www.internationaltaxreview.com
Women in Tax
Leaders
The comprehensive guide to the world’s leading female tax advisers
Contents
2 Introduction and methodology 8 Bouverie Street, London EC4Y 8AX, UK 3 Overview 42 Malta Tel: +44 20 7779 8308 Fax: +44 20 7779 8500 Women in tax: Introduction to Managing editor Ralph Cunningham Diversity Malta’s [email protected] corporate 4 Australia Editor Matthew Gilleard income tax [email protected] 11 Austria regime Reporter Joe Stanley-Smith [email protected] 12 Belgium 46 Mexico Managing editor, TPWeek.com Sophie Ashley [email protected] 13 Brazil 49 Netherlands Reporter, TPWeek.com Joelle Jefferis [email protected] 14 Bulgaria 50 New Zealand Production editor João Fernandes 51 Norway [email protected] 15 Canada Method for Publisher Oliver Watkins 16 China [email protected] gross up of net Associate publisher Andrew Tappin 17 Colombia salary for [email protected] cross -border Online associate publisher Megan Poundall 17 Croatia employees [email protected] Marketing executive Sophie Vipond 18 Cyprus 55 Philippines [email protected] Domicile under Subscriptions manager Nick Burroughs Cypriot Tax Law 55 Poland [email protected] 56 Portugal Account manager James Baker 21 Czech [email protected] Republic 57 Romania Divisional director Greg Kilminster SUBSCRIPTIONS AND CUSTOMER SERVICES 21 Denmark 58 Russia Customer services: +44 20 7779 8610 UK subscription hotline: +44 20 7779 8999 21 Finland 59 Singapore US subscription hotline: +1 800 437 9997 © Euromoney Trading Limited, 2015. The copyright of all 22 France 61 South Africa editorial matter appearing in this Review is reserved by the publisher. 24 GCC (UAE) 62 Spain No matter contained herein may be reproduced, duplicated 25 Germany or copied by any means without the prior consent of the 63 Sweden holder of the copyright, requests for which should be 27 Greece addressed to the publisher. Although Euromoney Trading 67 Switzerland Limited has made every effort to ensure the accuracy of this 27 Hong Kong publication, neither it nor any contributor can accept any 68 Taiwan legal responsibility whatsoever for consequences that may 28 India arise from errors or omissions, or any opinions or advice 68 Tunisia given. This publication is not a substitute for professional 35 Indonesia advice on specific transactions. 69 Turkey Chairman Richard Ensor 36 Ireland 70 Ukraine Directors Sir Patrick Sergeant, The Viscount Rothermere, Christopher Fordham (managing director), Neil Osborn, 38 Italy 71 UK John Botts, Colin Jones, Diane Alfano, Jane Wilkinson, Martin Morgan, David Pritchard, Bashar AL-Rehany, 39 Latvia 80 US Andrew Ballingal, Tristan Hillgarth Women in tax: International Tax Review is published 10 times a year by 39 Lithuania Euromoney Trading Limited. The US 40 Luxembourg This publication is not included in the CLA license. perspective Copying without permission of the publisher is prohibited 41 Malaysia 95 Index of firms ISSN 0958 -7594
1W|O MwEwNw .IinNt TeArnXa tLiEoAnDalEtaRxS review.com www.internWatOioMnEaNlt aIxNre TvAieXw L.cEoAmDE |R S1 Introduction It is acknowledged that gender inequality is an unacceptable and outdated concept. Judging the Methodology ability of a professional – in whatever sphere they happen to operate – by reference to gender, is nei - Women in Tax Leaders is a guide to ther appropriate nor helpful. the leading female tax advisers in Despite recent advances in the area of diversity, the world. Inclusion in the Women women account for just 15% of board members of in Tax Leaders guide is based on a the top S&P 1500 companies. This figure may be minimum number of nominations the highest it has ever been, but given that women received from peers and clients, make up roughly half of the population, and of the along with evidence of outstanding workforce, it is easy to see that the picture remains success in the past year. Firms and skewed. individuals cannot pay to be recom - The amount of women in public accounting mended in this guide. firms diminishes by 60% at partner level, according to research from Tax Talent. In 2014, men account - ed for 79% of the partnership at Big 4 accounting firms, while females made up 21%. On entry to senior staff, the gender mix is roughly 50-50. Statistics like this show that while the glass ceiling may be higher than ever before, it still exists. Companies should be keen to smash through this barrier, particularly given that various studies show greater gender balance as directly proportional to better business performance, while research from Wake Forest University and University of North Carolina-Wilmington indicates that diversity in the C-suite leads to more honest financial decision-making. In today’s world where transparency and reputation are of central importance to multinational companies, boardrooms cannot afford to take any backward steps. Part of the solution may be staring them in the face. There is clearly still work to be done to completely eradicate gender bias. An important part of finding parity on gender issues is addressing the historical imbalance. This is part of the motivation for launching International Tax Review ’s Women in Tax Leaders guide. We want to highlight some of the women making strides in a field traditionally viewed as male- dominated. This guide also brings you a selection of articles contributed by some of the leading female advisers listed within its covers. These range from tax technical analysis pieces aimed at giv - ing readers a primer on some of the areas these women are excelling in, to insights on the specific impact women are making in the tax advisory practices of law and accountancy firms, as well as tax boutiques.
