversy and in order to submit tax rulings to the Italian TaxAuthorities.

He is an equity partner of SCGT – Studio di Consulenza Giuridico-Tributaria, a law firm specialized in tax matters that he founded in2006, after lengthy experience in the tax offices of KPMG, ArthurAndersen and Assonime (the Association of Italian Joint StockCompanies). Currently, SCGT numbers more than 50 professionalswith offices in Rome, Milan and Turin.

Alberto is a registered chartered accountant and statutory auditor. Heis a delegate to the national committee of CNDCEC responsible for taxmatters, the Italian delegate to the European Tax Adviser FederationETAF, the head of IAS/IFRS-adopter committee of ODCEC (Romebranch). He is a member of IFA – International Tax Association andCFE-Tax advisers Europe.

He sits on numerous committees, very often involved in supportingItalian public authorities in the adoption of new tax law andregulations or in the implementation of EU directives in Italy.

He is statutory auditor of several companies and public entities; he hasalso been the statutory auditor for the Italian Revenue Agency.

He has lectured at various public and private institutions, includingBocconi and Bicocca (Milan) and Luiss (Rome) and is often asked toact as speaker and moderator in seminars and conferences on taxmatters.

He is co-author of the top-rated commentary on Italian income taxlaw “Le imposte sui redditi nel Testo Unico”, Giuffré, editions 2010-2020, as well as the texts “L’attività di controllo sul consolidatonazionale”, IPSOA, 2006, and “Fiscalità d’impresa e reati tributari”, IlSole 24 Ore, 2000, and is the author of numerous articles in specialistpublications.

Born in Rome on October 20, 1970, he graduated cum laude inEconomics at LUISS (1995). Following his graduation, he studied atthe International Bureau of Fiscal Documentation in Amsterdam(International Tax Law) and at the Center for Educational Studies inChicago (Master in US/International Tax Law).

Alberto TrabucchiSCGT – Studio di Consulenza Giuridico-TributariaPiazza Adriana, 15 – 00193 – RomeCorso degli Abruzzi, 3 – 10128 – TurinForo Buonaparte, 50 – 20121 – MilanTel: (39) 06 95216800Email: [email protected];

[email protected]: www.scgt.it

I TA L Y

44 EXPERTGUIDES TAX

EUROPE THOUGHT LEADERSHIP

Interview: Tax policy developmentsfor governments and multinationals

Wilbert Kannekens and Loek HeldermanKPMG Meijburg & CoAmsterdam

“Governments and tax policy”The European Green Deal suggests that well-designed tax reformscan boost economic growth and help reduce greenhouse gasemissions by ensuring an effective carbon pricing.

Q1: Loek, do you think that using taxation as a policy tool, byrevising the Energy Taxation Directive and creating a CarbonBorder Adjustment Mechanism, is the right way forward?“Well, that’s a difficult question to answer for a tax advisor. It isclear that climate change will have a considerable impact on theeconomy. For that matter governments and institutions like the EUwill probably take some considerable measures which will alsoimpact the economy and all taxpayers. I’m curious to see theoutcome of the consultation process on CBAM. Personally I wouldbe concerned about the differences in levels of ambition on thecarbon emissions and the associated measures taken bygovernments, and the impact this may have on industries andindividual companies which will largely depend on how these haveorganized their supply chains. It is my understanding that the EUambition exceeds the Paris Agreement and that certain countrieshave withdrawn from the latter, notably the US of course. TheCBAM is apparently seen as a tool to steer the carbon footprintand therefore an additional complexity in structuring a company’ssupply chain. But obviously this must lead to a better climate withless emissions, or at least that is the goal of course.”

The European Commission also launched the EU Recoveryinstrument (Next Generation EU) including new revenue sourcesof the EU budget in the form of (i)Emissions Trading System-based ownresources, including extension to themaritime and aviation sectors to generate€10 billion per year, (ii) Carbon borderadjustment mechanism to raise €5 billionto €14 billion per year, (iii) own resourcebased on operations of companies, thatdraw huge benefits from the EU singlemarket, which, depending on its design,could yield around €10 billion per yearand (iv) digital tax on companies with aglobal annual turnover of above €750million to generate up to €1.3 billion peryear.

Q2: Wilbert, is the EU running the risk of losing the EU MemberStates support by bringing new elements to the EU ownresources?“I am not sure whether this train can be stopped, especially in thistime of excessive crisis caused by the COVID-19 pandemic bothwithin individual states and the EU as an institution. With the har-monization of indirect tax, one of the objectives of a free trade zonewithin a common market was supposed to be met to some extent.Direct tax harmonization is long seen as a violation of taxsovereignty for the member states. However, we have also seenmany unilateral and multilateral measures taken against tax plan-ning strategies which resulted in the shifting of profits from one ju-risdiction to the other, e.g. BEPS actions, including the MLI, State

Aid cases, ATAD. Of course, the BEPS andassociated EU initiatives have been success-ful and have to a certain extent led to har-monized anti-avoidance legislation, withmany action items being implementedwithin a very short period of time. A furtherharmonization on direct tax, including aharmonized tax base has been consideredand discussed within the EU for decadesand lately with initiatives around for in-stance CC(C)TB again. None of these haveresulted in agreement amongst the memberstates, because of the perceived impact onthe national budgets. One could questionwhether climate change or COVID-19 is the

ONE COULD QUESTIONWHETHER CLIMATE

CHANGE OR COVID-19IS THE GAME CHANGERFOR EU MEMBER STATES

TO FURTHER GIVE UPTAX SOVEREIGNTY

N E T H E R L A N D S

TAX EXPERTGUIDES 45

THOUGHT LEADERSHIP EUROPE

game changer for EU Member States to further give up taxsovereignty. In today’s global crisis, people do understand that achange in the way we deal with the planet will be required, but I be-lieve that people are more likely to put their trust in institutionsclose at home and will rely more on their own national govern-ments to take the necessary measures and to decide on the methodhow to finance these measures than on international institutions.The main challenge for the EU as a whole is whether Member Statesthat have a robust budget are willing to step in and help otherMember States.”

Q3: Loek, should sustainability be government-led, or shouldthis be a matter of corporate initiatives?“Today’s crisis and the connect people tend to make with sustain-ability, may lead to governments and organization as the EU andOECD, taking the lead or an important coordinating role in thesematters. In my view 2020 could become a turning point in these de-velopments. However, this can’t be seen as a challenge to be only ledby governments or international organizations. Individuals, organi-zations and corporates all will have to take their responsibility. Andthis isn’t new. During the last decade we have seen many multina-tional organizations changing the way they run their business witha focus on sustainability. This will vary from the impact the com-pany makes on the environment, to the health and wellbeing ofpeople. In my view governments should stimulate these initiativesand governments may use the tax instrument as it is currently al-ready used in multiple jurisdictions, provided the tax instrument isused in a smart and effective way. This requires rules that are sim-ple, targeted and robust and not subject to abuse.”

“Multinational companies and tax policy”Q4: Wilbert, which trends do you see in corporatesustainability and tax? “One simple trend is that companies approach us or other consul-tancy firms to provide support in this area. Ever since the OECDlaunched the BEPS initiative in 2012 and the EU more or less si-multaneously launched its own anti-tax avoidance initiatives,multinational companies have become more transparent in theirapproach to tax. Tax has become part of the public relations policyof many multinationals. A sustainable tax policy and tax risk man-agement have become an integral part of Corporate Social Respon-sibility. Within KPMG we have established an experienced networkof professionals from across the globe to deliver industry leadingpractices, research and trusted client solutions to address these sus-tainability issues, including sustainability solutions in the field oftaxation.”

Q5: Loek, which guiding principles would you recommend tocompanies willing to publish tax policy statements as part ofgood corporate citizenship? “Of course, it is important for companies to consider the overall picture,the trends in the industry and the trends at peers, as well as the legislativelandscape. Obviously, some multinational companies may take a veryadvanced approach and become leading edge and a frontrunner in thisfield. This will also depend on the overall sustainability strategy of thecompany. Once multinationals have become very advanced in terms ofsustainability goals for the company at large, it makes a lot of sense toalso consider transparency in the field of taxation.”

Q6: Wilbert, do you think that the tax transparency principlespublished brings the tax function of multinational companies intoa potential conflict with creating shareholder value?“I don’t think so. Over time maybe even the contrary. Being transparenton your tax principles may provide a reputational benefit against yourpeers, whereas being secretive about the group’s tax position may bring apotential conflict with the creation of shareholder value for that matter.

Obviously before deciding on the publication of data under suchtax transparency principles, company management must consider itsimpact. This does not apply to tax only of course, but also to the otherparts of the business. Business reputation plays an important role,more than in the past. With today’s media attention and the overallpublic debate around tax, of course companies want to make sure thatindeed they pay a fair share of tax, whatever the definition of “fair”.Being transparent about your aggressive tax planning won’t help. Forthat same reason we have seen companies taking the appropriate mea-sures and making changes in their tax position on elements of theirbusiness structure, before the publication of their country by countryreports under BEPS 13. Of course there are various degrees in the ap-proach companies may take in publishing tax data under their taxtransparency principles. Most companies publish their tax principlesor tax policy, but so far only a few have decided to be very transparentabout the total tax contribution of the group for instance on a coun-try by country basis, but this may change over time. In December2019 for instance the Global Reporting Initiative (an independent in-ternational organization that helps businesses and other organizationsunderstand and communicate their sustainability impacts) launched anew tax reporting standard that seeks to ensure multinationals aremuch clearer about how much – and where – they pay their taxes.This has received widespread international support, but of course wenow have to see to what extent companies will actually apply the stan-dard. Apart from this standard, it should be kept in mind that publictransparency/public country by country reporting may one day be-come the compulsory minimum standard.”


46 EXPERTGUIDES TAX


Loek HeldermanKPMG Meijburg & CoLaan van Langerhuize 91186 DS AmstelveenNetherlandsTel: (31) 20 656 14 15Email: [email protected]: www.meijburg.com


Wilbert brings over 25 years of experience working with large globalcompanies, investors and governments on projects related tointernational tax, pan-European advice, cross-border reorganizations,mergers and acquisitions and strategic tax counseling.

Wilbert is since 2014 the managing partner and Chairman of KPMGMeijburg & Co in The Netherlands. He previously served as globalleader of KPMG’s International Tax Group and as president of theDutch Association of Academic Tax Advisors.

He is a frequent speaker and moderator at international conferences,delivering insights on topics such as international tax, fiscal policy,European integration, globalization and economic developments.Over the last 25 years, he has also published and contributed to articlesand books on business and tax.

Wilbert KannekensKPMG Meijburg & CoPO Box 746001070 DE AmsterdamNetherlandsTel: (31) 88 909 1035Email: [email protected]: www.meijburg.com


Professional experienceLoek joined KPMG Meijburg & Co – part of the international KPMGnetwork – in September 2010 following 23 years in the employ of amultinational enterprise active in the global market for fast movingconsumer goods (total sales of EUR 45 billion). There he held variousinternational positions within the corporate tax department, the lastten years as a member of the tax leadership team and as head of globaltransfer pricing and European tax matters.

In addition to his involvement in a large number of projects in the fieldof Dutch and international corporate income tax, Loek also hasextensive experience with large-scale corporate restructuring.

Loek specializes in international taxation, transfer pricing and businessrestructuring. He has participated in numerous international projectsin these fields. Where business restructuring is concerned, his activitiesusually concern large-scale feasibility studies and the subsequentdesign and implementation of the business model, as well as theinteraction with local tax authorities.

In his current position at KPMG Meijburg & Co, Loek supportsmultinational enterprises with local and international tax matters.Loek is co-leading the KPMG Meijburg Corporate Clients Team andhas a number of global tax lead partner roles with Dutchmultinationals.

Specialization• International tax• Transfer pricing for goods, services and intellectual property rights,

such as trademarks, patents and know-how• Mergers and acquisitions• Group financing• Cross-border and general corporate restructuring• Value Chain Management• Documentation and planning risk management• Tax policy and strategy

TAX EXPERTGUIDES 47


In addition to his responsibilities as board member, Michael is head ofour tax practice group, and previously a resident partner at ourLondon and New York offices, Michael’s expertise is global.

His specialisms include domestic and international taxation withparticular emphasis on M&A and private equity transactions,corporate reorganisations and investment fund structures.

Michael guides large multinational companies, financial institutionsand private equity firms through every stage of technically complexissues, including contentious issues, ensuring all their needs are met.

He is also a frequent speaker on international tax issues and has co-authored several books and articles on international taxation.

Michael has a law degree from Amsterdam University and an LL.M.from New York University. He is a member of the International FiscalAssociation (IFA), the International Bar Association (IBA) and of thePractice Council of NYU’s International Tax Program.

Specialisation• International tax• Investment Management• Corporate Tax• International Tax Planning• Tax Controversy

Languages: Dutch, English, GermanAdmitted to the Amsterdam Bar: 1992Partner since: 2000

Michael MolenaarsStibbe Beethovenplein 101077 WM AmsterdamNetherlandsTel: (31) 20 546 06 38Mob: (31) 6 293 391 47Email: [email protected]: www.stibbe.com


Prof. Dr. Stef van Weeghel is Global Tax Policy leader at PwC. He is alsoprofessor of international tax law at the University of Amsterdam andchair of the Board of Trustees at the International Bureau for FiscalDocumentation (IBFD).

Stef ’s primary focus is on tax policy, strategic tax advice and taxcontroversy. His experience covers cross-border transactions,structuring and tax controversy/litigation. He advises and renderssecond opinions to clients and their advisers on corporate income taxand tax treaty matters, is consulted by the Dutch government on aregular basis and participates in the work of the OECD. He acts ascounsel and as expert witness on tax treaty interpretation (fortaxpayers and for governments) before Dutch and foreign courts andin arbitration pursuant to bilateral investment treaties and incommercial arbitration.

Stef graduated from the University of Leiden in business law (1983)and tax law (1987) and obtained an LLM in Taxation from New YorkUniversity (1990). In 1997, he received a doctorate in law from theUniversity of Amsterdam (PhD thesis: Improper Use of Tax Treaties);in 2000 he was appointed a tenured professor of international tax lawat that same university. He has authored and co-authored severalbooks and many articles on Dutch and international taxation. He haslectured extensively in the Netherlands and internationally.

Before joining PwC, Stef was a partner at Linklaters and at Stibbewhere his roles included membership of the executive committee, headof tax and resident partner in the New York office. He has acted assecretary and chair of the Dutch branch of the International FiscalAssociation (IFA) and is immediate past chair of IFA’s PermanentScientific Committee. In 2010 he was the general reporter for Subject1 (Tax treaties and tax avoidance: application of anti-avoidanceprovisions) at the IFA Congress in Rome.

In 2009/2010 Stef chaired the Study Group Tax System, a committeethat advised the Dutch government on comprehensive tax reform. In2000 he was a member of the Van Rooy-Committee that advised theDutch government on corporate income tax reform. Prior thereto hewas member of a working group at the Dutch Ministry of Finance thatworked on revision of the Dutch ruling practice. He also worked on thereview of administrative practices in taxation commissioned by theEuropean Commission. On various occasions he appeared as expertbefore the Finance Committees of the Second and First Chamber ofthe Dutch Parliament and he also appeared before the TAXE-Committee and the PANA-Committee of the European Parliament.

Stef van WeeghelPwCThomas R. Malthusstraat 51066 JR, P.O. Box 903581006 BJ AmsterdamNetherlandsTel: (31) 88 792 6763Email: [email protected]: www.pwc.nl


48 EXPERTGUIDES TAX


Thomas Andersson is a KPMG tax director and leads the KPMGSweden Tax Dispute and resolution team. Thomas primarily workswith domestic and international corporate tax law.

He has extensive experience in the fields of international tax planning,restructuring assignments and of curse tax disputes. The last yearsThomas has mainly focused on large tax litigation and disputes andhave as legal counsel won several cases. Thomas has extensiveknowledge and skill in the tax profession and has worked as a taxexpert for more than 30 years.

Thomas AnderssonKPMGVasagatan 16SE-101 27 StockholmSwedenTel: (46) 8 723 91 00 Email: [email protected]: www.kpmg.se

S W E D E N

Jörgen Graner is a KPMG tax partner and leads the KPMG SwedenCorporate Tax practice. He serves as the Lead Client Partner for anumber of Swedish multinationals.

Jörgen primarily works with domestic and international corporate taxlaw. He has extensive experience in the fields of international taxplanning, restructuring assignments, tax disputes and M&A projects.Jörgen has extensive knowledge and skill in the tax profession and hasworked as a tax expert for the past 20 years. He advises clients across arange of industries.

Jörgen earned his LLM at the University of Uppsala in 1997 and is amember of the International Fiscal Association and FAR, the institutefor the accountancy profession in Sweden.

Jörgen GranerKPMGVasagatan 16SE-101 27 StockholmSwedenTel: (46) 8 723 91 00Email: [email protected]: www.kpmg.se

S W E D E N

TAX EXPERTGUIDES 49


Helena Robertsson is a Senior Partner with more than 25 years ofexperience in serving as trusted Tax advisor for companies andindividuals around the world. She is the Global Leader of EY’s FamilyEnterprise practice. Between 2017 and 2019 Helena was responsible forPrivate Client practice in Europe, Middle East, India and Africa. Shealso led the Family Enterprise team in the Nordics and the Tax practicein Stockholm. Her passion is helping entrepreneurial families designlong-term strategies and implement the right tools, skills and trainingto succeed from generation to generation.

Helena uses her broad expertise in national and international taxationto help her clients resolve complex issues related to capital gainstaxation, global mobility, compensation and benefit planning, taxreturn compliance, transfer pricing, international corporate tax, andother matters. She served as Lead Partner in various engagements withsome of the largest family offices, private equity companies, privateequity partners, high-net-worth individuals, and private companies inthe Nordics. She advised several private equity funds in developingeffective fund and carry structures.

Helena holds an MSc in Business Administration and Tax Law fromStockholm University. She is a certified tax adviser and the Chair of theStockholm University Center for Commercial Law. She also serves as aboard member of the Swedish-American Chamber of Commerce inNew York.

Helena is a frequent speaker at tax conferences and tax educationseminars in Sweden, and regularly comments on tax matters in themedia.

Helena RobertssonEYJakobsbergsgatan 24103 99 StockholmSwedenTel: (46) 52059000Email: [email protected]: www.ey.com/private

S W E D E N

Lennart Staberg, who has a Master of Laws (LLM) degree from theUniversity of Uppsala, joined PricewaterhouseCoopers in 1994. Beforejoining the firm, he was assistant judge of the Administrative Court ofAppeal in Gothenburg and also deputy director with the NationalCouncil for Advance Tax Rulings. He has well over 20 years ofexperience from tax-related work.

Lennart, who is a tax partner, specialises in providing tax consultancyservices to the financial sector in Sweden and abroad. He also hasextensive experience of tax litigation and services in relation to thestructuring of private equity funds.

Lennart’s principal clients are major Swedish companies and foreigncompanies with business activities in Sweden.

Lennart StabergPwCTorsgatan 21SE-113 97 StockholmSwedenTel: (46) 10 213 3169Email: [email protected]: www.pwc.com

S W E D E N

50 EXPERTGUIDES TAX


Tina Zetterlund is the senior partner and head of tax at KPMG and isone of the leading tax advisers in Sweden. Tina has advised Swedishand foreign companies in a wide range of sectors for more than 15years. Her client relationships focus on Swedish and foreignmultinationals and she has extensive experience of tax advising.

Recent matter highlightsWith Tina as the head of tax, the tax department at KPMG has reachedall-time highs in both revenue and number of practitioners and hasreceived the award as the Swedish Tax Firm of the Year by InternationalTax Review for for five consecutive years, 2016–2020.

With Tina’s combined skills in accounting and tax, she is appreciatedby her clients for her ability to see the full spectrum of tax-relatedissues and questions and is regularly consulted on tax issues withfinancial statements impacts.

Practice areas• Business model optimisation• Policy design• Restructuring• Tax consulting• International tax advisory

Sector specialisations• Accounting• Consumer goods and service• Energy• Industrials• Tech and telecoms

Association memberships• Certified tax adviser with FAR, The professional institute for

authorised public accountants

Academic qualifications• Master of Science degree in economics & business from the

Stockholm School of Economics

Tina ZetterlundKPMGVasagatan 16SE-101 27 StockholmSwedenTel: (46) 70 3999284Email: [email protected]: www.kpmg.se

S W E D E N

Practice area: Tax, Private Clients, Succession Law, Commercial andContracts, Investigations

Languages: French, English, German

Jean-Blaise Eckert is considered as a leading lawyer in tax and privateclient matters in Switzerland. He is the co-head of the tax group ofLenz & Staehelin. He advises a number of multinational groups ofcompanies as well as HNWIs. Jean-Blaise Eckert is a frequent speakerat professional conferences on tax matters. He is Secretary General ofthe International Fiscal Association (IFA). Jean-Blaise Eckert studiedlaw at the University of Neuchâtel and was admitted to the Bar ofNeuchâtel in 1989 and to the Bar of Geneva in 1991. He studiedbusiness administration in the US (Berkeley, Haas Business School)where he acquired an MBA in 1991. He acquired a diploma as aCertified Tax Expert in 1994. Since 2016, he is a Certified SpecialistSBA in Inheritance Law.

Jean-Blaise EckertLenz & StaehelinRoute de Chêne 30CH-1211 Geneva 6Switzerland Tel: (41) 58 450 70 00 Email: jean-blaise.eckert@ lenzstaehelin.comWebsite: www.lenzstaehelin.com

S W I T Z E R L A N D

TAX EXPERTGUIDES 51

EXPERT LISTINGS EUROPE

A U S T R I AMarkus AchatzLeitnerLeitnerLinz

Franz AlthuberAlthuber Spornberger & PartnerVienna

Paul DoraltDORDAVienna

Gerald GahleitnerLeitnerLeitnerLinz

Andreas HableBinder GrösswangVienna

Ingrid RattingerEYVienna

Roland RiefEYVienna

Niklas SchmidtWolf TheissVienna

Michael SedlaczekFreshfields Bruckhaus DeringerVienna

Claus StaringerFreshfields Bruckhaus DeringerVienna

Andreas StefanerEYVienna

Alexander StieglitzEYVienna

Verena TrenkwaderKPMGLinz

Benjamin TwardoszCerha HempelVienna

Christian WimpissingerBinder GrösswangVienna

Hans ZöchlingKPMGVienna

B E L G I U M

Christian ChéruyLoyens & LoeffBrussels

Xavier ClareboutLoyens & LoeffBrussels

Marc De MunterBaker TillyBrussels

Guido De WitLinklatersBrussels

Mark DelanoteBloom law firmBrussels

Daniel GarabedianArteo LawBrussels

Axel HaeltermanFreshfields Bruckhaus DeringerBrussels

Werner HeyvaertAKDBrussels

Stéphanie HouxAllen & OveryBrussels

Alain HuygheBaker McKenzieBrussels

Philippe LionBaker McKenzieBrussels

Nicolas LippensLinklatersBrussels

Koen MaerevoetKPMGBrussels

Koen MorbéeTiberghienBrussels

Alexandre OomsClifford ChanceBrussels

Wim PanisStibbeBrussels

Bernhard GröhsDeloitte AustriaRenngasse 1/FreyungWien, A-1010Austria Tel: (43) 15 3700 5500Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Herbert KovarDeloitte AustriaRenngasse 1/FreyungWien, A-1010Austria Tel: (43) 15 3700 3600Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Josef SchuchDeloitte AustriaRenngasse 1/FreyungWien, A-1010Austria Tel: (43) 15 3700 7100Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Michael WeismannDeloitte AustriaRenngasse 1/FreyungWien, A-1010Austria Tel: (43) 15 3700 6700Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Emmanuel BrehmenDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 600 6679Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Patrick CauwenberghDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 600 6927Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Luc De BroeDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 800 7010Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Christophe De WaeleDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 600 6562Email: [email protected]: www.deloitte.comSee page 28 for regional profile

52 EXPERTGUIDES TAX

EUROPE EXPERT LISTINGS

Bernard PeetersTiberghienBrussels

René PhilipsKPMGBrussels

Natalie ReypensLoyens & LoeffBrussels

Patrick SmetAllen & OveryBrussels

Axel SmitsPwCBrussels

Gérard van den Bergvan den Berg & PartnersBrussels

Marnix Van KeirsbilckDumon Sablon & VanheeswijckBrussels

Dirk Van StappenKPMGAntwerp

Luc VanheeswijckDumon Sablon & VanheeswijckBrussels

Henk VanhulleLinklatersBrussels

Henk VerstraeteStibbeBrussels

C Y P R U SMarios AndreouPwCLimassol

Stavros CleridesClerides Anastassiou NeophytouLimassol

Spyros IoannouLIS Primus Audit and TaxLimassol

George V MarkidesKPMGNicosia

Elias NeocleousAndreas Neocleous & CoLimassol

Philippos RaptopoulosEYLimassol

C Z E C HR E P U B L I CJana AlferyAlferyPrague

Jan CapekEYPrague

Michal DušekAllen & OveryPrague

Libor FryzekEYPrague

Helena NavrátilováKocián Šolc BalaštíkPrague

Petr SebestaClifford ChancePrague

David Stan kStan k Tomí ek & PartnersPrague

D E N M A R KJakob Skaadstrup AndersenGorrissen FederspielCopenhagen

Kaspar BastianTVC AdvokatfirmaCopenhagen

Thomas BjerrePwCCopenhagen

Nikolaj BjørnholmBjørnholm LawCopenhagen

Jan BørjessonDLA PiperÅrhus

Artur BugsgangDLA PiperCopenhagen

Lasse Esbjerg ChristensenPlesnerCopenhagen

Anders Endicott PedersenPlesnerCopenhagen

Ria FalkKPMG Acor TaxHellerup

Danny StasDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 800 7011Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Pascal Van HoveDeloitte BelgiumGateway Building Luchthaven BrusselNationaal 1 JZaventem, 1930, Belgium Tel: (32) 2 600 6770Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Pieris MarkouDeloitte Cyprus24 Spyrou Kyprianou Avenue, Nicosia CY-1075Cyprus Tel: (357) 2236 0607Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Alecos PapalexandrouDeloitte CyprusMaximos Plaza - Tower 3 - 2nd floor 213Arch. Makarios III AvenueLimassol CY-3030, CyprusTel: (357) 2586 8822Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Antonis TaliotisDeloitte CyprusMaximos Plaza - Tower 3 - 2nd floor 213Arch. Makarios III AvenueLimassol CY-3030, CyprusTel: (357) 2586 8820Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Søren Reinhold AndersenDeloitte DenmarkWeidekampsgade 6København S, 2300Denmark Tel: (45) 2220 2190Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 53


Thomas FrøbertBech-BruunCopenhagen

Hans Severin HansenPlesnerCopenhagen

Søren Jesper HansenPwCCopenhagen

Claus HolbergDLA PiperCopenhagen

Jef Nymand HounsgaardPlesnerCopenhagen

Tom Kári KristjánssonPlesnerCopenhagen

Jakob KrogsøeBech-BruunCopenhagen

Arne Møllin OttosenKromann ReumertCopenhagen

Søren Lehmann NielsenBruun & HjejleCopenhagen

Arne RiisARITax/lawCopenhagen

Michael SerupBech-BruunÅrhus

Hans Severin HansenPlesnerCopenhagen

Niclas H SonneEYCopenhagen

Jan Steen HansenGorrissen FederspielCopenhagen

Bodil TolstrupBjørnholm LawCopenhagen

Niels Winther-SørensenVistisen Falk WintherCopenhagen

E S T O N I APriit LättPwC LegalTallinn

Kaspar LindATTELA Law OfficeTallinn

Helmut PikmetsTGS BalticTallinn

Marko SaagATTELA Law OfficeTallinn

Egon TalurCobaltTallinn

Ranno TingasEYTallinn

Ain VeideEversheds Sutherland Ots & CoTallinn

F I N L A N DOssi HaapaniemiRoschierHelsinki

Raimo HietalaEYHelsinki

Janne JuuselaBoreniusHelsinki

Einari KarhuBoreniusHelsinki

Sari LaaksonenCastrén & SnellmanHelsinki

Antti LehtimajaKrogerusHelsinki

Samuli MakkonenPwCHelsinki

Timo MatikkalaKPMGHelsinki

Mika OhtonenRoschierHelsinki

Kari PasanenEYHelsinki

Leena RomppainenCastrén & SnellmanHelsinki

Thomas Svane JensenDeloitte DenmarkWeidekampsgade 6København S, 2300Denmark Tel: (45) 2517 1855Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Lars Loftager JørgensenDeloitte DenmarkWeidekampsgade 6København S, 2300Denmark Tel: (45) 2342 2744Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Niels JosephsenDeloitte DenmarkWeidekampsgade 6København S, 2300Denmark Tel: (45) 2154 3211Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Tomi KarsioDeloitte FinlandPorkkalankatu 24 P.O. Box 122Helsinki, 00181Finland Tel: (358) 2 0755 5466Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Johanna OksaDeloitte FinlandPorkkalankatu 24 P.O. Box 122Helsinki, 00181Finland Tel: (358) 2 0755 5329Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Virpi PasanenDeloitte FinlandPorkkalankatu 24 P.O. Box 122Helsinki, 00181Finland Tel: (358) 2 0755 5813Email: [email protected]: www.deloitte.comSee page 28 for regional profile

54 EXPERTGUIDES TAX


Niklas ThibblinWaselius & WistHelsinki

Timo TorkkelKPMGHelsinki

Martti VirolainenPwCHelsinki

F R A N C EClaire AcardEYParis

Vincent AgulhonDarrois Villey Maillot BrochierParis

Christophe Aldebert See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Denis AndresArsene TaxandParis

Stéphane Austry See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Gauthier BlanluetSullivan & CromwellParis

Laurent BoreyMayer BrownParis

Bernard BoutemyJeausserand AudouardParis

Stephane ChaouatWeil Gotshal & MangesParis

Edouard ChapellierLinklatersParis

Jean-Yves CharriauLacourte Raquin TatarParis

Emmanuel ChauveDe Pardieu Brocas MaffeiParis

Laurence ClotBird & BirdParis

Michel Collet See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Antoine Colonna d'IstriaNorton Rose FulbrightParis

Sabina ComisDechertParis

Anne-Sophie CoustelCleary Gottlieb Steen & HamiltonParis

Olivier DauchezGide Loyrette NouelParis

Eric DavoudetClifford ChanceParis

Agnès de l'Estoile-Campi See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Sébastien de MonèsBredin PratParis

Allard de WaalPaul HastingsParis

Niels DejeanShearman & SterlingParis

Philippe DerouinAvocat au barreau de ParisParis

Frederic Donnedieu de VabresArsene TaxandParis

Pierre-Jean Douvier See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Pierre-Henri DurandBredin PratParis

Richard Foissac See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Eric FourelEYParis

Alain FrenkelFrenkel & AssociésParis

Julien GayralBredin PratParis

Stéphane Gelin See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Nadine GelliKirkland & EllisParis

Bruno Gibert See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Sandra HazanDentonsParis

François Hellio See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Benjamin HomoMayer BrownParis

Alexandre IppolitoWhite & CaseParis

Anne-Sophie KerfantOrrick Herrington & SutcliffeParis

Alexandre LagarrigueClifford ChanceParis

Pia StubbDeloitte FinlandPorkkalankatu 24 P.O. Box 122Helsinki, 00181Finland Tel: (358) 2 0755 5449Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Sophie Blégent-DelapilleDeloitte | TajMajunga - 6, place de la Pyramide Paris La Défense, 92 908 France Tel: (33) 1 4088 7205Email: [email protected]: www.deloitte.comSee page 26 for regional profile

TAX EXPERTGUIDES 55


Xenia LegendreHogan LovellsParis

Lionel Lenczner See bioCMS Francis Lefebvre AvocatsParis

Eglantine LioretPinsent MasonsParis

Philippe LorentzAugust & DebouzyParis

Sylvie MagnenEYParis

Norbert MajerholcWhite & CaseParis

Eric MeierBaker McKenzieParis

Edouard Milhac See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Véronique MillischerBaker McKenzieParis

Marc PelletierFrenkel & AssociésParis

Thomas PerrotSkadden Arps Slate Meagher & FlomParis

Emmanuelle Pontnau-FaureAshurstParis

Olivia Rauch-RaviséLatham & WatkinsParis

Xavier RenardLatham & WatkinsParis

François Rontani See bioCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Yves RutschmannBredin PratParis

Pierre-Sébastien ThillCMS Francis Lefebvre AvocatsNeuilly-sur-Seine

Jérôme TurotCabinet TurotParis

Pierre UllmannCazals Manzo Pichot Saint QuentinParis

Cyril ValentinFreshfields Bruckhaus DeringerParis

Mirouna VerbanArsene TaxandParis

G E R M A N YHubertus BaumhoffFlick Gocke SchaumburgBonn

Stephan BehnesBaker McKenzieFrankfurt am Main

Stefan BehrensClifford ChanceFrankfurt am Main

Stefanie BeinertHengeler MuellerStuttgart

Bodo BenderWhite & CaseFrankfurt am Main

Michael BestP+P Pöllath + PartnersMunich

Jens BlumenbergLinklatersHamburg

Axel BödefeldOppenhoff & PartnerCologne

Gottfried E BreuningerAllen & OveryMunich

Jan BrinkmannFreshfields Bruckhaus DeringerFrankfurt am Main

Xaver DitzFlick Gocke SchaumburgBonn

Oliver DörflerPwCDüsseldorf

Pia DorfmuellerP+P Pöllath + PartnersFrankfurt am Main

Petra EcklGSK StockmannFrankfurt am Main

Christian EhlermannEYMunich

Stephan EilersFreshfields Bruckhaus DeringerDüsseldorf/London

Thomas ElserTAXGATEStuttgart

Uwe EpplerNorton Rose FulbrightHamburg

Hans-Jürgen FeyerabendKPMGFrankfurt am Main

Thomas FoxLatham & WatkinsMunich/Düsseldorf

Johannes FreySkadden Arps Slate Meagher & FlomFrankfurt am Main/Munich

Rolf FügerMilbankMunich

Arnaud MourierDeloitte | TajMajunga - 6, place de la Pyramide Paris La Défense, 92 908 France Tel: (33) 1 5561 5373Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Thomas PerrinDeloitte | TajMajunga - 6, place de la Pyramide Paris La Défense, 92 908 France Tel: (33) 1 5561 6948Email: [email protected]: www.deloitte.comSee page 26 for regional profile

56 EXPERTGUIDES TAX


Michael GrafDentonsFrankfurt am Main

Maximilian HaagP+P Pöllath + PartnersMunich

Klaus HerkenrothJones DayFrankfurt am Main

Claus Jochimsen-von GfugKPMGMunich

Christine KamphausPwCDüsseldorf

Martin KleinHengeler MuellerFrankfurt am Main

Thomas KleinheisterkampMilbankMunich

Gunnar KnorrOppenhoff & PartnerCologne

Marc KrischerOppenhoff & PartnerCologne

Florian LechnerJones DayFrankfurt am Main

Nicole LooksBaker McKenzieFrankfurt am Main

Jochen LüdickeLüdicke & KollegenRechtsanwaltsgesellschaftDüsseldorf

Jürgen LüdickePwCHamburg

Jörg W LüttgeFlick Gocke SchaumburgBonn

Stefan MayerGleiss LutzFrankfurt am Main

Dirk PohlMcDermott Will & EmeryMunich

Norbert RiegerMilbankMunich

Claus RitzerFlick Gocke SchaumburgMunich

Thomas RödderFlick Gocke SchaumburgBonn/Düsseldorf

Andreas RodinP+P Pöllath + PartnersFrankfurt am Main

Oliver RosenbergLinklatersDüsseldorf

Frank RoserRoserHamburg

Michael SchadenEYStuttgart

Andreas SchaflitzlLinklatersMunich

Matthias SchellMilbankMunich

Martin SchiesslFreshfields Bruckhaus DeringerFrankfurt am Main

Norbert SchneiderFreshfields Bruckhaus DeringerCologne

Arne SchnitgerPwCBerlin

Andreas SchumacherFlick Gocke SchaumburgBonn

Ulrich SiegemundLuther.Frankfurt am Main

Klaus SiekerFlick Gocke SchaumburgFrankfurt am Main

Tobias TeufelFreshfields Bruckhaus DeringerFrankfurt am Main

Alexander VögeleNERA Economic ConsultingFrankfurt am Main

J F Daniel WeydeCleary Gottlieb Steen & HamiltonFrankfurt am Main

Götz T WieseWiese LukasHamburg

Franz ZimmermannKantenweinMunich

G R E E C EDaphne CozonisZepos & YannopoulosAthens

John C DryllerakisDryllerakis & AssociatesAthens

Theodore FortsakisFortsakis Diakopoulos Mylonogiannis &AssociatesAthens

Sophia K GrigoriadouDryllerakis & AssociatesAthens

Sven FuhrmannDeloitte GermanyFranklinstrasse 50Frankfurt, 60486Germany Tel: (49) 69 756957024Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Marcus RothDeloitte GermanyRosenheimer Platz 4Muenchen, 81669Germany Tel: (49) 89 290368278Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Christoph WelterDeloitte GermanyLoeffelstrasse 42Stuttgart, 70597Germany Tel: (49) 711 65547486Email: [email protected]: www.deloitte.comSee page 26 for regional profile

TAX EXPERTGUIDES 57


Stephanos MitsiosEYAthens

Ioannis F StavropoulosStavropoulos & PartnersAthens

Yerassimos YannopoulosZepos & YannopoulosAthens

H U N G A R YÁkos BecherBecher & TormaBudapest

Róbert HeinczingerEYBudapest

Eszter KálmánCMS Cameron McKenna NabarroOlswangBudapest

Botond RenczEYBudapest

Levente TormaBecher & TormaBudapest

I R E L A N D

Sharon BurkeKPMGDublin

Fintan ClancyArthur CoxDublin

Caroline DevlinArthur CoxDublin

Maura DineenDLA PiperDublin

Paul FahyA&L GoodbodyDublin

Ailish FinnertyArthur CoxDublin

Mike GaffneyKPMGDublin

Turlough GalvinMathesonDublin

Denis HarringtonPwCDublin

Alan HeustonMcCann FitzGeraldDublin

Shane HoganMathesonDublin

David LawlessDillon EustaceDublin

Greg LockhartMathesonDublin

Peter MaherA&L GoodbodyDublin

Sonya ManzorWilliam FryDublin

Kevin McLoughlinEYDublin

Conor O'BrienKPMGDublin

Catherine O'MearaMathesonDublin

Frank O'NeillEYCork

Martin PhelanWilliam FryDublin

John RyanMathesonDublin

Anna ScallyKPMGDublin

Jonathan SheehanWalkersDublin

James SomervilleA&L GoodbodyDublin

Aidan WalshEYDublin

I TA L YLuciano AcciariGianni Origoni Grippo Cappelli &PartnersRome

Bernadette AcciliLMS Studio LegaleMilan

Attila KövesdyDeloitte HungaryDozsa Gyorgy ut 84/CBudapest, 1068Hungary Tel: (36) 1428 6728Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Pascal BrennanDeloitte Ireland29 Earlsfort Terrace Dublin 2Dublin, D02 AY28Ireland Tel: (353) 1417 2443Email: [email protected]: www.deloitte.ieSee page 28 for regional profile

Declan ButlerDeloitte Ireland29 Earlsfort Terrace Dublin 2Dublin, D02 AY28Ireland Tel: (353) 1417 2822Email: [email protected]: www.deloitte.ieSee page 28 for regional profile

Pádraig CroninDeloitte Ireland29 Earlsfort Terrace Dublin 2Dublin, D02 AY28Ireland Tel: (353) 1417 2417Email: [email protected]: www.deloitte.ieSee page 28 for regional profile

58 EXPERTGUIDES TAX


Ottavia AlfanoDi Tanno e AssociatiMilan

Giulio Andreani See bioDentonsMilan

Massimo AntoniniChiomentiMilan

Giuseppe AscoliCMS Adonnino Ascoli & CavasolaScamoniRome

Fulvia AstolfiHogan LovellsRome

Maria Antonietta BiscozziEYMilan

Angelo BonissoniCBA Studio Legale e TributarioMilan

Fabio BrunelliDi Tanno e AssociatiRome/Milan

Paola CamagniCamagni e AssociatiMilan

Cristiano Caumont CaimiTremonti Romagnoli Piccardi e AssociatiMilan

Luca Dal CerroLeganceMilan

Luca DezzaniGrimaldi Studio LegaleMilan

Tommaso Di TannoDi Tanno e AssociatiRome

Carlo GalliClifford ChanceMilan

Massimiliano GazzoDe Berti JacchiaMilan

Massimo GiaconiaBaker McKenzieMilan

Giuseppe A GiannantonioChiomentiMilan

Francesco GuelfiAllen & OveryMilan

Marco LombardiJones DayMilan

Paolo LudoviciLudovici Piccone & PartnersMilan

Guglielmo MaistoMaisto e AssociatiMilan

Andrea ManzittiBonelliEredeMilan

Giuseppe MarinoMB AssociatiMilan

Christian MontinariDLA PiperMilan

Luca NiscoEYMilan

Carlo Maria PaolellaMcDermott Will & EmeryRome

Raul-Angelo Papotti See bioChiomentiMilan

Renato PaternolloFreshfields Bruckhaus DeringerMilan

Maricla Pennesi See bioAndersen Tax & LegalMilan

Stefano PetreccaCBAMilan

Vania PetrellaCleary Gottlieb Steen & HamiltonRome

Lorenzo PiccardiTremonti Romagnoli Piccardi e AssociatiMilan

Pietro Piccone FerrarottiLudovici Piccone & PartnersMilan

Dario RomagnoliTremonti Romagnoli Piccardi e AssociatiMilan

Eugenio RomitaGiovannelli e AssociatiMilan

Luca RossiFacchini Rossi MicheluttiMilan

Livia SalviniSalvini e SociRome

Andrea SilvestriBonelliEredeMilan

Stefano SimontacchiBonelliEredeMilan

Antonio Tomassini See bioDLA PiperMilan/Rome

Alberto Trabucchi See bioSCGTRome

Riccardo UbaldiniBonelliEredeMilan

Piergiorgio ValenteValente Associati GEB PartnersMilan

Marcello ValentiTremonti Romagnoli Piccardi e AssociatiMilan

Raffaele VillaEYMilan

Tiziana ZonaDe Berti JacchiaMilan

TAX EXPERTGUIDES 59


L AT V I AIlona ButaneEYRiga

Valters GencsGencs Valters Law FirmRiga

Janis TaukacsSorainenRiga

Janis ZelmenisBDORiga

L I T H U A N I AKestutis LisauskasEYVilnius

L U X E M B O U R GThierry CharonLoyens & LoeffLuxembourg

Frédéric FeytenDentonsLuxembourg

Jean-Luc FischElvinger Hoss PrussenLuxembourg

Eric FortArendt & MedernachLuxembourg

Bruno GasparottoArendt & MedernachLuxembourg

Alain GoebelArendt & MedernachLuxembourg

Jean-Marc GroellyNautaDutilhLuxembourg

Fabien HautierPwCLuxembourg

Thierry LesageArendt & MedernachLuxembourg

Patrick MischoAllen & OveryLuxembourg

Peter MoonsLoyens & LoeffLuxembourg

Gérard NeiensHogan LovellsLuxembourg

Simon PaulLoyens & LoeffLuxembourg

Jean SchaffnerAllen & OveryLuxembourg

Alain SteichenBonn Steichen & PartnersLuxembourg

Louis ThomasKPMGLuxembourg

M A L TARobert AttardEYMsida

Rosanne BonniciFenech & Fenech AdvocatesValletta

Juanita BrockdorffKPMGPieta

Neville GattPwCValletta

Renald MicallefBusuttil & MicallefBirkirkara

Christopher NaudiEYMsida

N E T H E R L A N D SMarieke BakkerLoyens & LoeffRotterdam

Jaap W BellingwoutVu University AmsterdamAmsterdam

Lodewijk BergerJones DayAmsterdam

Roderik BouwmanDLA PiperAmsterdam

Thijs ClementNobrius Clement AdvocatenAmsterdam

Juliana DantasBaker McKenzieAmsterdam

Marja de BestLoyens & LoeffRotterdam

Marco de LignieLoyens & LoeffAmsterdam

Rob de WinVan DoorneAmsterdam

Bernard B DavidDeloitte Luxembourg20 Boulevard de KockelscheuerLuxembourg, L-1821Luxembourg Tel: (352) 45145 2799Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Raymond KrawczykowskiDeloitte Luxembourg20 Boulevard de KockelscheuerLuxembourg, L-1821Luxembourg Tel: (352) 45145 2500Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Conrad Cassar TorregianiDeloitte MaltaDeloitte Place, Triq L–IntornjaturCentral Business District, Mriehel CBD 3050MaltaTel: (356) 2343 2716Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Frits G BarnardDeloitte NetherlandsGustav Mahlerlaan 2970Amsterdam, 1081 LANetherlands Tel: (31) 882886857Email: [email protected]: www.deloitte.comSee page 28 for regional profile