Matthew Gilleard, Editor, International Tax Review
W2 |O MwEwNw .IinNt TeArnXa tLiEoAnDalEtaRxS review.com www.internWatOioMnEaNlt aIxNre TvAieXw L.cEoAmDE |R S2 Overview Women in tax: Diversity
Gender diversity is an issue that all firms need to consider if they are to develop a truly modern workforce. Females must be represented at every level of an organisa - tion, as appointing women to high-profile positions makes it easier for others to follow in their footsteps. Big 4 firms around the globe are working towards partner - ship gender equity and have ambitious goals around this sub - ject. There are promising figures around newly appointed female equity partners and this is key to the tax profession attracting and retaining talent. Elspeth McAinsh We are seeing firms ranked according to parental leave and Brewer Morris partnership gender equity and firms are now viewing diversity as a strategic key to commercial success and not just an employer branding initiative.
Why promote gender diversity in tax? There are various studies into diversity and the avoidance of risk. The overall findings demonstrate that adopting gender diversity directives leads to altering the cultures and values with - in an organisation, in turn promoting greater balance. We see an increasing number of professionals moving into the C-suite and professional services leadership roles. Diversity in tax should lead to an increase in the percentage of women securing top level leadership positions. Diversity and its related goals are long term projects that should be underpinned by talent development, succession plan - ning and continuous measurement of results. Improvements are evident but we need to sustain and build on them.
3W|O MwEwNw .IinNt TeArnXa tLiEoAnDalEtaRxS review.com www.internWatOioMnEaNlt aIxNre TvAieXw L.cEoAmDE |R S3 Australia
Fiona Craig
Fiona leads Deloitte’s Australian Transfer Pricing practice – a team with more than 60 full time specialist practitioners. Fiona has more than 20 years’ experience with Deloitte in Australia and the UK, including 15 years specialising in transfer pricing. Her impressive track record in achieving successful transfer pric - ing outcomes includes experience in implementing and pricing tax efficient structures for large listed and privately owned Deloitte multinational companies. Fiona’s experience in negotiating and settling transfer pric - Grosvenor Place 225 George Street ing cases with revenue authorities in Australia and overseas has Sydney NSW 2000 resulted in an impressive list of successful outcomes for her Australia clients – involving both transfer pricing reviews and transfer Direct: +61 (02) 9322 7770 pricing audits, as well as the negotiation of more than 30 Email: [email protected] advance pricing arrangements. Website: www.deloitte.com Fiona has been recognised on multiple occasions as a leading specialist in Euromoney/Legal Media Group’s Expert Guide to the World’s Leading Transfer Pricing Advisers. Fiona is a regular presenter at taxation and industry focussed forums on transfer pricing and a frequent contributor to ATO and Treasury consultations on transfer pricing matters. Fiona has specialised in transfer pricing for companies in the resources industry and also in the technology sector and advises many of these industries’ largest players. Her work ranges from the structuring of supply chains and pricing of cross-border debt to the development of global policies for services and intangible payments. Many of the arrangements of Fiona’s clients have been successfully included in APA arrangements or defended under audit.
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Amelia O’Rourke
Amelia O’Rourke is a director in Ryan’s Australian practice based in Sydney and has held a variety of consulting, corporate and government roles. Amelia advises large corporate clients on all aspects of GST across a range of industry sectors. She is particularly recognised for her depth of expertise in financial services, having previous - ly worked for five years as an in-house GST adviser for two of Ryan Australia’s largest financial institutions. Amelia has extensive experience in interactions with revenue authorities, including Suite 402, 35 Lime Street Sydney NSW 2000 audit defence and dispute resolution, and is regularly consulted Australia by the government on GST technical matters. Amelia began her career in the Australian Taxation Office, Tel: +61 2 8243 5101 Email: [email protected] including as a member of the original team that designed and Website: www.ryan.com drafted Australia’s GST law. She performed the role of assistant commissioner responsible for liaison between the Australian Taxation Office, Treasury and the Parliament, and has also worked in the Assistant Treasurer’s Office and the Treasury’s indirect tax policy group.
5W|O MwEwNw .IinNt TeArnXa tLiEoAnDalEtaRxS review.com www.internWatOioMnEaNlt aIxNre TvAieXw L.cEoAmDE |R S5 Australia
Heather Park
Heather is a partner at Deloitte, the National Practice Leader of the Tax & Legal Quality & Risk Services group for Deloitte Australia and the Global Practice Leader of the Tax & Legal Quality, Risk and Regulation for Deloitte Asia Pacific. She has been a partner at Deloitte for almost 10 years, having joined in 2006.