60 EXPERTGUIDES TAX


Guido DerckxLoyens & LoeffAmsterdam

Sylvia DikmansHouthoffAmsterdam

Frank EngelenPwCRotterdam

Peter FlipsenSimmons & SimmonsAmsterdam

Jan-Willem A M GerritsenBaker McKenzieAmsterdam

Rob HavengaHouthoffAmsterdam

Loek Helderman See bioKPMG Meijburg & CoAmstelveen

Frank HerreveldHerreveld Van Sprundel & PartnersRotterdam

Dick HoflandLinklatersAmsterdam

Jeroen JanssenLoyens & LoeffAmsterdam

Wilbert Kannekens See bioKPMG Meijburg & CoAmsterdam

Godfried KinnegimAllen & OveryAmsterdam

Helmar KlinkEYAmsterdam

Friggo KraaijeveldKC LegalAmsterdam

Olaf KroonJSA Tax ConsultancyAmsterdam

Margriet LukkienLoyens & LoeffAmsterdam

Paulus MerksHouthoffAmsterdam

Michael Molenaars See bioStibbeAmsterdam

Wouter A PaardekooperBaker McKenzieAmsterdam

Bart RubbensLoyens & LoeffRotterdam

Erik T H ScheerBaker McKenzieAmsterdam

Paul H SleurinkDe Brauw Blackstone WestbroekAmsterdam

Jan L N SnelBaker McKenzieAmsterdam

Etienne SpiertsLoyens & LoeffAmsterdam

Michiel SundermanClifford ChanceAmsterdam

Marc TemmeKPMG Meijburg & CoAmstelveen

Ewout van AsbeckVan DoorneAmsterdam

Gesina van de WeteringVan Campen LiemAmsterdam

Eelco van der StokFreshfields Bruckhaus DeringerAmsterdam

Maarten van der WeijdenDe Brauw Blackstone WestbroekAmsterdam

J V (Valentijn) van Noorle JansenKPMG Meijburg & CoAmstelveen

Stef van Weeghel See bioPwCAmsterdam

Dennis WeberLoyens & LoeffAmsterdam

Bartjan ZoetmulderLoyens & LoeffAmsterdam

N O R WAYSvein G AndresenKPMG Law AdvokatfirmaOslo

Finn Backer-GrøndahlThommessenOslo

Einar BakkoSelmerOslo

Bettina BanounWiersholmOslo

Morten BeckPwCOslo

Caspar DekkerDeloitte NetherlandsGustav Mahlerlaan 2970Amsterdam, 1081 LANetherlands Tel: (31) 882881877Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Aart NoltenDeloitte NetherlandsGustav Mahlerlaan 2970Amsterdam, 1081 LANetherlands Tel: (31) 654706088Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Patrick van MinDeloitte NetherlandsWilhelminakade 1Rotterdam, 3072 APNetherlands Tel: (31) 882881989Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Rogier VanhorickDeloitte NetherlandsWilhelminakade 1Rotterdam, 3072 APNetherlands Tel: (31) 882888648Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 61


Joachim M BjerkeBAHROslo

Christin BøsterudEYOslo

Andreas BullenWiersholmOslo

Knut EkernHarboe & CoOslo

Morten FjermerosHjortOslo

J Christian GrevstadHarboe & CoOslo

Arne HaavindHaavindOslo

Steinar HareidePwCOslo

Harald HaugeHarboe & CoOslo

Anders HeierenKluge AdvokatfirmaOslo

Hanne Skaarberg HolenThommessenOslo

Øyvind HovlandEYOslo

Njaal Arne HøylandEYOslo

Ole Morten HusebyForsbergOslo

Sverre HvedingSelmerOslo

Jan B JansenBAHROslo

Oddgeir KjørsvikKPMG Law AdvokatfirmaOslo

Ståle R KristiansenThommessenOslo

Thor LeegaardKPMG Law AdvokatfirmaOslo

Anders H LilandKPMG Law AdvokatfirmaOslo

Anders MyklebustWikborg ReinOslo

Espen NordbøHaavindOslo

Tonje Christin NorrvallKPMG Law AdvokatfirmaOslo

Amund NossKluge AdvokatfirmaOslo

Per Daniel NybergKPMG Law AdvokatfirmaOslo

Ernst RavnaasSANDSOslo

Jan SamuelsenKPMG Law AdvokatfirmaOslo

Frode TalmoBAHROslo

P O L A N DMariusz AleksandrowiczFKA Furtek Komosa AleksandrowiczWarsaw

Piotr AugustyniakPATH Augustyniak Hatylak & PartnersWarsaw

Jaroslaw BieronskiSołtysiński Kawecki & SzlęzakWarsaw

Slawomir BorucBaker McKenzie Krzyżowski i WspólnicySpółka KomandytowaWarsaw

Marcin ChomiukJDP Drapala & PartnersWarsaw

Andrzej DebiecHogan LovellsWarsaw

Renata DluskaMDDPWarsaw

Karina Furga-DabrowskaDentonsWarsaw

Tomasz M KacymirowGreenberg Traurig Grzesiak sp.k.Warsaw

Marek KozaczukGreenberg Traurig Grzesiak sp.k.Warsaw

Robert KrasnodebskiRymarz ZdortWarsaw

Janusz MarciniukMarciniuk & PartnersWarsaw

Audun FrølandDeloitte NorwayDronning Eufemias gate 14Oslo, 0191NorwayTel: (47) 2327 9600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Tore PaulshusDeloitte NorwayDronning Eufemias gate 14Oslo, 0191NorwayTel: (47) 2327 9600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Rolf J SaastadDeloitte NorwayDronning Eufemias gate 14Oslo, 0191NorwayTel: (47) 2327 9600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

62 EXPERTGUIDES TAX


Andrzej MarczakKPMGWarsaw

Mariusz MareckiPwCWarsaw

Tomasz MichalikMDDPWarsaw

Irena OzogOzog TomczykowskiWarsaw

Andrzej PosniakCMSWarsaw

Karolina StawowskaWolf TheissWarsaw

Dorota SzubielskaRadzikowski Szubielska i WspólnicyWarsaw

Dariusz WasylkowskiWardynski & PartnersWarsaw

Magdalena ZasiewskaJDP Drapala & PartnersWarsaw

Andrzej ZubikPwCWarsaw

P O R T U G A LManuel Anselmo TorresGalhardo Vilão TorresLisbon

Rui BarreiraBCH LawyersLisbon

Catarina BelimBelimLisbon

António Pedro BragaMLGTSLisbon

Pedro Miguel BrazGarriguesLisbon

Francisco Cabral MatosVdALisbon

Serena Cabrita NetoPLMJLisbon

José Calejo GuerraCCSL AdvogadosLisbon

Rui Camacho PalmaLinklatersLisbon

Tiago Cassiano NevesGarriguesLisbon

Fernando Castro SilvaGarriguesLisbon

Ricardo da Palma BorgesRPBALisbon

Samuel Fernandes de AlmeidaVdALisbon

Tânia de Almeida FerreiraCCALisbon

Nuno de Oliveira GarciaGómez-Acebo & PomboLisbon

Francisco de Sousa da CâmaraMLGTSLisbon

Patrick DewerbeCMS Rui Pena & ArnautLisbon

João EspanhaEspanha e AssociadosLisbon

António Fernandes de OliveiraAFDOLisbon

Rogério M Fernandes FerreiraRFF & AssociadosLisbon

Maria FigueiredoMirandaLisbon

António GaioAntónio Frutuoso de Melo & AssociadosLisbon

Conceição GamitoVdALisbon

Joaquim Pedro LampreiaVdALisbon

Gonçalo Leite de CamposGonçalo Leite de Campos & AssociadosLisbon

António Lobo XavierMLGTSPorto

Marta Machado de AlmeidaRFF & AssociadosLisbon

Afonso ArnaldoDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427528 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Luis BeloDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427611 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Cláudia BernardoDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427513 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Paulo GasparDeloitte PortugalBom Sucesso Trade Center, Praça do BomSucesso, 61 - 13º, Porto, 4150-146 PortugalTel: (351) 225439240Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Luis LeonDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427542 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 63


Tiago Marreiros MoreiraVdALisbon

Pedro Vidal MatosCuatrecasasLisbon

Paulo MendoncaEYLisbon

António Moura PortugalDLA Piper ABBCLisbon

António NevesEYLisbon

Diogo Ortigão RamosCuatrecasasLisbon

José Pedroso de MeloSRS AdvogadosLisbon

João Riscado RapoulaVdALisbon

Ricardo Reigada PereiraRRP AdvogadosLisbon

Miguel C ReisPLMJPorto

António Rocha MendesCampos Ferreira Sá Carneiro - CSAssociadosLisbon

Filipe RomãoUría MenéndezLisbon

Bruno SantiagoMLGTSLisbon

Ricardo Seabra MouraVdALisbon

Pedro Soares da SilvaMLGTSLisbon

João SousaEYLisbon

Miguel Teixeira de AbreuAbreu AdvogadosLisbon

R O M A N I A

Jean-Marc CambienEYBucharest

Razvan Gheorghiu-TestaTuca Zbârcea & AsociatiiBucharest

Alexander MilcevEYBucharest

Angela RoscaTaxHouseBucharest

Ionut SimionPwCBucharest

R U S S I AVladimir AbramovEYMoscow

Rustem AkhmetshinPepeliaev GroupMoscow

Valentina AkimovaPepeliaev GroupMoscow

Alexander BychkovBaker McKenzieMoscow

Alexander ChmelevBaker McKenzieMoscow

Irina DmitrievaWhite & CaseMoscow

Dzhangar DzhalchinovDentonsMoscow

Sergey KalininEgorov Puginsky Afanasiev & PartnersMoscow

Oleg KonnovHerbert Smith FreehillsMoscow

Alexei KuznetsovEYMoscow

Victor MatchekhinLinklatersMoscow

Petr MedvedevEYMoscow

Miguel Leonidas RochaDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427530 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Rosa Maria SoaresDeloitte PortugalAv. Eng. Duarte Pacheco, 7Lisboa, 1070-100Portugal Tel: (351) 210427518 Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Dan BadinDeloitte Romania82-98 Calea Grivitei, The Mark Tower, 14thFloor, District 1, 010735, BucharestRomania Tel: (40) 2120 75378; (40) 2120 75392Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Vlad BoeriuDeloitte Romania82-98 Calea Grivitei, The Mark Tower, 14thFloor, District 1, 010735, BucharestRomania Tel: (40) 2120 75378; (40) 2120 75341Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Gennady KamyshnikovDeloitte Russia5 Lesnaya St., Bldg. B Business CenterWhite Square, Moscow, 125047 Russian Federation Tel: (7) 4957870600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Natalia KuznetsovaDeloitte Russia5 Lesnaya St., Bldg. B Business CenterWhite Square, Moscow, 125047 Russian Federation Tel: (7) 4957870600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

64 EXPERTGUIDES TAX


Galina NaumenkoPwCMoscow

Andrey NikonovPepeliaev GroupMoscow

Sergey G PepeliaevPepeliaev GroupMoscow

Maxim RovinskiyinfralexMoscow

Denis SchekinSchekin & PartnersMoscow

Igor SchikowEgorov Puginsky Afanasiev & PartnersMoscow

Arseny SeidovBaker McKenzieMoscow

Evgeny TimofeevBryan Cave Leighton PaisnerMoscow

Ruslan VasutinDLA PiperSt Petersburg

Igor VenediktovDLA PiperMoscow

Maxim VladimirovNoerrMoscow

Sergei V ZhestkovBaker McKenzieMoscow

Anna ZverevaDentonsMoscow

S PA I NEduardo Abad ValdenebroGarriguesMadrid

Carlos AlbiñanaJones DayMadrid

José Ignacio Alemany BellidoAlemany Escalona & De FuentesMadrid

Felipe Alonso FernándezGTA Villamagna AbogadosMadrid

Álvaro AntónCuatrecasasMadrid

Javier Artiñano Rodríguez de TorresDe Andrés y ArtiñanoMadrid

Miró AyatsCuatrecasasMadrid

María Antonia AzpeitiaBaker McKenzieMadrid

Antonio BarbaCuatrecasasMadrid

Luis BrionesBaker McKenzieMadrid

Rafael Calvo SalineroGarriguesMadrid

Guillermo CanalejoUría MenéndezMadrid

Iratxe CelayaUría MenéndezBilbao

Albert Collado ArmengolGarriguesBarcelona

Araceli Saenz de Navarrete CrespoEYMadrid

Isidro del Saz CorderoMontero Aramburu AbogadosMadrid

Abelardo Delgado PachecoGarriguesMadrid

Santiago DíezMarimon AbogadosMadrid

Alejandro EscodaCuatrecasasBarcelona

Rafael FusterUría MenéndezMadrid

Rafael GarcíaUría MenéndezMadrid

Javier García-PitaLinklatersMadrid

Javier GazullaHogan LovellsMadrid

Carlos Gómez BarreroGarriguesMadrid

Eduardo GraciaAshurstMadrid

Roberto GrauClifford ChanceMadrid

Svetlana MeyerDeloitte Russia5 Lesnaya St., Bldg. B Business CenterWhite Square, Moscow, 125047 Russian Federation Tel: (7) 4957870600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Elena SolovyovaDeloitte Russia5 Lesnaya St., Bldg. B Business CenterWhite Square, Moscow, 125047 Russian Federation Tel: (7) 4957870600Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Nicolás de GaviriaDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 911578875Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Borja Escrivá de RomaníDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 914381065Email: [email protected]: www.deloitte.comSee page 26 for regional profile

TAX EXPERTGUIDES 65


Javier Hernández GalanteAshurstMadrid

Joan HortaláCuatrecasasBarcelona

Clara JiménezPérez-LlorcaMadrid

Federico LinaresEYMadrid

Jesús López TelloUría MenéndezMadrid

Nicolás MartínHerbert Smith FreehillsMadrid

Javier MoreraBroseta AbogadosMadrid

Natalia Pastor CaballeroKPMG AbogadosMadrid

Silvia PaternainFreshfields Bruckhaus DeringerMadrid

Lourdes Pérez-LuqueLópez-Ibor AbogadosMadrid

Carlos RodríguezDLA PiperMadrid

Andrés SánchezCuatrecasasMadrid

Miguel Ángel SánchezHogan LovellsMadrid

Luis TrigoBroseta AbogadosMadrid

Andreas TrostCuatrecasasBarcelona

Blanca Uson VegasRoca JunyentMadrid

Eduardo Abad ValdenebroGarriguesMadrid

Sonia VelascoCuatrecasasBarcelona

Víctor VianaUría MenéndezMadrid

Luis Manuel ViñualesGarriguesMadrid

Adolfo ZunzuneguiAllen & OveryMadrid

S W E D E NThomas Andersson See bioKPMGStockholm

Mats Andersson LohiEYGöteborg

Fredrik BerndtSvalner Skatt & TransaktionStockholm

Erik BjörkesonDLA PiperStockholm

Lars BosonKPMGStockholm

Jari BurmeisterSkeppsbron SkattStockholm

Anders ErasmieMannheimer SwartlingStockholm

Mattias FriSvalner Skatt & TransaktionStockholm

Jörgen Graner See bioKPMGStockholm

Martin NilssonMannheimer SwartlingStockholm

Luis Fernando GuerraDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 914381932Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Brian LeonardDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 914381023Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Isabel Lopez-BustamanteDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 914432105Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Ana ZarazagaDeloitte LegalTorre Picasso - Plaza Pablo Ruiz Picasso 1,Madrid 28020 Spain Tel: (34) 914381604Email: [email protected]: www.deloitte.comSee page 26 for regional profile

Sara BolmstrandDeloitte SwedenRehnsgatan 11 Stockholm, 113 79 Sweden Tel: (46) 70 080 30 43Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Lars FranckDeloitte SwedenRehnsgatan 11 Stockholm, 113 79 Sweden Tel: (46) 73 397 21 26Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Henrik KarlssonDeloitte SwedenRehnsgatan 11 Stockholm, 113 79 SwedenTel: (46) 76 827 73 93Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Magnus LarssonDeloitte SwedenBox 33 Göteborg, 401 20 Sweden Tel: (46) 73 397 73 17Email: [email protected]: www.deloitte.comSee page 28 for regional profile

66 EXPERTGUIDES TAX


Johan RasmussenDeloitte SwedenStockholm

Helena Robertsson See bioEYStockholm

Viktor SandbergSvalner Skatt & TransaktionStockholm

Mattias SchömerVingeStockholm

Christian SjöqvistSetterwallsGöteborg

Johan SjöqvistPwCStockholm

Lennart Staberg See bioPwCStockholm

Jan SvenssonSkeppsbron SkattStockholm

Tina Zetterlund See bioKPMGStockholm

S W I T Z E R L A N DJürg AltorferADB Altorfer Duss & BeilsteinZürich

Daniel BaderBär & KarrerZürich

Maja Bauer-BalmelliTax Advisors & AssociatesZürich

Marco A BlancoCurtis Mallet-Prevost Colt & MosleGeneva/Paris/New York

Martin BusenhartWalder WyssZürich

Fabian DussADB Altorfer Duss & BeilsteinZürich

Jean-Blaise Eckert See bioLenz & StaehelinGeneva

Pierre-Marie GlauserOberson AbelsLausanne

Thomas GrafNiederer Kraft FreyZürich

Dieter GrünblattHomburgerZürich

Nils HarbekePestalozzi Attorneys at LawZürich

Reto HeubergerHomburgerZürich

Pascal HinnyLenz & StaehelinZürich

Marcel R JungFroriepZürich

Hans KochBaker McKenzieZürich

Andreas KolbKOLB International Tax ServicesZürich

Markus E KronauerNiederer Kraft FreyZürich

Mario KumschickBaker McKenzieZürich

Daniel U LehmannBär & KarrerZürich

Hubertus LudwigLudwig + PartnerBasel

Jean-Frédéric MaraiaSchellenberg WittmerGeneva

Thomas MeisterWalder WyssZürich

Victor MeyerPwCZürich

Frédéric NeukommLenz & StaehelinGeneva

Michael NordinSchellenberg WittmerZürich

Xavier ObersonOberson AbelsGeneva

Stefan OesterheltHomburgerZürich

Andrio OrlerCMS von Erlach PoncetGeneva

Stephan PfenningerTax Partner AGZürich

Philip RobinsonEYZürich

Johan RasmussenDeloitte SwedenRehnsgatan 11 Stockholm, 113 79 SwedeTel: (46) 70 080 29 59Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Reto GerberDeloitte SwitzerlandGeneral Guisan-Quai 38 8022 Zurich Zurich, 8022 Switzerland Tel: (41) 58 279 66 75Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Jackie HessDeloitte SwitzerlandGeneral Guisan-Quai 38 8022 Zurich Zurich, 8022 Switzerland Tel: (41) 58 279 6312Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Jacques KistlerDeloitte SwitzerlandRue du Pre-de-la-Bichette 1 Geneva, 1202 SwitzerlandTel: (41) 58 279 8164Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 67


Heini RüdisühliLenz & StaehelinZürich

David RyserTax Partner AGZürich

Pietro SansonettiSchellenberg WittmerGeneva

Daniel SchaferLenz & StaehelinGeneva

Daniela SchmuckiNiederer Kraft FreyZürich

Susanne SchreiberBär & KarrerZürich

Jonas SigristPestalozzi Attorneys at LawZürich

Nadia Tarolli SchmidtVischerBasel

Markus WeidmannWeidmann Weidmann RechtsanwälteZürich

T U R K E YKadir BasPwCIstanbul

Timur CakmakKPMGAnkara

Erdal ÇalikogluEYIstanbul

Zeki GündüzPwCIstanbul

A Feridun GüngörEYIstanbul

Abdulkadir KahramanEYIstanbul

Mehmet MaçBDOIstanbul

Yavuz ÖnerKPMGIstanbul

Erdoğan SağlamBDOIstanbul

Yuksel ToparlakPwCIstanbul

Bilgutay YasarPwCIstanbul

U K R A I N E

Yevgeniya DerbalKonnov & SozanovskyKyiv

Vladimir KotenkoEYKyiv

Oleh MarchenkoMarchenko PartnersKyiv

Alexander MininWTS ConsultingKyiv

Ivan ShynkarenkoWTS ConsultingKyiv

Slava VlasovPwCKyiv

Hennadiy VoytsitskyiBaker McKenzieKyiv

U N I T E DK I N G D O MJames AndersonSkadden Arps Slate Meagher & FlomLondon

Philip Baker QCField Court Tax ChambersLondon

Mark BaldwinMacfarlanesLondon

Sandy BhogalGibson Dunn & CrutcherLondon

Jan BirtwellO'Melveny & MyersLondon

Adam BlakemoreCadwalader Wickersham & TaftLondon

Helen BuchananFreshfields Bruckhaus DeringerLondon

Jeremy CapeSquire Paton BoggsLondon

Alex ChadwickBaker McKenzieLondon

Lydia ChallenAllen & OveryLondon

Murray ClaysonFreshfields Bruckhaus DeringerLondon

Niyazi ComezDeloitte TurkeyEski Büyükdere Caddesi Maslakno1 PlazaMaslak, Istanbul, 34398 Turkey Tel: (90) 212 366 6069Website: www.deloitte.comSee page 28 for regional profile

Alexander CherinkoDeloitte Ukraine48-50a Zhylyanska St. Business Center Prime Kyiv, 01030 Ukraine Tel: (380) 444909000Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Victoria ChornovolDeloitte Ukraine48-50a Zhylyanska St. Business Center Prime Kyiv, 01030 Ukraine Tel: (380) 444909000Email: [email protected]: www.deloitte.comSee page 28 for regional profile

68 EXPERTGUIDES TAX


Peter ClementsFreshfields Bruckhaus DeringerLondon

Brenda A ColemanRopes & GrayLondon

Jason CollinsPinsent MasonsLondon

Jonathan CooklinDavis Polk & WardwellLondon

Mark DelaneyBaker McKenzieLondon

Justine DelroyAddleshaw GoddardManchester

Ed DennyWinston & StrawnLondon

Jenny DoakWeil Gotshal & MangesLondon

Sophie Donnithorne-TaitAkin Gump Strauss Hauer & FeldLondon

Steve EdgeSlaughter and MayLondon

David Ewart QCPump Court Tax ChambersLondon

Liesl FichardtQuinn Emanuel Urquhart & SullivanLondon

Sean FinnLatham & WatkinsLondon

Malcolm Gammie QCOne Essex CourtLondon

Fred R GanderKPMGLondon

Melissa GeigerKPMGLondon

Heather GethingHerbert Smith FreehillsLondon

Julian Ghosh QCOne Essex CourtLondon

Ashley GreenbankMacfarlanesLondon

Judith HargerWillkie Farr & GallagherLondon

David HarknessClifford ChanceLondon

Derek HillFieldfisherLondon

Karen HughesHogan LovellsLondon

Russell JacobsMilbankLondon

Michael JonesGray's Inn Tax ChambersLondon

Mike LaneSlaughter and MayLondon

Helen LethabyFreshfields Bruckhaus DeringerLondon

Matthew MealeyEYLondon

Nikhil MehtaGray's Inn Tax ChambersLondon

Simon MeredithNGM Tax LawLondon

David Milne QCPump Court Tax ChambersLondon

Frank Mitchell SCMonckton ChambersLondon

Dan NeidleClifford ChanceLondon

Peter NiasPump Court Tax ChambersLondon

Peter ReinhardtEYLondon

Philip RidgwayTemple Tax ChambersLondon

James RossMcDermott Will & EmeryLondon

Yash RupalSimpson Thacher & BartlettLondon

Kathleen RussTravers SmithLondon

Angela SavinKPMGLondon

Jonathan S SchwarzTemple Tax ChambersLondon

Christopher J ScottKPMGLondon

Drew ScottSidley AustinLondon

Nicola Shaw QCGray's Inn Tax ChambersLondon

Rupert ShiersHogan LovellsLondon

Stuart SinclairAkin Gump Strauss Hauer & FeldLondon

Philip MillsDeloitte LLP, the UK Deloitte member firm2 New Street Square London, EC4A 3BZ UK Tel: (44) 20 7007 8602Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 69


James SmithBaker McKenzieLondon

Dominic StuttafordNorton Rose FulbrightLondon

Vimal TilakapalaAllen & OveryLondon

Jeffrey M TrinkleinGibson Dunn & CrutcherLondon/New York

Lynne WalkingtonLinklatersLondon

William WatsonSlaughter and MayLondon

Patrick Way QCField Court Tax ChambersLondon

Dominic WinterLinklatersLondon

Michael WistowWhite & CaseLondon

Charles YorkeAllen & OveryLondon

Isaac ZailerHerbert Smith FreehillsLondon

Lisa StottDeloitte LLP, the UK Deloitte member firmAbbots House Abbey Street Reading, RG1 3BD UK Tel: (44) 118 322 2312Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Andrew WildeDeloitte LLP, the UK Deloitte member firm2 Hardman Street Manchester, M3 3HF UK Tel: (44) 161 455 8556Email: [email protected]: www.deloitte.comSee page 28 for regional profile

James WrightDeloitte LLP, the UK Deloitte member firm2 New Street Square London, EC4A 3BZ UK Tel: (44) 20 7007 3979Email: [email protected]: www.deloitte.comSee page 28 for regional profile

70 EXPERTGUIDES TAX


L AT I N A M E R I C A A N D T H E C A R I B B E A N

Q&A with:

Ricardo González Orta of Deloitte Mexico 73

Argentina 75

Bermuda 75

Bolivia 75

Brazil 75

Chile 77

Colombia 78

Costa Rica 79

Curaçao 79

Dominican Republic 79

Ecuador 79

El Salvador 79

Honduras 79

Mexico 79

Paraguay 80

Peru 80

Uruguay 81

Venezuela 81

TAX EXPERTGUIDES 71

REGIONAL PROFILE LATIN AMERICA AND THE CARIBBEAN

Deloitte LATAM Regional Profile

Paseo de la Reforma 505, Colonia CuauhtémocCiudad de México CP 06500México Tel: +52 (55) 5080 6000Email: [email protected] Twitter: @DeloitteWebsite: Deloitte.com/taxOffices: 80 Number of professionals: 5,730

Our broad network allows us to deploy the right local and regionalteams quickly. The Latin America and Caribbean tax teams consistof over 5,730 professionalsbacked by approximately 115,000 and264,000 regional and global professionals, respectively, across allbusinesses. Regional Deloitte Tax & Legal teams are present acrossthe globe to deliver services locally, while coordinating engage-ments from a central location. In addition, Deloitte capabilities andstrengths of all businesses – Audit & Assurance, Consulting, andRisk & Financial Advisory – deliver broad-scale tax aligned businesssolutions.

Tax and Legal services in the region have consistently grown overthe years, triggered by the largest economies – Brazil, Mexico, Colom-bia, Chile, Argentina and Central America. Corporate business tax re-mains the dominant service in the region followed by Tax Compliance& Reporting, Transfer Pricing, Indirect Taxes, Legal services and Em-ployer services.

Deloitte is heavily investing in tax technology and analytics capa-bilities as well as our alignment with the broader firm’s global plat-forms. The practice offers highly effective, flexible tools that helpclients comply with rules such as the Foreign Account Tax Compli-ance Act, Common Reporting Standard, Local Country tax compli-ance including meeting local electronic books and recordsrequirements, and consistent advisory and compliance services suchas transfer pricing on both regional and global basis.

Present in Latin American and Caribbean helping clients refineand update their tax procedures and compliance & reporting systems.Deloitte is working with them to assess their tax teams, current pro-cesses, and technologies to respond to the changing demands of elec-tronic filing, e-invoicing, and e-audits in the region, as local taxauthorities continue to leverage technology in their collection and ad-ministrative efforts.

Latin America and the Caribbean are emerging markets where De-loitte is well-positioned as a leader in the largest metropolitan areas.Size and scale in each location supports both, global and local marketgrowth. The firm s largest tax and legal practices in the Latin Amer-ica/Caribbean region include Argentina, Brazil, Chile, Colombia, andMexico. Market presence further reaches across the region with strongpractices in Aruba, the Bahamas, Barbados, Bermuda, Bolivia, the

Cayman Islands, Costa Rica, Curacao, Dominican Republic, Ecuador,El Salvador, Guatemala, Honduras, Nicaragua, Panama, Paraguay,Peru, St. Maarten, Trinidad & Tobago, Uruguay, Venezuela, and theVirgin Islands (British & US).

Our key service offerings• Business Tax (Tax Compliance and Reporting; Tax Controversy;

Tax Implications of Business Change; Business, High Net Worth,and International Tax Consulting)

• Business Process Solutions• Global Employer Services• Global Investments and Innovation Incentives • Indirect Tax (including Global Trade Advisory)• Mergers & Acquisitions• Tax Management Consulting• Transfer Pricing• Deloitte Legal

Recent wins: • Three-year global compliance and transfer pricing documenta-

tion engagement for a Latin America’s leading flat steel pro-ducer, with operations in Mexico, Brazil, Argentina, Colombia,the southern United States and Central America through re-gional manufacturing facilities, service centers and distributionnetworks. The proposal includes preparing the transfer pricingdocumentation for 29 legal entities distributed in 11 countries

• Payroll process automation solution through robotics technol-ogy for more than 100 clients that reduces processing time, in-creases time for analysis and approval, helps deliver deadlinesand most importantly, completes payroll taxes calculations tomeet compliance obligations

• Tax Technology Consulting (within Tax Management Consult-ing) engagement to support the S4 HANA Tax engine for a com-pany through collaboration with Deloitte Consulting and thebroader regional network including Colombia, Brazil, Mexico,and the US

• Compliance reporting engagement with a large manufacturingclient to provide services over five years related to Indirect TaxVAT, and withholding tax with thirteen Latin America countriesin scope including Argentina, Guatemala , Colombia, Peru, Hon-duras, Venezuela, Uruguay, Puerto Rico, Costa Rica, Panama, ElSalvador, Chile and Mexico plus Canada

• Two-Year regional Engagement for Expatriate Tax Assistance tosupport a Large Consulting Company in designing a Policy andimplementation of technology for trailing mobile employeesthrough collaboration with Immigration team and the broaderregional network in Latin America including: Argentina, Colom-bia, Costa Rica, Panama, Guatemala and Mexico.


72 EXPERTGUIDES TAX

LATIN AMERICA AND THE CARIBBEAN REGIONAL PROFILE

Awards: 2018• Americas Transfer Pricing, Tax Technology and Tax Compliance &

Reporting firm of the year• Colombia, Peru and Central America Transfer Pricing firm of the

year (ITR)• Venezuela Tax firm of the year (ITR)

2019• Americas Transfer Pricing, Tax Technology and Indirect Tax firm

of the year• Mexico, Argentina, Peru and Central America Transfer Pricing firm

of the year

Eminent Leaders:• Atilio Cataldo [Argentina]• Ricardo Gonzalez Orta (LATAM)• Hugo Hurtado (Chile) • Diego Franco (Colombia)• Joao Gumiero (Brazil)• Jorge Sánchez Hernández (México)







TAX EXPERTGUIDES 73

Q&A LATIN AMERICA AND THE CARIBBEAN

Q&A with Ricardo González OrtaPartner, Spanish Latin America Tax & Legal leaderDeloitte Mexico

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?There has been a confluence of events over the last year and a half thathave contributed to a rapidly changing tax landscape in Latin America(LATAM). Several countries, including Argentina, Brazil, Colombia,Chile, Costa Rica, and Mexico, have witnessed tax reforms with differ-ing objectives. While some of the reforms have resulted in a reductionof the corporate tax rates and simplification of the tax system with aview to promoting investment, others have taken a different approach,introducing new taxes or strengthening collection procedures on digi-tal supplies of goods and/or services traded through digital platforms.

One unifying theme embraced by all the LATAM countries (andthe general focus of our responses below) is the introduction of real-time or near real-time reporting requirements, which require busi-nesses to provide much more detailed information—on acontemporaneous basis—to the tax authorities. This heightenedtransparency that comes with real-time reporting means that the taxauthorities will have more access to (and insight into) a taxpayer’sbusiness operations and transactions and taxpayers will use the newcompliance requirements as an impetus to harness new technologiesto scale-up and better automate their systems and processes.

In addition, governments throughout LATAM are adoptingOECD-driven recommendations in areas such as anti-base erosionmeasures and transfer pricing reporting. Measures relating to the firstcategory include limits on the deduction of interest expense, limits onthe deferral of taxation of CFC-related income in appropriate cases,and adoption of the expanded definition of a permanent establish-ment. Unfortunately, there is little coordination across LATAM gov-ernments in adopting BEPS-type measures, so taxpayers will need tohave a cogent understanding of the landscape to ensure they are incompliance and able to manage any potential tax risk.

Further, the following “international” developments have had (orare expected to have) an impact on how investments in the LATAMregion are structured and operate:• Implementation of the OECD Multilateral Instrument; • 2019 US tax reform;• Potential direct and indirect tax reform in Brazil as part of its ef-

forts to join the OECD (changes to Brazil’s approach to transferpricing are already being contemplated and certain OECD recom-mendations, such as country-by-country reporting, have been im-plemented); and

• New free trade agreement (USMCA) approved by Canada, Mexicoand the US that replaces NAFTA and that will enter into force overthe short term.

What was the most notable effect of that change?Organizations are increasingly turning to digital technologies to auto-mate their tax systems via consistent processes to comply with in-

creased reporting and compliance obligations and to enable them tomodel their tax profiles, given the changing tax landscape. The diver-sity of legislation across Latin America, however, requires that newprocesses and technologies be customized for each jurisdiction tomeet local requirements. The taxation of digital platforms, in particu-lar, will change the landscape of digitized services and create potentialdouble taxation issues.

Where is the market moving in this practice area?These market conditions demand that we deliver timely and technol-ogy-aligned tax advice to help clients more efficiently and effectivelycomply with information and reporting requirements through in-creased visibility and controls. We also bring value to clients by helpingthem extract more data through automation and by performing dataanalytics and modelling for better access to information and deeper in-sights into the performance of their business and overall tax profile.

What kind of impact will this have on your work?Our fundamental approach to client projects has not changed as a re-sult of recent developments. We continue to offer our clients consis-tent and quality tax advice, helping them address both existing andemerging business challenges and tax issues with confidence. With theuse of innovative technologies, we also realize the need in many in-stances to properly report, model and present our tax advice on a real-time basis.

L AT I N A M E R I C A

74 EXPERTGUIDES TAX

LATIN AMERICA AND THE CARIBBEAN Q&A

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?While the push for enhanced transparency and information disclo-sure are certain to continue, legislative changes are possible in cer-tain jurisdictions due to upcoming elections coupled with regionalpolitical developments, which could drive major tax reform and/orthe renegotiation of significant trade agreements such as the UnitedStates – Mexico – Canada free trade agreement (USMCA). In-creased transparency could also mean more controls for cross-bor-der transactions. In addition, new digital tax compliance rulescould have impact processes such as electronic invoicing and digitalaccounting reports.

As noted above, OECD initiatives have had a considerable influ-ence on international tax policy in the LATAM region, with countriesadopting (or intending to adopt) various BEPS-related measures intotheir domestic tax legislation and signing onto the MLI. The tax treat-ment of digital businesses is another topic that is being discussed aspart of the tax policy agendas throughout the region.

If these come into force, how will the industry look in thefuture?Companies may need to consider changes to their supply chain, op-erating models, and legal entity structures in the event of future taxreform(s) or the renegotiation of trade agreements. In an environ-ment where there is a push for centralization of real-time reportingand more detailed data requests, we envision that companies mayneed to model out the potential impacts of tax reform in certain ju-risdictions quickly.

How would you describe the tax controversy landscape inyour region/jurisdiction?The tax controversy environment in the LATAM region is challenging interms of escalating challenges by the tax authorities (and appeals toeither non-tax specialized courts or tax specialized courts) and theduration of tax litigation. In some countries, such as Brazil and Mexico,it is not uncommon for court cases to last for five to 10 years. Whilenegotiation processes are becoming more popular, some countries inthe region do not allow this type of out-of-court settlement.International means of dispute resolution also are on the rise (if allowedby the relevant countries), either by way of a mutual agreementprocedure or arbitration under a double taxation treaty. However, taxauthorities acting as competent authorities for these purposes may notbe fully prepared to navigate alternative means of dispute resolution.

This environment is likely to be further complicated as the region’sneeds for additional tax collection is intensified.

Do you expect tax procedures in your region to move towardscommon standards or diverge in the future?Many of the tax systems in the LATAM region share similarities (asidefrom Brazil), which can be explained by a historic modeling or adop-tion of Mexico’s overall tax system structure. Considering that mostcountries in LATAM are paying attention to OECD efforts and oftenadopt OECD recommendations, it is likely that there will be commonapproaches to tax policy, especially in the areas of international taxa-tion, transfer pricing, global reporting and exchange of information.However, tax policy agendas tend to change and adjustments are com-mon when new governments are elected—depending on the circum-stances, governments may adjust the tax framework to a more“business-friendly” environment or conversely move towards moreaggressive taxation measures.

As noted above, a tax reform is anticipated in Brazil as part of its ef-forts to join the OECD.

Is the global drive towards regulation going to affect tax practice?If yes, in which areas?With technology and digitalization rapidly gaining ground by both thetax authorities and taxpayers, the use of technology, artificial intelligenceand automation has been our approach and will continue to be so. Sincethis is a venture that demands constant evolution, tax technology willcontinue to be an important element of our practice and a natural con-sequence of automation is that tax specialists will be enabled to be morefocused on strategic decisions and advice, using data to drive analyticsthat lead to better answers.

What do you see as the direct impact of COVID-19 in yourpractice?It is an understatement to say that the COVID-19 pandemic has pre-sented extensive challenges to organizations worldwide. Our first prior-ity is to safeguard our people, clients and communities, while at the sametime we need to ensure the delivery of quality and timely services withminimal disruption. Strengthening digital capabilities as businesses havetransitioned to remote working, adopting changes to supply chains andoperating models, and engaging in crisis management are imperativesfor many businesses, and once the crisis begins to ease, it will be neces-sary to shift focus to a recovery phase as clients begin to resume regularoperations and quickly adjust to a “new normal.”






L AT I N A M E R I C A

TAX EXPERTGUIDES 75

EXPERT LISTINGS LATIN AMERICA AND THE CARIBBEAN

A R G E N T I N ARubén O AsoreyAsorey & NavarrineBuenos Aires

Martín J BarreiroBaker McKenzieBuenos Aires

Manuel BenitesPAGBAMBuenos Aires

María Inés BrandtMarval O'Farrell & MairalBuenos Aires

Gabriela Inés BurattiAbeledo Gottheil AbogadosBuenos Aires

Carlos CasanovasEYBuenos Aires

Valeria D’AlessandroGoldemberg Saladino Hermida Rolando& AsociadosBuenos Aires

Daniel DassoEYBuenos Aires

Valeria EstathioO'FarrellBuenos Aires

Jorge GebhardtAguirre Saravia & GebhardtBuenos Aires

Eduardo Gil RocaPwCBuenos Aires

Cecilia GoldembergGoldemberg Saladino Rolando ClercBuenos Aires

Gabriel GotlibMarval O'Farrell & MairalBuenos Aires

Walter César KeinigerMarval O'Farrell & MairalBuenos Aires

Liban A KusaBruchou Fernández Madero & LombardiBuenos Aires

Guillermo LalanneO'FarrellBuenos Aires

Ezequiel LipovetzkyBruchou Fernández Madero & LombardiBuenos Aires

Sebastián López SansónSalaberren & López SansónBuenos Aires

Rubén H MalvitanoAguirre Saravia & GebhardtBuenos Aires

Alejandro E MessineoBomchilBuenos Aires

Ricardo Mihura EstradaLeverone & Mihura EstradaBuenos Aires

Santiago MontezantiEstudio Beccar VarelaBuenos Aires

Luis Marcelo NuñezPAGBAMBuenos Aires

Matías Olivero VilaBruchou Fernández Madero & LombardiBuenos Aires

Leandro M PassarellaPassarella AbogadosBuenos Aires

Horacio García PrietoMarval O'Farrell & MairalBuenos Aires

Darío RajmilovichRajmilovich & ForcadaBuenos Aires

Eduardo Raúl MujicaAbeledo Gottheil AbogadosBuenos Aires

Cristian E Rosso AlbaRosso Alba Francia & AsociadosBuenos Aires

Alberto TarsitanoBulit Goñi & TarsitanoBuenos Aires

Guillermo O TeijeiroTeijeiro & BalloneBuenos Aires

Miguel TesónO'FarrellBuenos Aires

Fernando Martin VaqueroMarval O'Farrell & MairalBuenos Aires

B E R M U D A

B O L I V I AJaime Eduardo Araújo CamachoAraujo & ForguesSanta Cruz

Elbio Pérez LopezBenítez Rivas Pérez & AsociadosSanta Cruz

B R A Z I LDaniel Abraham LoriaBMA - Barbosa Müssnich AragãoSão Paulo

Abel AmaroVeirano AdvogadosSão Paulo

Paulo Barreto AyresAires Barreto AdvogadosSão Paulo

Daniel Horacio CaraccioloDeloitte ArgentinaFlorida 234. Floor 5th Buenos Aires, C1005AAFArgentina Tel: (54) 11 4321 3003Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Christian FucinosDeloitte ArgentinaFlorida 234. Floor 5th Buenos Aires, C1005AAFArgentina Tel: (54) 11 4320 4020Email: [email protected]: www.deloitte.comSee page 71 for regional profile

James DockerayDeloitte Ltd. BermudaCorner House, 20 Parliament StreetHamilton, HM 12Bermuda Tel: (1) 44 1524 1399Email: [email protected]: www.deloitte.comSee page 71 for regional profile

76 EXPERTGUIDES TAX

LATIN AMERICA AND THE CARIBBEAN EXPERT LISTINGS

Roberto BarrieuCescon Barrieu Flesch & BarretoAdvogadosSão Paulo

Luiz Frederico BattendieriNeves & BattendieriSão Paulo

Andrea Bazzo LaulettaMattos FilhoSão Paulo

Ricardo Luiz BeckerPinheiro Neto AdvogadosSão Paulo

Isabel A BertolettiMachado AssociadosSão Paulo

João Francisco BiancoMariz de Oliveira e Siqueira CamposAdvogadosSão Paulo

Luiz Gustavo A S BicharaBichara AdvogadosRio de Janeiro

Elidie Palma BifanoMariz de Oliveira e Siqueira CamposAdvogadosSão Paulo

Gustavo BrigagãoBrigagão Duque-EstradaRio de Janeiro

Isabel BuenoMattos FilhoSão Paulo

Sacha CalmonSacha Calmon Misabel DerziConsultores e AdvogadosBelo Horizonte

Bruno CarramaschiLefosse AdvogadosSão Paulo

Roque Antônio CarrazzaRoque Carrazza Advogados AssociadosSão Paulo

Vivian CasanovaBMA - Barbosa Müssnich AragãoSão Paulo/Rio de Janeiro

Luiz Felipe Centeno FerrazMattos FilhoSão Paulo

Tércio ChiavassaPinheiro Neto AdvogadosSão Paulo

Celso CostaMachado Meyer Sendacz e OpiceSão Paulo

Marienne CoutinhoKPMGSão Paulo

Eloisa de Almeida Rego Barros CuriDemarest AdvogadosSão Paulo

Thais De Barros BeiraBMA - Barbosa Müssnich AragãoSão Paulo

Marcos de CarvalhoLefosse AdvogadosSão Paulo

Mauricio de Carvalho Silveira BuenoHuck Otranto CamargoSão Paulo

Júlio M de OliveiraMachado AssociadosSão Paulo

Karem DiasRivitti Dias AdvogadosSão Paulo

Hamilton Dias de SouzaDias de Souza Advogados AssociadosSão Paulo

Roberto Duque EstradaBrigagão Duque-EstradaRio de Janeiro

Renata EmeryStocche Forbes AdvogadosRio de Janeiro

Bruno FajersztajnMariz de Oliveira e Siqueira CamposAdvogadosSão Paulo

Ricardo Ferreira BolanLefosse AdvogadosSão Paulo

André Gomes de OliveiraCastro Barros AdvogadosRio de Janeiro

Antonio Carlos Guidoni FilhoVella Pugliese Buosi e Guidoni -AdvogadosSão Paulo

Gustavo Lian HaddadLefosse AdvogadosSão Paulo

José Otavio Haddad FaloppaBMA - Barbosa Müssnich AragãoSão Paulo

Leo KrakowiakAdvocacia KrakowiakSão Paulo

Ricardo KrakowiakAdvocacia KrakowiakSão Paulo

Daniel Lacasa MayaMachado AssociadosSão Paulo

Tacio Lacerda GamaLacerda Gama AdvogadosSão Paulo

Glaucia M Lauletta FrascinoMattos FilhoSão Paulo

Clarissa G MachadoTrench Rossi e WatanabeSão Paulo

Stephanie MakinMachado AssociadosSão Paulo

Cristina Arantes A BerryDeloitte BrazilAv. Dr. Chucri Zaidan, 1.240From 4th to 12th floors - Golden TowerSão Paulo, SP, 04709-111, Brazil Tel: (55) 11 5186 1013Email: [email protected]: www.deloitte.com.brSee page 71 for regional profile

Luiz Fernando R GomesDeloitte BrazilRua São Bento, 1815th and 16th floorsRio de Janeiro, RJ, 20090-010, BrazilTel: (55) 21 3981 0451Email: [email protected]: www.deloitte.com.brSee page 71 for regional profile

Douglas LopesDeloitte BrazilAv. Dr. Chucri Zaidan, 1.240From 4th to 12th floors - Golden TowerSão Paulo, SP, 04709-111, Brazil Tel: (55) 11 5186 1002Email: [email protected]: www.deloitte.com.brSee page 71 for regional profile

TAX EXPERTGUIDES 77


Eduardo ManeiraManeira AdvogadosRio de Janeiro

Ricardo Mariz de OliveiraMariz de Oliveira e Siqueira CamposAdvogadosSão Paulo

Giancarlo Chamma MatarazzoPinheiro Neto AdvogadosSão Paulo

Gil F MendesMattos FilhoSão Paulo

André Mendes MoreiraSacha Calmon Misabel DerziConsultores e AdvogadosBelo Horizonte

Francisco Lisboa MoreiraBocater Camargo Costa e SilvaRodrigues AdvogadosSão Paulo

Ian MunizVeirano AdvogadosSão Paulo

Simone Dias MusaTrench Rossi e WatanabeSão Paulo

Raquel NovaisMachado Meyer Sendacz e OpiceSão Paulo

Gustavo PaesLefosse AdvogadosSão Paulo

Luiz Roberto Peroba BarbosaPinheiro Neto AdvogadosSão Paulo

Roberto Quiroga MosqueraMattos FilhoSão Paulo

Luiz Fernando RezendeDeloitte BrazilRio de Janeiro

João Dácio RolimRolim Viotti & Leite Campos AdvogadosSão Paulo

Luciana Rosanova GalhardoPinheiro Neto AdvogadosSão Paulo

Cristiano Frederico RuschmannBrazuna Ruschmann e SorianoAdvogadosSão Paulo

Isabela Schenberg FrascinoLevy & Salomão AdvogadosSão Paulo

Ana Paula Schincariol Lui BarretoMattos FilhoSão Paulo

Luís Eduardo SchoueriLacaz Martins Pereira Neto Gurevich &SchoueriSão Paulo

Alexandre Siciliano BorgesLobo de Rizzo AdvogadosSão Paulo

Lucilene Silva PradoDerraik & MenezesSão Paulo

Wagner Silva RodriguesLRNG AdvogaodsSão Paulo

Renato SilveiraMachado AssociadosSão Paulo

Heleno Taveira TôrresHeleno Tôrres AdvogadosSão Paulo

Fernando TonanniMachado Meyer Sendacz e OpiceSão Paulo

Carlos Henrique Tranjan BecharaPinheiro Neto AdvogadosRio de Janeiro

Antenori Trevisan NetoMundie AdvogadosSão Paulo

Erika Yumi TukiamaChiarottino e NicolettiSão Paulo

Ana Carolina UtimatiLefosse AdvogadosSão Paulo

Marcos André Vinhas CatãoCTA AdvogadosSão Paulo

C H I L EDaniella ZagariMachado Meyer Sendacz e OpiceSão Paulo

Fernando Barros TBarros & ErrázurizSantiago

Christian Blanche ReyesTax AdvisorsSantiago

Jorge CarrahaClaro & CiaSantiago

Carolina CollantesBaraona Fischer SpiessSantiago

María Teresa Cremaschi MBarros & ErrázurizSantiago

Alicia Dominguez VarasEYSantiago

Ricardo EscobarBofill Escobar AbogadosSantiago

Felipe EspinaEYSantiago

Oscar FerrariGarriguesSantiago

Alex FischerBaraona Fischer SpiessSantiago

Mario NascimentoDeloitte BrazilRua São Bento, 1815th and 16th floorsRio de Janeiro, RJ, 20090-010, BrazilTel: (55) 21 3981 0660Email: [email protected]: www.deloitte.com.brSee page 71 for regional profile

Marcelo NataleDeloitte BrazilAv. Dr. Chucri Zaidan, 1.240From 4th to 12th floors - Golden TowerSão Paulo, SP, 04709-111, Brazil Tel: (55) 11 5186 1003Email: [email protected]: www.deloitte.com.brSee page 71 for regional profile

78 EXPERTGUIDES TAX


Carolina Fuensalida MerinoFuensalida & DelValleSantiago

Diego GarciaCMS Carey & AllendeSantiago

Arturo GarnhamGarnham AbogadosSantiago

Mario GorzigliaPrietoSantiago

Pablo GreiberEYSantiago

Patrick HumphreysGarnham AbogadosSantiago

Guillermo InfantePhilippi Prietocarrizosa Ferrero DU &UríaSantiago

Mauricio LópezKPMGSantiago

Francisco LyonKPMGSantiago

Alberto P MaturanaBaker McKenzieSantiago

Macarena NavarreeteEYSantiago

Loreto PelegríPwCSantiago

Jesica PowerCareySantiago

Leonidas PrietoPrieto y CíaSantiago

Soledad RecabarrenRecabarren & AsociadosSantiago

Francisco SelaméPwCSantiago

Mario SilvaPhilippi Prietocarrizosa Ferrero DU &UríaSantiago

Rodrigo SteinKPMGSantiago

Carola Trucco HBarros & ErrázurizSantiago

C O L O M B I AMartín AceroPhilippi Prietocarrizosa Ferrero DU &UríaBogotá

Camilo CortésDentons Cardenas & CardenasBogotá

Mario Criales ArdilaMario Criales AbogadosBogotá

Lucy Cruz de QuiñonesQuiñones CruzBogotá

Juan Pablo Godoy FajardoGodoy & Hoyos AbogadosBogotá

Andrés González BecerraDLA Piper Martinez BeltranBogotá

Myriam GutiérrezKPMGBogotá

Andrés Hernández De LeónBrigard UrrutiaBogotá

Catalina Hoyos JiménezGodoy & Hoyos AbogadosBogotá

Carlos Mario LafauriePwCBogotá

Alfredo LewinLewin & WillsBogotá

Ciro Meza MartinezBaker McKenzieBogotá

Lucas Moreno SalazarBrigard UrrutiaBogotá

Álvaro Para GómezParra Rodríguez AbogadosBogotá

Mauricio Piñeros PerdomoGómez-Pinzón Zuleta AbogadosBogotá

Natalia Quiñones CruzQuiñones CruzBogotá

Antonio Quiñones MontealegreQuiñones CruzBogotá

Adrián RodríguezLewin & WillsBogotá

Hugo HurtadoDeloitte ChileRosario Norte 407 Las Condes SantiagoSantiagoChile Tel: (56) 2272 98126Email: [email protected]: www.deloitte.comSee page 71 for regional profile Mario Andrade

Deloitte ColombiaCra 7 74 - 09Bogota, A.A. 07854Colombia Tel: (57) 1 426 2188Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Diego Cubillos PedrazaDeloitte ColombiaCra 7 74 – 09Bogota , A.A. 07854Colombia Tel: (57) 1 426 2285Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Diego FrancoDeloitte ColombiaCra 7 74 - 09Bogota, A.A. 07854Colombia Tel: (57) 1 426 2282Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Julian Moreno PérezDeloitte ColombiaCra 7 74 - 09Bogota, A.A. 07854Colombia Tel: (57) 1 426 2218Email: [email protected]: www.deloitte.comSee page 71 for regional profile

TAX EXPERTGUIDES 79


Carolina RozoPhilippi Prietocarrizosa Ferrero DU &UríaBogotá

Juan Guillermo RuizPosse Herrera & RuizBogotá

Jaime VargasEYBogotá

C O S TA R I C A

Carolina FloresArias & MuñozSan José

Diego SaltoConsortium LegalSan José

C U R A Ç A OEmile SteevenszSteevensz|BeckersWilemstad

D O M I N I C A NR E P U B L I C

E C U A D O RPablo AguirrePwCQuito

Juan Gabriel Reyes-VareaPérez Bustamante & PonceQuito

E L S A L VA D O R

H O N D U R A S

M E X I C OMauricio Ambrosi HerreraTuranzas Bravo & AmbrosiMexico City

Pedro Arias GarridoArias y MeurinneMexico City

Victor BarajasBashamMexico City

Alejandro BarreraBashamMexico City

Jaime G BendiksenBéndiksen DiedrichEnríquez SalazarSantoyo & YanarMexico City

Mauricio Bravo FortoulTuranzas Bravo & AmbrosiMexico City

Fernando Camarena CardonaFoley ArenaMexico City

Luis C CarbajoBaker McKenzieJuárez

Jorge CorreaCreel García-Cuéllar Aiza y EnríquezMexico City

Jorge Covarrubias BravoDespacho ParásMexico City

Mariana Eguiarte MorettSánchez DeVannyMexico City

Jaime Espinosa de los MonterosHogan LovellsMexico City/Monterrey

Roxana M Gómez-OrtaBaker McKenzieMonterrey

Rosario HuetRamírez Gutiérrez-Azpe Rodríguez-Rivero y HurtadoMexico City

Ricardo León-SantacruzSánchez DeVannyMonterrey

Carla CoghiDeloitte Costa RicaCentro Corporativo El Cafetal Edificio B,piso 2 La Ribera, BelenHeredia, San José 3667-1000 San joseCosta Rica Tel: (506) 2246 5231Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Fabio SalasDeloitte Costa RicaCentro Corporativo El Cafetal Edificio B,piso 2 La Ribera, BelenHeredia, San José 3667-1000 San joseCosta Rica Tel: (506) 2246 5058Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Carla CoghiDeloitte Dominican RepublicCentro Corporativo El Cafetal Edificio B,piso 2 La Ribera, BelenHeredia, San José 3667-1000 San joseCosta Rica Tel: (506) 2246 5231Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Richard TroncosoDeloitte Dominican RepublicCalle Rafael Augusto Sanchez No. 65Edificio Deloitte Ensanche PiantiniSto Domingo, Sto Domingo Dominican Republic Tel: (809) 262 4707Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Joseph SotoDeloitte EcuadorA. Tulcan 803GuayaquilEcuador Tel: (593) 4 3700 100Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Federico PazDeloitte El SalvadorEdificio Avante Penthouse Oficinas 10-01 y10-03 U Antiguo Cuscatlán La LibertadLa Libertad, San Salvador N/A, El Salvador Tel: (503) 2524 4133Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Carla CoghiDeloitte HondurasCentro Corporativo El Cafetal Edificio B,piso 2 La Ribera, BelenHeredia, San José 3667-1000 San joseCosta Rica Tel: (506) 2246 5958Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Eduardo BarrónDeloitte MexicoAv Paseo de la Reforma 505 P28 Col.CuauhtémocMexico, Ciudad de México 06500, Mexico Tel: (52) 155 5433 7507Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Ricardo González OrtaDeloitte MexicoAv Paseo de la Reforma 505 P28 Col.CuauhtémocMexico, Ciudad de México 06500, Mexico Tel: (52) 55 5080 7023Email: [email protected]: www.deloitte.comSee page 71 for regional profile

80 EXPERTGUIDES TAX


Oscar A López VelardeRitch Mueller Heather y NicolauMexico City

Jorge San MartínSMPS LegalMexico City

Eduardo MedinaJáuregui y Del ValleMexico City

Nora MoralesMijares Angoitia Cortes & FuentesMexico City

Nora Morales RodríguezEYMexico City

Jorge S Narváez-HasfuraBaker McKenzieMexico City

Christian R NateraNATERAMexico City

Gerardo NietoBashamMexico City

Gabriel Ortiz GómezOrtiz AbogadosMexico City

Ana Paula Pardo Lelo de LarreaSMPS LegalMexico City

Gabriela PellónGalicia AbogadosMexico City

Enrique Ramirez FigueroaEYMexico City

Héctor Reyes-FreanerBaker McKenzieMexico City

Manuel Sáinz OrantesChévez Ruiz ZamarripaMexico City

Alejandro SantoyoCreel García-Cuéllar Aiza y EnríquezMexico City

Federico SchefflerGalicia AbogadosMexico City

Manuel F SolanoEYMexico City/New York

Alejandro J Torres RiveroChévez Ruiz ZamarripaMexico City

Angel J Turanzas DíazTuranzas Bravo & AmbrosiMexico City

Adalberto Valadez HernándezNader Hayaux & GoebelMexico City

Luis Vázquez RCreel García-Cuéllar Aiza y EnríquezMexico City

Gil Zenteno GBashamMexico City

Omar Zúñiga A.Creel García-Cuéllar Aiza y EnríquezMexico City

PA R A G U AYFederico ValinottiBKM BerkemeyerAsunción

P E R UJuan José AsseretoZuzunaga Assereto & ZegarraLima

Ana Luz BandiniMazarsLima

Walther BelaúndeDamma Legal AdvisorsLima

Milagros BustillosHernández & CíaLima

Rolando CevascoCMS GrauLima

José ChiarellaDamma Legal AdvisorsLima

Iván ChuDamma Legal AdvisorsLima

Alex Córdova ARodrigo Elías & Medrano AbogadosLima

David de la TorreEYLima

Guillermo D GrellaudGrellaud y Luque AbogadosLima

Luis Hernández BerenguelHernández & CíaLima

Rocío LiuDamma Legal AdvisorsLima

César Luna-VictoriaRubio Leguía NormandLima

Orlando MarchesiPwCLima

Camilo MaruyRebaza Alcázar & De Las CasasLima

Eduardo RevillaDeloitte MexicoAv Paseo de la Reforma 505 P28 Col.CuauhtémocMexico, Ciudad de México 06500, Mexico Tel: (52) 55 5080 6081Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Luis Sanchez GalgueraDeloitte MexicoAv Paseo de la Reforma 505 P28 Col.CuauhtémocMexico, Ciudad de México 06500, Mexico Tel: (52) 55 5080 7018Email: [email protected]: www.deloitte.comSee page 71 for regional profile

Jorge Sánchez HernandezDeloitte MexicoAv Paseo de la Reforma 505 P28 Col.CuauhtémocMexico, Ciudad de México 06500, Mexico Tel: (52) 55 5080 6496Email: [email protected]: www.deloitte.comSee page 71 for regional profile

TAX EXPERTGUIDES 81


Humberto MedranoRodrigo Elías & Medrano AbogadosLima

Marilú PedrazaRubio Leguía NormandLima

Rolando Ramírez GastonEstudio EchecoparLima

Arturo TuestaPwCLima

Walker VillanuevaPhilippi Prietocarrizosa Ferrero Du &UríaLima

Fernando ZuzunagaZuzunaga Assereto & ZegarraLima

U R U G U AYJuan Manuel AlbaceteGuyer & RegulesMontevideo

Leonardo Costa FrancoBrum CostaMontevideo

Gianni GutiérrezFerrereMontevideo

Nicolás JuanGuyer & RegulesMontevideo

Domingo PereiraBergstein AbogadosMontevideo

Alicia SeijasKPMGMontevideo

V E N E Z U E L AAlberto BenshimolD'Empaire Reyna AbogadosCaracas

Manuel CandalCandal TaxandCaracas

Juan Carlos Castillo CarvajalTinoco Travieso Planchart & NúñezCaracas

Valmy Díaz IbarraTorres Plaz & AraujoCaracas

Elvira Dupouy MendozaRodríguez & MendozaCaracas

Ronald E EvansBaker McKenzieCaracas

Fernando Fernández BarrosoAdvantax AbogadosCaracas

Carlos Fernández-SmithAdvantax AbogadosCaracas

Luis Fraga PittalugaDentonsCaracas

Juan Carlos Garantón-BlancoTorres Plaz & AraujoCaracas

Rodolfo Plaz AbreuTorres Plaz & AraujoCaracas

Gabriel Ruán SantosAraqueReynaCaracas

Jesús Alberto Sol GilLE A AbogadosCaracas

Gonzalo LucasDeloitte UruguayJuncal 1385, 11th floorMontevideo 11000 Uruguay Tel: (598) 2916 0756; ext=6156Email: [email protected]: www.deloitte.comSee page 71 for regional profile

82 EXPERTGUIDES TAX


M I D D L E E A S T A N D A F R I C A

Egypt 83

Ghana 83

Israel 83

Kenya 83

Morocco 83

Nigeria 83

Oman 83

Saudi Arabia 83

South Africa 83

United Arab Emirates 84

TAX EXPERTGUIDES 83

EXPERT LISTINGS MIDDLE EAST AND AFRICA

E G Y P TSherif El KilanyEYCairo

G H A N A

I S R A E LTal AtsmonGoldfarb SeligmanTel Aviv

Eldar Ben-RubyMeitar Liquornik Geva Leshem TalTel Aviv

John FisherKPMGTel Aviv

Gil GradyGornitzky & CoTel Aviv

Shaul GrossmanMeitar Liquornik Geva Leshem TalTel Aviv

Doron LevyAmit Pollak Matalon & CoTel Aviv

Meir LinzenHerzog Fox & NeemanTel Aviv

Yaron MehulalEitan Mehulal Sadot Law firmTel Aviv

Meir MizrahiMeir Mizrahi & CoTel Aviv

Leor NoumanS Horowitz & CoTel Aviv

Dina Pasca-RazKPMGTel Aviv

Daniel PasermanGornitzky & CoTel Aviv

Eli PitermanKPMGTel Aviv

Eyal RubinBDOTel Aviv

Doron SadanPwCTel Aviv

Ziv SharonZiv Sharon & Co Law OfficeTel Aviv

Yaniv ShekelShekel & CoTel Aviv

Ayal ShenhavShenhav & CoTel Aviv

Sharon ShulmanEYTel Aviv

K E N YA

M O R O C C OAnis MahfoudAB Avocats & AssociesCasablanca

N I G E R I ARobert Ade-OdiachiSIAO PartnersLagos

O M A NAshok HariharanKPMGMuscat

S A U D I A R A B I A

S O U T H A F R I C AGerhard BadenhorstCliffe Dekker HofmeyrJohannesburg

Anne BennettWebber WentzelJohannesburg

Emil BrinckerCliffe Dekker HofmeyrJohannesburg

Peter DachsENSafricaCape Town

Michael HoniballWerksmansJohannesburg

Wally HorakBowmansCape Town

David LermerPwCJohannesburg/Cape Town

Doelie LessingWerksmansStellenbosch

Mark LiningtonCliffe Dekker HofmeyrJohannesburg

George AnkomahDeloitte Ghana4 Liberation Road Accra AccraAccra, GHGhana Tel: (233) 302 775355Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Alona MeironDeloitte Israel1 Azrieli Center, P.O.B 16593Tel-Aviv, 61164Israel Tel: (972) 3 6085540Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Lilian KubebeaDeloitte KenyaDeloitte Place Waiyaki Way MuthangariNairobi, KEKenya Tel: 0719 039 000Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Fred OmondiDeloitte KenyaDeloitte Place Waiyaki Way MuthangariNairobi, KEKenya Tel: 0719 039 000Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Nauman AhmedDeloitte and Touche & Co. - CharteredAccountantsABT Building Khobar Dammam Highway AlKhobar, Al Khobar, Al Khobar 182 Saudi Arabia Tel: (966) 3 887 3937Email: [email protected]: www.deloitte.comSee page 28 for regional profile

84 EXPERTGUIDES TAX

MIDDLE EAST AND AFRICA EXPERT LISTINGS

Ernest MazanskyWerksmansJohannesburg

Graham ViljoenWebber WentzelJohannesburg

U N I T E D A R A BE M I R AT E SAbdelhamid AttallaThe Cragus GroupDubai

Reggie MezuBaker McKenzie Habib Al MullaDubai

Robert PeakeThe Cragus GroupDubai

Mark StevensThe Cragus GroupDubai

Louise VoslooDeloitte South AfricaDeloitte 5 Magwa Crescent Waterfall City Johannesburg, ZA 2090 South Africa Tel: (27) 118065360Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Anbreen KhanDeloitte Middle EastDIFC, Al Fattan Currency House Building 1,Level 5 DIFC, Dubai, Dubai 282056 United Arab Emirates Tel: (971) 4 376 8888Email: [email protected]: www.deloitte.comSee page 28 for regional profile

Alex LawDeloitte Middle EastDIFC, Al Fattan Currency House Building 1,Level 5 DIFC, Dubai, Dubai 282056 United Arab Emirates Tel: (971) 4 506 4700Email: [email protected]: www.deloitte.comSee page 28 for regional profile

TAX EXPERTGUIDES 85


N O R T H A M E R I C A

Q&A with:

Philippe Belair of Deloitte Canada 90

Steve Kimble of Deloitte Tax LLP 92

Canada 100

United States 94, 101

86 EXPERTGUIDES TAX

NORTH AMERICA REGIONAL PROFILE

Deloitte Canada Regional Profile

8 Adelaide St W #200, Toronto, ON M5H 0A9Tel: (1) 416-601-6150Twitter: @DeloitteCanadaWebsite: www2.deloitte.com/ca/en.htmlOffices: 58 locations in CanadaNumber of professionals: Deloitte Canada’s 10,267 talented people,including 959 partners

Deloitte Canada offers public and private clients a broad range of fullyintegrated services that span tax and legal, assurance and advisory,risk management, financial advisory and consulting. Our approachcombines insight and innovation from multiple disciplines with busi-ness and industry knowledge to help your company excel globally.

Deloitte Canada’s 10,267 talented people, including 959 partners,in 58 locations throughout Canada, serve clients across numerous in-dustries.

We also go to market by industry, and tax is well integrated intoGovernment and Public Services, Energy, Resources and Industrial(ER&I), Financial Services (FS), Life Sciences & Healthcare, Con-sumer Business and Technology, Media and Telecom (TMT). Throughthis approach, we are able to communicate with our clients in a waythat demonstrates we truly understand their business and havebrought the right value-add perspectives from our firm to their busi-ness discussions.

We are currently seeing growth in our cross-border business, inDeloitte Legal and our recovery work in Indirect Tax.

More generally, as a practice, we are leveraging our national modelto respond to growth activity across the country. Our national plat-form positions us to mobilize the right talent for each opportunityand leverage our multidisciplinary model. This involves assessing abusiness problem from multiple service lines’ perspectives, so that wecan provide a solution based on a thorough understanding eachclients’ circumstances.

This includes our recently created National Tax Office with emi-nent advisors, whose technical knowledge is centralized through thiscore center of excellence. This allows us to bring our professionalsfrom across the practice to our clients when they require deep techni-cal subject matter knowledge.

Innovation is a mindset and embedded in the DNA of our busi-ness. At Deloitte Canada, we leverage the newest exponential tech-nologies and programs to help our clients innovate towards atech-enabled future.

We are currently on a digital transformation journey of our own,as we are digitizing our tax and legal practice globally. This willchange how we work and serve clients, it will allow us to automatetasks and create efficiencies, and provide our practitioners with tai-lored data so they can leverage those insights to inform how we adviseour clients.

Many factors differentiate Deloitte Canada in the marketplace,including:• Our commitment to inclusion and diversity in all aspects of our

work and culture. • Our commitment to innovation.• Our commitment to providing content in French and English.• Our commitment to understanding our clients’ needs and expe-

riences in order to serve them better through our Voice of Clientprogram.

• Deloitte University North (DU North) opened in Toronto, On-tario in October 2016 which creates a unique learning forum forour practitioners and our clients.

• Deloitte Greenhouse immerses executives in customized experi-ences to solve their toughest business challenges.

• Deloitte Canada and Deloitte Chile have been operating as oneunit since June of 2016, harnessing the combined knowledge toservice the needs of a client.

• Deloitte Canada values integrity, a commitment to one another,corporate responsibility and strength from cultural diversity.

• We have some of the best and brightest tax professionals in thecountry working at our firm.

• We can customize value-added services depending on the needsof a client.

• We invite our clients to participate in a network of various rela-tionships that we have grown through our various eminenceprograms.

• We focus on industry and staff our engagements with tax profes-sionals suited to the engagement.

• We provide a full range of globally integrated tax services.

Our key service offeringsDeloitte Canada is one of the largest tax and legal practices in theglobal network of Deloitte Touche Tohmatsu Limited, after theUnited States and the United Kingdom tax practices. Our tax andlegal service offerings include:• Business Tax• Deloitte Legal Canada• Global Employer Services• Global Investment and Innovation Incentives• Immigration• Indirect Tax• International Tax• Mergers and Acquisitions• Tax Management Consulting• Transfer Pricing• US Tax Services

C A N A D A

TAX EXPERTGUIDES 87

REGIONAL PROFILE NORTH AMERICA

Recent wins: • Reorganization of a Canadian multi-national with two legacy US

businesses including re-financing of the combined US operations,as well as designing a global tax efficient business model alignedwith the company’s digital transformation.

• Seamlessly transitioned a global private equity fund from a multi-service provider model to Deloitte as their primary serviceprovider, with a multi-year multi-service compliance engagement.

• Assisted a technology company with its global expansion in multi-ple countries by aligning tax and transfer pricing considerationswith the company’s global business objectives.

Awards: World Tax 2020 awarded Deloitte with 50 tier 1 jurisdictions. DeloitteCanada was one of ten member firms recognized in the Americas re-gion.Source: International Tax Review

Women in Tax 2020 – 237 Deloitte professionals were recognized, in-cluding 12 women from Deloitte Canada.Source: International Tax Review

Tax Controversy Leaders 2020 recognized 183 Deloitte professionals,including 8 from Deloitte Canada.Source: International Tax Review

2020 Indirect Tax Leaders Guide recognized 157 Deloitte specialists.For the sixth consecutive year, Deloitte continues to be a leader in In-direct Tax. Four Canadian partners were recognized.Source: International Tax Review

2019 Guide to the World’s Leading Transfer Pricing Advisers recognized148 Deloitte professionals. 6 Canadian partners were recognized.Source: Euromoney

Two partners in Deloitte Canada’s allied law firm de Lint LLP wererecognized by Who’s Who Legal Canada in 2018 as the “Most HighlyRegarded Individuals” in Canada.

Eminent Leaders:Cheryl ManuelChristine RamsayMark NoonanOlivier Fournier






C A N A D A

88 EXPERTGUIDES TAX

NORTH AMERICA REGIONAL PROFILE

Deloitte United StatesRegional Profile

Deloitte Tax LLP30 Rockefeller Plaza, New York, NY 10112Tel: (212) 492-4000Twitter: @DeloitteTaxWebsite: Deloitte.com/taxOffices: 130 (Deloitte US)Number of professionals: 12,452

Deloitte Tax LLP provides industry-leading tax services to many ofthe world’s most admired brands delivering measurable and lastingresults by reimaging how these clients navigate the increasingchange and complexity in the tax profession. Specifically, DeloitteTax provides tax preparation and advisory services, including coun-sel related to business tax services, international tax, transfer pric-ing, indirect tax, multistate tax, tax management consulting, globalemployer services, mergers and acquisitions, research and develop-ment and government incentives and private wealth.

Led by Chairman and Chief Executive Officer Steve Kimble, De-loitte Tax LLP is one of Deloitte LLP’s five businesses and represent-ing nearly 17 percent of the Deloitte US Firm’s US$21.9 billion inrevenue. Deloitte Tax is leading clients through the tax transforma-tion taking place in the marketplace and providing a broad range offully integrated tax services that deliver insight, innovation, anddeep business and industry knowledge.

In fiscal year 2019, the tax industry saw radical and emergingglobal tax transformation – including the digitization of reporting,an evolving policy landscape, and increasing transparency expecta-tions for multinational businesses. This growth contributed to De-loitte Tax’s continued revenue increase.

Deloitte Tax LLP is a leader in the professional services industryfor its investment in and leverage of technology and processes to en-able superior client service. In 2018, Deloitte Tax made the decisionto increase the investment and pace of its digital transformationstrategy, giving name to the initiative in early 2019: Tax in 2020. Taxin 2020 is a three-year plan anchored by an unprecedented invest-ment in building a seamless global tax experience for the firm’sclients that helps them reimagine how to navigate the increasingchange and complexity in the tax profession. Through Tax in 2020,Deloitte Tax has doubled its investment in innovation and deepenedthe firm’s commitment to evolve with its clients, while anticipatingthe next generation of solutions and capabilities to meet the ever-changing set of challenges faced by companies. More broadly acrossthe practice, Deloitte Tax is focused on three key areas: technologyinnovation, which leverages leading edge digital capabilities andcloud-based solutions to create and enhanced experience for clients;an integrated global platform, which automates many aspects of taxcompliance; and, transforming operating models to create efficiencyimprovements, cost savings and increased business value.

Deloitte Tax recognizes that one of the biggest challenges andgreatest opportunities for a multinational company today is address-ing local and foreign taxes in a way that substantively aligns with itsoverall business objectives and operations. • International Tax Services: Providing tax resources where needed,

unhindered by geographic or organizational barriers, to help com-panies address their U.S. outbound and inbound tax issues, includ-ing exploring considerations to reduce their global tax burden.

• Transfer Pricing: Assisting companies that operate in an environ-ment of unprecedented tax complexity coupled with a rising vol-ume and variety of intercompany cross-border transactions andenforcement activities worldwide. Deloitte Tax transfer pricingspecialists can help companies address their tax compliance risksby aligning practical transfer pricing approaches with their over-all global business operations and objectives.

• Indirect Tax: Deloitte Tax professionals advise companies on awide range of indirect taxes, including value-added tax(VAT)/goods and services tax (GST), sales and use tax, customsduties, excise duties, insurance premium tax, and more. Their ex-perience and knowledge covers the areas of tax compliance andreporting, dispute resolution, tax consultancy and potential op-portunity identification, and assistance with process implemen-tation.

• Global Tax Compliance Services: Assisting organizations to de-velop new approaches to global tax compliance and reportingthat enable them to elevate the role of the tax department andthe value it adds to their businesses. Deloitte Tax professionalswork with companies to evaluate operating models that leverageDeloitte’s tax technical, technology, data management, and pro-cess knowledge to help organizations access insights to supportsmart decisions while containing costs.

Our key service offeringsBusiness tax services, international tax, transfer pricing, indirect tax,multistate tax, tax management consulting, global employer services,mergers and acquisitions, research and development and governmentincentives and private wealth.

Awards: Deloitte Tax has received numerous honors and recognition over thepast few years, continuing to demonstrate the depth of Deloitte’s ex-perience and skills across the Americas region. Recent awards include:• International Tax Review, Americas Tax Technology Firm of the

Year (2018, 2019)• International Tax Review, North America Transfer Pricing Firm of

the Year (2017, 2018, 2019)• International Tax Review, Americas Transfer Pricing Firm of the

Year (2019)

U N I T E D S TAT E S

TAX EXPERTGUIDES 89

REGIONAL PROFILE NORTH AMERICA

• International Tax Review, Tax Compliance & Reporting Firm ofthe Year (2015, 2016, 2017, 2018)

• CPA Practice Advisor, 40 Under 40 and 20 Under 40 RecognitionAward (2017, 2019)

• CPA Practice Advisor, Most Powerful Women in Accounting(2019)

• ACQ5 Award (2019)• Acquisition International, Accounting, Audit & Tax Awards (2017)







90 EXPERTGUIDES TAX

NORTH AMERICA Q&A

Q&A with Philippe BelairManaging partner, Tax & LegalDeloitte Canada

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?In the past 18 months, our Tax & Legal practice nationalized ourservice lines. We gradually introduced the national model, startingwith a few service lines that lent themselves well to a national struc-ture due to their size and the nature of their work. Throughout theprocess, the benefits to this approach for both our clients and ourtalent were clear, and today, all 11 of our service lines operate onthis model.

We also enhanced our service offerings, building out our legalpractice and introducing our Operations Transformation for Taxprogram, to the market. We consolidated our go-to-market approachfor our cross-border service lines (International Tax and TransferPricing). We have also been expanding the scope of our National TaxOffice in order to enhance our capability to bring world-class tax ad-vice in the face of ever-increasing complexity of tax issues.

What was the most notable effect of that change?The most notable effect from our decision to nationalize our prac-tice is our ability to collaborate for a measurable impact, both in-ternally and in the marketplace. We now have a framework thatimproves our efficiency in bringing the right resources to the rightopportunities. This increases the synergy among teams, both ourclient teams and our internal teams, which produces impactful re-sults in our service delivery.

Where is the market moving in this practice area?The market is moving towards consolidated market offerings andour national structure positions us well to deliver against this ex-pectation. Clients want trusted business advisors not just single ser-vice delivery professionals.

A significant number of companies across all industries are un-dergoing digital transformation and this impacts all aspects of theirbusiness. The onus is on Deloitte to bring specialists to the table sowe can have holistic discussions with our clients about the implica-tions and opportunities associated with these types of transforma-tions. For Tax & Legal, this means we are frequently collaboratingwith other parts of our business, such as Consulting, to bring in-creasing value to clients during these discussions and having greaterimpact through our ability to provide tax advice and guidance asorganization undergo transformation.

We have also been seeing a significant increase in the amount ofcross-border tax advisory work related to the impacts of tax re-form, which has occurred in several jurisdictions relevant to bothCanadian in-bound and Canadian out-bound investments. Ourconsolidated market offerings and our national structure has en-abled us to respond to these changes in an efficient, proactive, andconsistent manner.

What kind of impact will this have on your work?I am noticing the impact of this through my own work, where clientsreach out to Deloitte Canada as a problem solver for their businessproblems, and not just a firm that can service their tax functions.With respect to the digital transformations, Tax & Legal is teamingmore frequently with the firm’s advisory businesses to help the clientsnavigate all the components of their business impacted by this trans-formation. Deloitte’s unified presence in the market with our tax andadvisory services differentiates us, because not all of our competitorscan bring these perspectives to the table.

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?Based on the Liberal Party election platform and subsequent MandateLetters from the Prime Minister to the Minister of Finance and theMinister of Revenue, some legislative developments were anticipatedincluding Canadian versions of Actions 2 (anti-hybrid rules) and 4(interest expense restriction rules) of the OECD led Base Erosion andProfit Shifting (BEPS) project. It remains to be seen if this will moveforward in the context of the global financial crisis caused by theCOVID-19 pandemic.

Like a number of other countries, Canada implemented very sig-nificant emergency relief monetary and fiscal measures, including taxmeasures, in response to the crisis. On a short- to medium-term basis,we will likely see a phasing out of the emergency measures along with

C A N A D A

TAX EXPERTGUIDES 91

Q&A NORTH AMERICA

some new (but more limited and focused) stimulus measures to helpthe economy restart. However, on a longer-term basis the unpresenteddeficits and resulting level of debt will need to be addressed – likelythrough a combination of reduced spending and tax increases. How-ever, this will be challenging, as it will need to be done in a way thatdoes not impair Canada’s competitiveness with other countries or im-pede growth.

If these come into force, how will the industry look in the future?These changes are expected to impact in-bound and out-bound fi-nancing within corporate groups, the location of debt within corpo-rate groups, as well as corporate capital structures. As is the case withother BEP driven initiatives, we anticipate a material rise in the needfor transfer pricing services, international tax consulting services, andcompliance services.

How would you describe the tax controversy landscape in yourregion/jurisdiction?The past few years have seen the Canada Revenue Agency become in-creasingly aggressive and ambitious in its efforts to ensure compliancewith Canada’s tax laws and generate tax revenues. The Canada Rev-enue Agency is raising large reassessments and leaving taxpayers todispute them through the lengthy administrative appeals process andlitigation in the courts. With the expected deficits and shortfalls inrevenue due to COVID-19, we anticipate that the Canada RevenueAgency will become even more sensitive to preserving Canada’s taxbase, so we expect this trend to continue. More than ever, it is impor-tant for taxpayers to plan their affairs and transactions carefully tominimize tax disputes, and to manage disputes strategically when theydo arise.

Do you expect tax procedures in your region to move towardscommon standards or diverge in the future?We expect the tax procedures in Canada to continue to move towardsa common standard in the future.

Is the global drive towards regulation going to affect taxpractice? If yes, in which areas?The global drive towards regulations will affect tax practices because itwill increase the standard for compliance and the volume of compliance.This will increase the importance of tax reporting and compliance workand the need for the right resources to serve clients. This will make oper-ating nationally and using technology all the more critical.

What do you see as direct impact of COVID-19 in your practice?COVID-19 has highlighted the importance of being agile and digital.Our practice pivoted quickly to a work-from-home model and experi-enced less of a disruption because our practitioners regularly workvirtually with teams across the country. Our team has stuck together,supported each other, and adapted to meet the needs of our evolvingsituation.

The current pandemic has created major disruptions and sparkeda sense of urgency for changes including a massive update in digitaltransformations. The accelerated pace of these changes will requirebusinesses to outsource their tax functions or to be nimble in howthey adapt. Our advisory and consulting services can help with thisand support clients’ entire businesses throughout this transition, in-cluding the evolution of their business model. We are already seeingan increase in demand for our grants an incentives team, employmentlaw team, and our restructuring business as they help clients navigatetheir digital transformation journey.






C A N A D A

92 EXPERTGUIDES TAX

NORTH AMERICA Q&A

Q&A with Steve KimbleChairman and CEODeloitte Tax LLP

What was the most significant development in yourregion/jurisdiction’s tax practice in the past 18 months?COVID-19 and the related legislative activity are the most significantdevelopments related to Deloitte’s US Tax business this year. Acrossindustries and sectors, companies are facing never-before experiencedchallenges and business issues, such as significant revenue contrac-tions, staffing and supply chain inconsistencies and distressed debtconsiderations. To lessen the impact of the downturn on individualsand businesses, the United States Congress passed the massive tax-and-spending CARES Act package to provide economic relief to ad-dress the impact of the COVID-19 pandemic. In addition to directcash payments for individual taxpayers and penalty-free, early accessto retirement savings, the legislation also includes several significantbusiness tax provisions, such as eliminating the taxable income limitfor certain net operating losses (NOL) and allowing businesses andindividuals to carry back NOLs arising in 2018, 2019, and 2020 to thefive prior tax years.

In April 2020, Deloitte Tax identified the business areas that weremost critical for our clients, which have been driving our focus for theimmediate term as we work through the COVID-19 outbreak and re-sponse. These key areas are: transition to remote working; tax plan-ning for cash needs; employee retention credit/payroll tax deferral;debt restructuring; and tax operating model considerations.

What was the most notable effect of that change?The most notable effect of COVID-19 and the CARES Act remains tobe seen. However, as business situations change Deloitte will continueto work closely with clients to carefully consider how the new lawcould impact their business plans and performance.

With additional coronavirus stimulus spending on the horizon,our professionals are helping financial executives and tax leaders un-derstand how their organizations might be impacted. Using our state-of-the-art modelling tools, Deloitte Tax professionals are providingrobust scenario analyses and customized reporting for new and exist-ing tax provisions, and are working to develop recommendations andaction plans for various scenarios.

Where is the market moving in this practice area?Deloitte is continuing to help clients navigate through the uncertaintycreated by COVID-19 and the subsequent CARES Act. We see lots ofmovement towards planning how potential scenarios could affect thefundamentals of their business, reveal vulnerabilities, and even createnew opportunities, and our professionals are helping our clients stayup-to-date and adaptable in the face of constantly changing condi-tions.

What kind of impact will this have on your work?Deloitte is always in the practice of adapting our work to meet our

clients where they’re at. COVID-19 and corresponding legislation tomitigate the worst economic impacts of the pandemic have onlyheightened our focus on providing services and technology tools tomeet our clients’ evolving and unprecedented needs – and give themthe confidence to make informed decisions during uncertain times. AtDeloitte, we will use our expertise to help our clients navigate thiscomplex legislative landscape and provide innovative solutions andmeaningful insights that deliver real, lasting value.

Do you anticipate any significant legislative changes in thefuture with a material impact on tax in your region?The United States has seen the enactment of several major pieces oflegislation aimed at helping individuals and businesses cope with thehealth and economic hardships of the coronavirus pandemic. On thetax side, these new laws tend to focus on providing much needed liq-uidity to businesses and individuals. As the year progresses, it is possi-ble we will see implementation of further efforts to use the tax code toassist coronavirus mitigation, response, and recovery, though the ex-tent to which we will see bipartisan political cooperation continue isuncertain. Historically, law-making slows dramatically as we get closerto November’s quadrennial presidential election, though it is possiblethe enormous challenges to individuals and businesses posed by thepandemic create something of an exception to that precedent.


TAX EXPERTGUIDES 93

Q&A NORTH AMERICA

How would you describe the tax controversy landscape in yourregion/jurisdiction?Tax authorities in the Americas are continuing to transition to acentralized, more automated approach in selecting the highest risktaxpayers for examination. Driven by data analytics, tax examinersare utilizing an issue-focused approach in their audits. With the ex-ception of taxpayers involved in aggressive tax planning, it is ex-pected that tax authorities will no longer target specific industriesor taxpayers for audit. Centralized decision-making and a percep-tive deployment of limited resources should enable a more strategicapproach to examinations. As a result of these changes, tax authori-ties have generally been more cooperative and transparent with tax-payers. We have experienced this collaborative interaction withsenior leadership of the tax authorities as we work through themany operational, technical and procedural issues stemming fromthe recent CARES Act legislation enacted due to the COVID-19pandemic.

Tax authorities in the Americas continue to publish new and up-dated guidance related to recent tax legislation (TCJA) which has re-sulted in added uncertainty and challenges to the tax preparationprocess, as well as new areas subject to eventual scrutiny by tax exam-iners. Our tax controversy specialists are supporting compliance per-sonnel in tax preparation and are focusing more on the examination

process with the goal of trying to resolve issues before administrativeappeals or litigation become necessary. As a result, it is essential tohave tax controversy specialists who are technically proficient, proce-durally savvy, and know how and when to elevate an issue to the ap-propriate levels within a taxing authority. Clients are seeking suchcompetencies, particularly as issues become more difficult to resolveat the examination level.

Is the global drive towards regulation going to affect taxpractice? If yes, in which areas?Over the past few years, governments around the world have beenlooking at how the global digitalization of the economy is changingbusiness models and whether that has implications for tax. Drivingmuch of the attention about taxation is the question of whethermultinationals are “paying their fair share,” in terms of recognizing in-come earned from the markets they serve. For businesses, it’s impor-tant to understand that, although the focus began with digitalbusiness models, other multinational operations involving intangiblevalue not linked to digital activities are also being looked at, especiallyif they involve high-margin activities viewed on a global basis.

What do you see as direct impact of COVID-19 in your practice?See response to Question 1.


Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”).DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in re-spect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services toclients. Please see

www.deloitte.com/about to learn more.





94 EXPERTGUIDES TAX

NORTH AMERICA ATTORNEY BIOGRAPHIES

Kenneth has led Fenwick’s award-winning tax controversy practicesince its formation, working on high-profile tax controversy matters inthe United States and internationally. As a partner and the chair of itstax controversy practice, Kenneth’s team has handled more than 75federal tax litigations. Several of these matters resulted in importantreported decisions; and Fenwick has received numerous accolades forits tax controversy practice, including recognition by International TaxReview as the top controversy practice in North America and as theU.S. tax litigation firm of the year in a number of different years.

The principal focus of Kenneth’s practice is complex federal taxlitigation and tax controversy work, particularly involvinginternational matters. He counsels clients on federal tax audits,appeals, transfer pricing, and APA matters. He practices in the U.S. TaxCourt and has published numerous articles relating to taxcontroversies. Kenneth’s practice includes clients such as Xilinx, TheLimited, L Brands, Textron, Chrysler AG, G.M. Trading, DoverCorporation, Adaptec, Analog Devices, Sanofi SA, Cameco, CBS andVF Corporation. Kenneth is included in International Tax Review’sWorld’s Controversy Leaders and Euromoney’s World’s LeadingTransfer Pricing Advisors.

In addition to his more than four decades of tax focus, Kenneth’s othercareer-long interests include providing strategic and legal advice tostartup businesses. He has extensively worked on mediations and otherforms of alternative dispute resolution, helping resolve business andlegal problems around the globe. He has worked on client matters innumerous countries, spanning Europe, Asia, Australia and NorthAmerica, as well as managing disputes in over twenty states in the U.S.He also has a notable background in teaching speaking techniquesbased on his competitive debating experience.

Kenneth B ClarkFenwick & West801 California StreetMountain View, CA 94041US Tel: (1) 650 335 7215 Email: [email protected]: www.fenwick.com


Tijana J Dvornic is a Partner in Wachtell, Lipton, Rosen & Katz’s TaxDepartment.

Ms Dvornic focuses on tax aspects of US and cross-border mergers andacquisitions, spin-offs and other dispositions, leveraged buy-outs, jointventures and financing transactions.

Ms Dvornic received a B.B.A. with highest distinction from theUniversity of Michigan. Ms Dvornic completed a J.D. magna cum laudefrom Harvard Law School, where she was the articles editor for theHarvard Civil Rights-Civil Liberties Law Review. Following law school,she was a law clerk to the Honorable Judge Priscilla R. Owen in theUnited States Court of Appeals for the Fifth Circuit. Ms Dvornicreceived an LL.M. in taxation from New York University School of Lawin 2016 and was awarded the David H Moses Memorial Prize.

Ms Dvornic is a member of the Tax Sections of the New York State BarAssociation and the American Bar Association.

Tijana J DvornicWachtell Lipton Rosen & Katz51 West 52nd StreetNew York, NY 10019US Tel: (1) 212 403 1074 Email: [email protected]: www.wlrk.com


TAX EXPERTGUIDES 95

ATTORNEY BIOGRAPHIES NORTH AMERICA

David Forst is a partner in Fenwick’s tax group and focuses oninternational corporate taxation. David is included in Euromoney’s TaxAdvisors Expert Guides (World’s Leading Tax Advisors and World’sLeading Transfer Pricing Advisors), and he was named one of the Top30 U.S. Tax Advisors. He is also in The Legal 500 Hall of Fame and isregularly recognized in Law Business Research’s International Who’sWho of Corporate and Tax Lawyers. David is listed in Chambers USAand Chambers Global as one of America’s Leading Lawyers for Tax andBusiness. He has also been named a Northern California Super Lawyerin Tax by San Francisco Magazine.

David is a lecturer at Stanford Law School and UC Berkeley LawSchool, where he focuses on international taxation. He is an editor ofand regular contributor to the Journal of Taxation, where hispublications have included articles on international joint ventures,international tax aspects of mergers and acquisitions, the dualconsolidated loss regulations, and foreign currency issues. He is aregular contributor to the Journal of Passthrough Entities, where hewrites a column on international issues. David is a frequent chair andspeaker at tax conferences, including the NYU Tax Institute, the TaxExecutives Institute, and the International Fiscal Association.

David graduated with an A.B., cum laude and Phi Beta Kappa, fromPrinceton University’s Woodrow Wilson School of Public andInternational Affairs, and received his J.D., with distinction, fromStanford Law School.

David is admitted to practice in California.

David L ForstFenwick & West801 California StMountain View, CA 94041 US Tel: (1) 650 335 7254 Email: [email protected]: www.fenwick.com


Jim Fuller is a partner in Fenwick’s tax group. Euromoney named Jimeight times as one of the world’s top 25 tax advisers, most recently in2019.

He is the only U.S. tax adviser to receive a Star Performer rating (higherthan first tier) in Chambers USA (2020), and Chambers Global rankshim tier one in corporate and international tax (2020). He also is oneof the three “most highly regarded” U.S. tax practitioners according toWho’s Who Legal (Law & Business Research Ltd). Legal 500 hasincluded Jim in its “Halls of Fame” for both Corporate Tax andInternational Tax. Jim also is one the U.S.’s top 30 transfer-pricingadvisors, according to Euromoney (2019).

Fenwick is first tier in International Tax Review’s World Tax 2020 inCorporate Tax, Tax Controversy and International Tax, the only firm inCalifornia to be named first tier in all three categories, and one of onlythree firms in the US to be so named. International Tax Review namedFenwick & West “Tax Firm of the Year for the San Francisco Area” 10times and “U.S. (or Americas) Tax Litigation Firm of the Year” fivetimes. Fenwick also has received a Transfer Pricing Firm of the Yearaward, been named “Americas M&A Tax Firm of the Year” and receiveda number of ITR’s M&A and JV Tax Deal of the Year awards.

James P FullerFenwick & West801 California StMountain View, CA 94041 US Tel: (1) 650 335 7205 Email: [email protected]: www.fenwick.com


96 EXPERTGUIDES TAX


Adam is a partner and the chair of Fenwick’s tax group, with 20 yearsof experience practicing U.S. international tax law at Fenwick.

Recognized as a leading tax practitioner, Adam focuses on the U.S.federal income taxation of international transactions. In recent years,Adam’s practice has focused significantly on the 2017 TCJA, includingFDII, GILTI, BEAT, and the new foreign credit system. Adam alsohandles traditional international tax issues such as transfer pricing,cross-border M&A, international restructurings, Subpart F, source ofincome and expense allocations.

Over 20 years at Fenwick, Adam has developed a reputation fordelivering practical, targeted advice on complex tax matters. He hassuccessfully defended U.S. and non-U.S. multinationals in federal taxcontroversies at all levels. He is a frequent speaker at TEI and PLI, anda Lecturer in Law at Stanford Law School. He has been named a leadingtax lawyer by Chambers, International Tax Review, and The Legal 500.

As chair of Fenwick’s tax group, Adam leads a team of lawyersrecognized across the United States and internationally. The group hasrepresented more than 100 Fortune 500 companies on tax matters, andhas served as counsel in innumerable IRS Appeals proceedings andfederal court tax cases.

Adam HalpernFenwick & West801 California StMountain View, CA 94041 US Email: [email protected]: www.fenwick.com


Joshua M Holmes joined the Tax Department of Wachtell, Lipton,Rosen & Katz as an associate in 1999 and was elected partner in 2007.He focuses on the tax aspects of corporate transactions, includingmergers and acquisitions, joint ventures, spin-offs and financialinstruments. Mr. Holmes has been the principal tax lawyer onnumerous domestic and cross-border transactions in a wide range ofindustries.

Mr Holmes received a B.A. from the University of Pennsylvania in1993, an M.A. in Economics from Stanford University in 1996, a J.D.from Stanford Law School in 1999 and an LL.M. in taxation from NewYork University School of Law in 2004.

Mr Holmes is recognized as a leading tax lawyer by Chambers USA,Who’s Who Legal 100, Leaders League, and Super Lawyers. He is anactive member of the Executive Committee of the Tax Section of theNew York State Bar Association, in addition to being a member of theTax Section of the American Bar Association, the USA branch of theInternational Fiscal Association, and the New York Committee ofRealty Trust Tax Lawyers.

Joshua HolmesWachtell Lipton Rosen & Katz51 West 52nd StreetNew York, NY 10019 US Tel: (1) 212 403 1306 Email: [email protected]: www.wlrk.com


TAX EXPERTGUIDES 97


Dr. Idan Netser is a partner in Fenwick’s tax group. He focuses hispractice on international emerging companies, venture capital,corporate and partnership taxation issues, including cross-borderinternational investments, joint ventures, mergers and acquisitions,transfer pricing, Subpart F, foreign tax credits, tax planning andrestructurings, international IP planning and exploitation, and taxcontroversy.

Idan was named to Daily Journal’s 2017 Top 40 Under 40 list, where hewas honored for his ability to lead international tax and large-scalematters while contributing to civic and pro bono matters. He is alsorecognized as a “Rising Star” by Northern California Super Lawyers(2014-2019). In 2019 and 2020, Chambers Global also ranked Idanamong the world’s leading lawyers representing U.S.-based clients inIsraeli-related U.S. international tax matters.

Idan graduated, with distinction, from both the Naval Academy andthe Naval Advanced Command course. Idan served as the Commanderof the Identification, Navigation and Communication squadron aswell as in different naval command positions on board a missile frigate,and led international naval operations in collaboration with NATO.

Idan is admitted to practice in California and Israel (inactive). He isfluent in Hebrew and English and proficient in French.

Dr Idan Netser Fenwick & West801 California StreetMountain View, CA 94041 US Tel: (1) 650 335 7716Email: [email protected]: www.fenwick.com


Larissa Neumann is a partner in Fenwick’s tax group and focuses herpractice on U.S. tax planning and tax controversy with an emphasis oninternational transactions. She has broad experience advising clientson mergers and acquisitions and restructurings, and she has extensivetransfer pricing experience. Larissa has a reputation as a leading taxadvisor due to her keen analytical skills coupled with a focus onproviding clients practical solutions to complex tax issues.

Chambers and Partners recognized Larissa for the second consecutiveyear for her “wide-ranging practice,” with clients noting that she has“strong international tax expertise” and “a lot of insight, and isthorough, responsive and careful.” Euromoney’s Women in BusinessLaw has named Larissa America’s Best Transfer Pricing Lawyer, and sheis consistently named as one of the World’s Leading Transfer PricingAdvisors. Law360 honored Larissa as among the most influentialwomen in tax law. In addition, The Legal 500 has recognized Larissaseveral times, most recently as a Next Generation Lawyer for both hertax dispute and international tax work. She was also named to the DailyJournal’s list of Top Women Lawyers in California and honored with theWomen of Influence award by the Silicon Valley Business Journal.

Larissa teaches international tax at the University of California,Berkeley, School of Law. She frequently speaks at conferences forprofessional tax groups, including TEI, IFA, Pacific Rim Tax Instituteand the ABA. Larissa also coauthors a monthly column on all recentdevelopments in U.S. international tax for Tax Notes International. Sheis also on the executive committee of the International FiscalAssociation (IFA) and serves as the President of Women in IFA (WIN).

Larissa received her J.D. from the University of California, Berkeley,School of Law. She received her M.A. in public health from YaleUniversity. She received her B.S. in molecular cell biology from theUniversity of California, Berkeley. Larissa is a member of the State Barof California and Pennsylvania and the ABA Section of Taxation. Sheis also admitted to practice in the U.S. Tax Court, the Federal Court ofClaims, and the U.S. Court of Appeals for the Ninth Circuit.

Larissa NeumannFenwick & West801 California StreetMountain View, CA 94041 US Tel: (1) 650 335 7253 Email: [email protected]: www.fenwick.com


98 EXPERTGUIDES TAX


Deborah L Paul is a partner in the Tax Department at Wachtell, Lipton,Rosen & Katz where she focuses on the tax aspects of corporatetransactions, including mergers and acquisitions, joint ventures,spinoffs and financial instruments. Ms Paul has been the principal taxlawyer on numerous domestic and cross-border transactions,including strategic acquisitions and private equity buyouts, in a widearray of industries, including telecommunications, oil and gas, food,defense and energy. Ms Paul is a frequent speaker at Practising LawInstitute, American Bar Association, New York State Bar Associationand New York City Bar Association conferences on tax aspects ofmergers and acquisitions and related topics. She is rated a leading taxlawyer by Chambers USA, Super Lawyers, the Legal 500 and Who’s WhoLegal. She was elected partner in 2000.

Ms Paul is an active member of the Executive Committee of the TaxSection of the New York State Bar Association. Prior to joiningWachtell Lipton in 1997, Ms Paul was an assistant professor at theBenjamin N. Cardozo School of Law (1995-1997) and an actingassistant professor at New York University School of Law (1994-1995).

Ms Paul received an A.B. from Harvard University in 1986, a J.D. fromHarvard Law School in 1989 and an LL.M. in taxation from New YorkUniversity School of Law in 1994.

ClerkshipsHonorable William T. Allen, Delaware Court of Chancery, 1989 – 1990

Recent Publications• What the New Tax Rules Mean for M&A, in Harvard Law School

Forum on Corporate Governance and Financial Regulation,January 12, 2018.

• IRS Releases Spin-Off Guidance, in Bank and CorporateGovernance Law Reporter, Volume 57 Number 1, September 2016.

• How to Kraft (or Not Kraft) Debt-Equity Regulations, in Tax Notes,July 25, 2016, p. 525.

• Further Treasury Action to Limit “Inversions”, in Bank andCorporate Governance Law Reporter Interim Report, January 14,2016.

• IRS Eliminates Partnership Structures Intended to Avoid CorporateTax on Dispositions of Appreciated Assets, in Columbia LawSchool’s Blog on Corporations and the Capital Markets, June 19,2015.

• A Perfect Storm for Corporate Inversions: Causes and Responses, inTax Management International Journal, 43 TMIJ 671, 11/14/2014.

• Understanding Tax Receivable Agreements, in Practical Law TheJournal, June 2013.

Deborah L PaulWachtell Lipton Rosen & Katz51 West 52nd StreetNew York, NY 10019 US Tel: (1) 212 403 1300 Email: [email protected]: www.wlrk.com


Jodi J Schwartz focuses on the tax aspects of corporate transactions,including mergers and acquisitions, joint ventures, spin-offs andfinancial instruments. Ms Schwartz has been the principal tax lawyeron numerous domestic and cross-border transactions in a wide rangeof industries. She was elected partner in 1990.

Ms Schwartz received her B.S. in Economics magna cum laude from theUniversity of Pennsylvania in 1981, her M.B.A. from the University ofPennsylvania (Wharton School) in 1984, her J.D. magna cum laudefrom the University of Pennsylvania Law School in 1984 and her LL.M.in taxation from the New York University Law School in 1987.

Ms Schwartz is recognized as one of the world’s leading lawyers in thefield of taxation, including being selected by Chambers Global Guide tothe World’s Leading Lawyers, Chambers USA Guide to America’s LeadingLawyers for Business, International Who’s Who of Business Lawyers andas a tax expert by Euromoney Institutional Investor Expert Guides. Inaddition, she is a member of the Executive Committee and past chairof the Tax Section of the New York State Bar Association and also is amember of the American College of Tax Counsel.

Ms Schwartz serves as an officer of both the UJA-Federation of NY andthe Jewish Federations of North America, serves as a member of theboard of Steep Rock Association and serves on the Board of Overseersof the University of Pennsylvania Law School. Ms Schwartz lives inManhattan with her husband, son and daughter.

Jodi J SchwartzWachtell Lipton Rosen & Katz51 West 52nd StreetNew York, NY 10019 US Tel: (1) 212 403 1212 Email: [email protected]: www.wlrk.com


TAX EXPERTGUIDES 99


William (Will) Skinner is a partner in Fenwick’s tax group. He focuseshis practice on international and corporate taxation, with a particularfocus on issues affecting technology and life sciences companies. Hispractice includes tax planning, tax controversy and tax matters relatedto mergers and acquisitions.

Will has broad and deep experience and knowledge of U.S.international taxation, including GILTI/subpart F, foreign tax credits,transfer pricing, tax treaties, and international restructurings andM&A. He has taught international tax as an adjunct professor at SanJose State University, the University of California, Berkeley, andStanford Law School, and he frequently writes and speaks in the area.Prior to entering private practice, Will clerked for the HonorableCarlos T. Bea, on the Ninth Circuit Court of Appeals.

Will received his J.D., with distinction, from Stanford Law School in2005. He received his B.A. in history from the University of California,Berkeley, in 2001. Will is a member of the State Bar of California.

William R SkinnerFenwick & WestSilicon Valley Center801 California StreetMountain View, CA 94041US Tel: (1) 650 988 8500 Email: [email protected]: www.fenwick.com


T Eiko Stange is a member of the Tax Department at Wachtell, Lipton,Rosen & Katz. He focuses on the tax aspects of US and cross-bordermergers and acquisitions, spin-offs and other dispositions, leveragedbuyouts, joint ventures and financing transactions. Mr Stange has beenthe principal tax lawyer on numerous major domestic and cross-border transactions in a diverse spectrum of industries, includingtelecommunications, technology, pharmaceuticals, banking andfinancial services, media and entertainment, real estate and retail. Mr.Stange joined Wachtell, Lipton, Rosen & Katz in 2000 and became apartner in 2006.

Mr Stange received a J.D. equivalent from the Universität Hamburg,Germany in 1993, an LL.M. in corporation law from New YorkUniversity School of Law in 1995 and an LL.M. in taxation from NewYork University School of Law in 1998.

Mr Stange is a member of the Tax Sections of the American BarAssociation and the New York State Bar Association. He is a native ofGermany.

T Eiko StangeWachtell Lipton Rosen & Katz51 West 52nd StreetNew York, NY 10019US Tel: (1) 212 403 1319 Email: [email protected]: www.wlrk.com


100 EXPERTGUIDES TAX

NORTH AMERICA EXPERT LISTINGS

C A N A D AFiroz AhmedOsler Hoskin & HarcourtToronto

Thomas A BauerBennett JonesToronto

Jack BernsteinAird & BerlisToronto

Monica BiringerOsler Hoskin & HarcourtToronto

Stephen W BowmanBennett JonesToronto

Mark BrenderOsler Hoskin & HarcourtMontréal

John A BrussaBurnet Duckworth & PalmerCalgary

Douglas A CannonMcCarthy TétraultToronto

Corrado CardarelliTorysToronto

Michael ColborneThorsteinssonsToronto

R Ian CrosbieDavies Ward Phillips & VinebergToronto

Michael FriedmanMcMillanToronto

Ian GambleThorsteinssonsVancouver

Paul GibneyThorsteinssonsToronto

David GlicksmanPwC LawToronto

Ash GuptaGowling WLGToronto

Frédéric HarveyKPMG LawMontréal

Jehad HaymourBennett JonesCalgary

Amanda HealeBlake Cassels & GraydonToronto

Raj JunejaMcCarthy TétraultToronto

Claire M C KennedyBennett JonesToronto

Robert KopsteinBlake Cassels & GraydonCalgary/Vancouver

Dean KrausStikeman ElliottToronto

Edwin G Kroft QCBennett JonesVancouver

John G LoritoStikeman ElliottToronto

Patrick MarleyOsler Hoskin & HarcourtToronto

Michael McLarenThorsteinssonsVancouver/Toronto

Al MeghjiOsler Hoskin & HarcourtToronto

Todd A MillerMcMillanToronto

Darcy D MochBennett JonesCalgary

Angelo NikolakakisEY LawMontréal

Joel A NitikmanDentonsVancouver

Kathleen V PennyBlake Cassels & GraydonToronto

Robert RaizenneOsler Hoskin & HarcourtMontréal

Alain RangerFaskenMontréal

Gabrielle RichardsMcCarthy TétraultToronto

Edward RoweOsler Hoskin & HarcourtCalgary

Stephen RubyDavies Ward Phillips & VinebergToronto

Daniel SandlerEY LawToronto

Alan M Schwartz QCFaskenToronto

Mitchell ShermanGoodmansToronto

Carrie SmitGoodmansToronto

Philippe BelairDeloitte CanadaLa Tour Deloitte 1190, avenue desCanadiens-de-Montréal Bureau 500,Montréal, QC H3B 0M7, CanadaTel: (1) 514 393 7045Email: [email protected]: www.deloitte.comSee page 86 for regional profile Geneviève Provost

Deloitte CanadaLa Tour Deloitte 1190, avenue desCanadiens-de-Montréal Bureau 500Montréal, QC H3B 0M7, Canada Tel: (1) 51 4393 7806Email: [email protected]: www.deloitte.comSee page 86 for regional profile

TAX EXPERTGUIDES 101

EXPERT LISTINGS NORTH AMERICA

Ken SniderCassels Brock & BlackwellToronto

Christopher SteevesFaskenToronto

Paul StepakBlake Cassels & GraydonToronto

Steve SuarezBorden Ladner GervaisToronto

Louise R SummerhillAird & BerlisToronto

John M UlmerDavies Ward Phillips & VinebergToronto

Chris Van LoanBlake Cassels & GraydonToronto

Marc VanassePwCMontréal

David G WeekesStikeman ElliottCalgary

Greg WiebeKPMG LawToronto

J Scott WilkieBlake Cassels & GraydonToronto

Sabrina WongKPMG LawToronto

Penelope (Penny) WoolfordKPMG LawToronto

Barbara WorndlAird & BerlisToronto

Jerald M WortsmanTorysToronto

U N I T E D S TAT E SWendy AbkinMorgan Lewis & BockiusSan Francisco

Suresh T AdvaniSidley AustinChicago

Val J AlbrightFoley & LardnerDallas

John M AllanJones DayAtlanta

Lauren AngelilliCravath Swaine & MooreNew York

Tim AnsonPwCWashington DC

Joan C ArnoldPepper HamiltonPhiladelphia

Layla J AsaliMiller & Chevalier CharteredWashington DC

David D AughtryChamberlain HrdlickaAtlanta

Summer AustinBaker McKenzieWashington DC

Sheldon I BanoffKatten Muchin RosenmanChicago

Neil BarrDavis Polk & WardwellNew York

James H BarrettBaker McKenzieMiami

Jason S BazarMayer BrownNew York

Mary C BennettBaker McKenzieWashington DC

Mary T BentonAlston & BirdAtlanta

Kenneth K BezozoHaynes and BooneNew York

Henry J BirnkrantAlston & BirdWashington DC

Kimberly S BlanchardWeil Gotshal & MangesNew York

Devon BodohWeil Gotshal & MangesWashington DC

William E BonanoPillsbury Winthrop Shaw PittmanSan Francisco

Christopher P BowersSkadden Arps Slate Meagher & FlomWashington DC

Kim Marie BoylanWhite & CaseWashington DC

Andrew H BraitermanHughes Hubbard & ReedNew York

James R BrownRopes & GrayNew York

Michael J CaballeroCovington & BurlingWashington DC

Robert CassanosFried Frank Harris Shriver & JacobsonNew York

William G CavanaghNorton Rose FulbrightNew York

Mike R SmithDeloitte Canada850- 2nd Street S.W. Suite 700Calgary, AB T2P 0R8Canada Tel: (1) 40 3267 0661Email: [email protected]: www.deloitte.comSee page 86 for regional profile

Jo Ann CatalanoDeloitte Tax LLP30 Rockefeller PlazaNew York, NY 10112-0015US Tel: (1) 212 436 2532Email: [email protected]: www.deloitte.comSee page 88 for regional profile



Kenneth B Clark see bioFenwick & WestMountain View

Steven E ClemensDechertNew York

R Brent CliftonWinsteadDallas

Peter J ConnorsOrrick Herrington & SutcliffeNew York

Ronald E Creamer JrSullivan & CromwellNew York/London

John J CreedSimpson Thacher & BartlettNew York

James E Croker JrAlston & BirdWashington DC

Andrew (Drew) P CrousoreBaker McKenziePalo Alto

Robert E CulbertsonCovington & BurlingWashington DC

Ronald A DabrowskiKPMGWashington DC

Nicholas J DeNovioLatham & WatkinsWashington DC

Michael A DiFronzoPwCWashington DC

Julie A DivolaPillsbury Winthrop Shaw PittmanSan Francisco

Diana S DoyleLatham & WatkinsChicago

James DuncanCleary Gottlieb Steen & HamiltonNew York

Tijana J Dvornic See bioWachtell Lipton Rosen & KatzNew York

Seth J EntinHolland & KnightMiami

Peter L FaberMcDermott Will & EmeryNew York

Michael FarberDavis Polk & WardwellNew York

Christopher FargoCravath Swaine & MooreNew York

F Scott FarmerMorgan Lewis & BockiusWashington DC

Lucy W FarrDavis Polk & WardwellNew York

Kevin J FeeleyMcDermott Will & EmeryChicago

Rocco V FemiaMiller & Chevalier CharteredWashington DC

Patrick B FennAkin Gump Strauss Hauer & FeldNew York

G Michelle FerreiraGreenberg TraurigSan Francisco

Richard M FijolekHaynes and BooneDallas

Miriam L FisherLatham & WatkinsWashington DC

Thomas W Ford JrHunton Andrews KurthHouston

David L Forst See bioFenwick & WestMountain View

Gary M FriedmanDebevoise & PlimptonNew York

James P Fuller See bioFenwick & WestMountain View

Peter A FurciDebevoise & PlimptonNew York

Phillip GallEYNew York

Marcy G GellerSimpson Thacher & BartlettNew York

George M GerachisVinson & ElkinsHouston

Imke GerdesBaker McKenzieNew York

Nathan W GiesselmanSkadden Arps Slate Meagher & FlomPalo Alto

Karen E CederothDeloitte Tax LLP111 S. Wacker DriveChicago, IL 60606-4301USTel: (1) 312 486 9814Email: [email protected]: www.deloitte.comSee page 88 for regional profile

David CordovaDeloitte Tax LLP925 Fourth Avenue, Suite 3300Seattle, WA 98104-1126US Tel: (1) 206 716 7527Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Ron DabruzzoDeloitte Tax LLP111 S. Wacker DriveChicago, IL 60606-4301USTel: (1) 312 486 3445Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Thomas J DriscollDeloitte Tax LLP111 S. Wacker DriveChicago, IL 60606-4301USTel: (1) 312 486 9564Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Miguel FonsecaDeloitte Deloitte Tax LLP333 SE 2nd Avenue, Suite 3600Miami, FL 33131US Tel: (1) 305 372 3274Email: [email protected]: www.deloitte.comSee page 88 for regional profile



Karen Gilbreath SowellEYWashington DC

Timothy H GillisKPMGWashington DC

Brian GleicherWhite & CaseWashington DC

Peter GlicklichDavies Ward Phillips & VinebergNew York

Joseph A GoldmanJones DayWashington DC

Stuart J GoldringWeil Gotshal & MangesNew York

Edward E GonzalezSkadden Arps Slate Meagher & FlomNew York

Stephen L GordonCravath Swaine & MooreNew York

Derek S GreenBaker BottsHouston

Lewis J GreenwaldAlvarez & MarsalNew York

Adam S Halpern See bioFenwick & WestMountain View

George A HaniMiller & Chevalier CharteredWashington DC

David R HardyOsler Hoskin & HarcourtNew York

David P HaritonSullivan & CromwellNew York

John L HarringtonDentonsWashington DC

Hal HicksSkadden Arps Slate Meagher & FlomWashington DC

Charles E Hodges IIJones DayAtlanta

Joshua M Holmes See bioWachtell Lipton Rosen & KatzNew York

Robert HoloPaul Weiss Rifkind Wharton & FarrisonNew York

Hillel JacobsonWillkie Farr & GallagherNew York

Michelle M JewettStroock & Stroock & LavanNew York

Sang I JiWhite & CaseNew York

Alan S KadenFried Frank Harris Shriver & JacobsonWashington DC

Barbara T KaplanGreenberg TraurigNew York

Sharon Katz-PearlmanKPMGNew York

Sam K Kaywood JrAlston & BirdAtlanta

Karl L KellarJones DayWashington DC

Edward T KennedyJones DayNew York

Kevin L KenworthyMiller & Chevalier Chartered

Washington DC

Andy KimPwCLos Angeles

Thomas Kittle-KampMayer BrownChicago

Kenneth KleinMayer BrownWashington DC

Andrius R KontrimasNorton Rose FulbrightHouston

Jeffrey S KorenblattReed SmithWashington DC

Andrea S KramerMcDermott Will & EmeryChicago

Emily M LamSkadden Arps Slate Meagher & FlomPalo Alto

Stuart E LeblangAkin Gump Strauss Hauer & FeldNew York

Marc LeveyBaker McKenzieNew York

Thomas V LinguantiMorgan Lewis & BockiusChicago

Richard (Dick) M LiptonBaker McKenzieChicago

Diana M LopoSkadden Arps Slate Meagher & FlomNew York

Daniel LuchsingerCovington & BurlingWashington DC

Steve KimbleDeloitte Tax LLP100 Kimball DriveParsippany, NY 07054-2176US Tel: (1) 212 436 4712Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Tony KunkelDeloitte Tax LLP30 Rockefeller PlazaNew York, NY 10112-0015US Tel: (1) 212 492 3828Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Dan LangeDeloitte Tax LLP555 East Wells St, Suite 1400Milwaukee, WI 53202-3824US Tel: (1) 414 347 6110Email: [email protected]: www.deloitte.comSee page 88 for regional profile



John Edward LynchVinson & ElkinsHouston

Enrica MaMcDermott Will & EmeryWashington DC

Raj MadanSkadden Arps Slate Meagher & FlomWashington DC

John B MageeMorgan Lewis & BockiusWashington DC

Gary B MandelSimpson Thacher & BartlettNew York

Steven |J MataysSkadden Arps Slate Meagher & FlomNew York

Todd F MaynesKirkland & EllisChicago

David W MayoPaul Weiss Rifkind Wharton & GarrisonNew York

Bill McKeeMorgan Lewis & BockiusWashington DC

Yvonne MetcalfeEYNew York

Daniel J MiccicheAkin Gump Strauss Hauer & FeldDallas

David S MillerProskauer RoseNew York

Michael J MillerRoberts & HollandNew York

Michael MollerusDavis Polk & WardwellNew York

Clifford E MullerEversheds SutherlandWashington DC

Jose E MurilloEYWashington DC

Jeremy NaylorProskauer RoseBoston

Andrew W NeedhamCravath Swaine & MooreNew York

William F NelsonMorgan Lewis & BockiusWashington DC

Idan Netser See bioFenwick & WestMountain View

Larissa B Neumann See bioFenwick & WestMountain View

David Z NirenbergChapman and CutlerNew York

David G NorenMcDermott Will & EmeryWashington DC

Edwin L NorrisSidley AustinLos Angeles

Amanda H NussbaumProskauer RoseNew York

Mark O'SullivanMathesonPalo Alto/San Francisco

Mark A OatesBaker McKenzieChicago

Kathleen PakenhamCooleyNew York

Jeffrey H ParavanoBakerHostetlerWashington DC

Joseph PariWeil Gotshal & MangesWashington DC/New York

Deborah L Paul See bioWachtell Lipton Rosen & KatzNew York

Jean A PawlowLatham & WatkinsWashington DC

Christopher J PetersWillkie Farr & GallagherNew York

John M Peterson JrBaker McKenziePalo Alto

Melinda R PhelanBaker McKenzieDallas

Bernie J PistilloMorrison & FoersterSan Francisco

David PolsterSkadden Arps Slate Meagher & FlomChicago

Joshua S RichardsonPwCChicago

Sally MorrisonDeloitte Tax LLP1100 Walnut, Suite 3300Kansas City, MO 64106-2129US Tel: (1) 816 802 7420Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Scott MundDeloitte Tax LLP555 West 5th St. Suite 2700Los Angeles, CA 90013-1010US Tel: (1) 213 688 3269Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Amin NosratDeloitte Tax LLP1111 Bagby St. Suite 4500Houston, TX 77002-2591US Tel: (1) 713 982 4057Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Brian PintoDeloitte Tax LLP2200 Ross Avenue, Suite 1600Dallas, TX 75201-6703US Tel: (1) 214 840 7802Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Keith ReamsDeloitte Tax LLP555 12th St NW, Suite 400Washington, DC 20004-1207US Tel: (1) 202 220 2623Email: [email protected]: www.deloitte.comSee page 88 for regional profile



James A RiedyMcDermott Will & EmeryWashington DC

David M RievmanSkadden Arps Slate Meagher & FlomNew York

Joseph A RileyDechertNew York

Andrew R RobersonMcDermott Will & EmeryChicago

Carley A RobertsPillsbury Winthrop Shaw PittmanSacramento

Donald E RocapKirkland & EllisChicago

Jeffrey L RubingerBaker McKenzieMiami

Robert A RudnickShearman & SterlingWashington DC

Alex E SadlerMorgan Lewis & BockiusWashington DC

Ozzie A SchindlerGreenberg TraurigMiami

David H SchnabelDavis Polk & WardwellNew York

Leslie J SchneiderIvins Phillips & BarkerWashington DC

Peter F G SchuurDebevoise & PlimptonNew York

Jodi J Schwartz See bioWachtell Lipton Rosen & KatzNew York

William M SharpHolland & KnightTampa

Abraham N M Shashy JrKing & SpaldingWashington DC

Jeffrey T SheffieldKirkland & EllisChicago

Stanley SherwoodSherwood AssociatesNew York

Dean S ShulmanKirkland & EllisNew York

Timothy S ShumanMcDermott Will & EmeryWashington DC

David R SicularPaul Weiss Rifkind Wharton & GarrisonNew York

Bryan C SkarlatosKostelanetz & FinkNew York

William R Skinner See bioFenwick & WestMountain View

Christine Agnew SloanBaker McKenzieWashington DC

Scott M SontagPaul Weiss Rifkind Wharton & GarrisonNew York

Gary D SpragueBaker McKenziePalo Alto

T Eiko Stange See bioWachtell Lipton Rosen & KatzNew York

Scott M StewartMayer BrownChicago

Steven M SurdellEYChicago

Dirk J J SuringaCovington & BurlingWashington DC

Linda Z SwartzCadwalader Wickersham & TaftNew York

C David SwensonPwCWashington DC

Edward TanenbaumAlston & BirdNew York

Marc D TeitelbaumDentonsNew York

Carol P TelloEversheds SutherlandWashington DC

J Leonard Teti IICravath Swaine & MooreNew York

Maria M TodorovaEversheds SutherlandAtlanta

Vincent van der LansLoyens & LoeffNew York

Ronald SaakeDeloitte Tax LLP555 Mission StreetSan Francisco, CA 94105-0920US Tel: (1) 415 783 6589Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Gretchen T SierraDeloitte Tax LLP555 12th St NW, Suite 400Washington, DC 20004-1207US Tel: (1) 202 220 2690Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Nancy A StacyDeloitte Tax LLP111 S. Wacker DriveChicago, IL 60606-4301USTel: (1) 312 486 3128Email: [email protected]: www.deloitte.comSee page 88 for regional profile

David StallingsDeloitte Tax LLP191 Peachtree St, Suite 2000Atalanta, GA 30303-1749US Tel: (1) 404 220 1402Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Michael E SteinsaltzDeloitte Tax LLP1700 Market StPhiladelphia, PA 19103-3984US Tel: (1) 215 299 4555Email: [email protected]: www.deloitte.comSee page 88 for regional profile



Mary F VoceGreenberg TraurigNew York

Philip WagmanClifford ChanceNew York

Andrew R WalkerMilbankNew York

Davis J WangSullivan & CromwellNew York

S Eric WangSullivan & CromwellNew York/London

Louis J WeberWinston StrawnChicago

Samuel R WeinerLatham & WatkinsLos Angeles

Jane Wells MayMcDermott Will & EmeryChicago

Thomas F WesselKPMGWashington DC

Philip R WestSteptoe & JohnsonWashington DC

Raymond J WiacekJones DayWashington DC

Gary WilcoxMayer BrownWashington DC

Robert WilkersonKPMGAtlanta

James WilsonBaker McKenzieWashington DC

Lowell D YoderMcDermott Will & EmeryChicago

Scott J VickmanDeloitte Tax LLP50 S 6th St. Suite 2800Minneapolis, MN 55402US Tel: (1) 612 397 4020Email: [email protected]: www.deloitte.comSee page 88 for regional profile

David M WalkerDeloitte Tax LLP2200 Ross Avenue, Suite 1600Dallas, TX 75201-6703US Tel: (1) 612 397 4020Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Dave WarcoDeloitte Tax LLP30 Rockefeller PlazaNew York, NY 10112-0015US Tel: (1) 212 436 6281Email: [email protected]: www.deloitte.comSee page 88 for regional profile

John T WomackDeloitte Tax LLP30 Rockefeller PlazaNew York, NY 10112-0015US Tel: (1) 212 492 3905Email: [email protected]: www.deloitte.comSee page 88 for regional profile

Who do clients really rate as the top practitioners?

ORDER FORM £85 per copy. Please send me the following Expert Guides. Indicate no. of copies in each box:

Aviation 2020 Banking, Finance and Transactional 2019 Best of the Best 2020 Best of the Best USA 2020 Competitionand Antitrust 2018 Construction and Real Estate 2019 Energy, Environment and Mining 2020 Commercial Arbitration 2019

Insurance and Reinsurance 2019 International Trade and Shipping 2017 Labour and Employment 2014 Life Sciences 2019 Litigation and Product Liability 2016 Patents 2019 Rising Stars 2020 Tax 2020 TMT 2015 Trade Mark 2020 Transfer Pricing 2019 White Collar Crime 2020 Women in Business Law 2019 Total £:

METHOD OF PAYMENTPlease find enclosed a cheque payable to ‘EuromoneyTrading Limited’Please invoice me/my company (Purchase Order Number: ____________________________)

Signature: _________________ Date: ____/____/____

YOUR DETAILS

Name:

Position: Company:

Address:

City/State: Post Code:

Country: Email:

Tel: Fax:

For 26 years, Legal Media Group’s Expert Guides have identified the world’s leading lawyers in 30 practice areas. If you regularly interact with the legal profession in a specific practice area anywhere

in the world, you should obtain a copy of the relevant Expert Guide for just £85

3 easy ways Tel: +44 (0) 20 7779 8418 Post to:to order: Email: [email protected]

Tatiana Hlivka, Expert Guides, 8 Bouverie Street, London EC4Y 8AX, UK

over 25 years , e xpe rience

over 25 years ex pe rience...gional tax advice to large AP inbound MNC’s. • Merged traditional...

Documents

Transcript of over 25 years ex pe rience...gional tax advice to large AP inbound MNC’s. • Merged traditional...