Leading the Qu ality & Risk management teams within Deloitte Deloitte, Heather supports teams with all matters relating to quality, risk management and regulation, including: compliance 550 Bourke Melbourne 3000 with regulatory requirements; assessment of enterprise risks and Australia development of appropriate risk mitigation plans; delivery of exceptional client service by overseeing the development of Email: [email protected] Website: www.deloitte.com policies, procedures, tools and templates for all tax and legal professionals at Deloitte. She is responsible for making sure that tax and legal quality and risk keeps pace with changes impacting the professional services sector and our clients, performing risk assessment on new service offerings and tools; and third party contracting. She also monitors the changing regulatory and social environment as it relates to tax services. Heather has been at the forefront of the debates surrounding base erosion and profit shift - ing (BEPS) and responsible taxation in Australia. She has assisted with submissions to the Senate Economics References Committee inquiry into corporate tax avoidance initiated by the Australian Government in 2014, and appeared before the Committee at their public hear - ings. Heather was also active in consultation regarding the regulation of tax advisers, including the development and implementation of the Tax Agent Services Act 2009 and various Accounting Professional & Ethics Standards Board standards. She has a strong interest in integrity, ethics and governance issues, and is the inaugural chair of Cycling Australia’s Ethics & Integrity Panel, appointed in consultation with the Australian Sports Commission. Heather has had a diverse career spanning 30 years, while constantly maintaining a focus on Australian direct and indirect taxes. Her roles have included: taxation senior associate with Arthur Robinson & Hedderwicks (Lawyers), case manager for the Australian Banking Industry Ombudsman Office, lecturer in tax and corporate law at the University of Melbourne and the Queensland University of Technology, and taxation adviser at Ernst & Whinney and Bentley & Co. Heather is a qualified Australian legal practitioner and chartered accountant, and holds a master’s degree in law (Bond University), and bachelor’s degrees in law (QUT) and business and accountancy (QUT) on top of qualifications in learning and knowledge management.
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Tracey Rens
Tracey is a corporate and international tax partner in Sydney with more than 20 years of cross-border M&A, international structuring and advisory experience. Tracey is the Sydney leader of the Corporate & International Tax group. Tracey provides advice on all major areas of Australian tax including capital gains tax issues relating to acquisitions, divest - Deloitte ments and restructures, loss management and integrity issues, capital allowance provisions, repatriation matters, tax consolida - Grosvenor Place 225 George Street tion and IFRS. Sydney NSW 2000 Tracey was previously in the International and M&A group Australia and was the lead tax adviser on numerous IPOs, acquisitions of Direct: +61 2 9322 7599 mining and mining services companies and divestments. Email: [email protected] She has also advised clients on the implementation of the tax Website: www.deloitte.com consolidation, TOFA and the minerals resource rent tax (MRRT) provisions. Tracey advises clients mainly in the Energy & Resources sec - tor based in NSW including mining companies as well as min - ing services companies and suppliers to companies in these sec - tors. She also provides tax services to clients in the retail, property, technology and tourism and leisure sectors. Tracey is a national councillor of The Tax Institute as well as being a member of various education, technical and membership committees of the Institute. Tracey has a master’s in taxation from University of New South Wales and bachelor’s degree in economics and law from Sydney University. She has been admitted as a solicitor of Supreme Court of New South Wales, is an associ - ate of the Institute of Chartered Accountants of Australia and a chartered tax adviser of the Tax Institute of Australia.
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Karen Stein
Karen is an R&D tax partner at Deloitte of 15 years in a career spanning 25 years. Having spent close to seven years at an R&D tax consulting firm, Karen joined Deloitte in 1997. Leading the Consumer Business Industry group for tax with - in Deloitte Australia, Karen assists with the coordination and provision of industry focussed tax advice to agribusiness, con - sumer product, retail, wholesale and distribution organisations. Deloitte Karen is responsible for the New South Wales (NSW) region R&D Tax & Government Incentives practice, where she assists Grosvenor Place 225 George Street companies with securing funding for the furtherance of their Sydney NSW 2000 innovation and capital projects within Australia. Australia Karen assists many of Australia’s key consumer business cor - Direct: +61 2 9322 7387 porates with the delivery of industry focused tax advice. In par - Email: [email protected] ticular, Karen personally assists clients with securing funding to Website: www.deloitte.com support their innovation and R&D strategic plans. Her depth of consumer business industry expertise adds value in the identifi - cation and qualification of associated funding programmes, including tax incentives and grants. Her understanding of the innovation life cycles within the consumer business industry, and the many related drivers and levers, assists with recognising the areas which may be supported by external funding. Karen is a regular presenter at consumer business conferences and has assisted in a num - ber of industry awards programmes as a panel judge. Karen also leads the NSW R&D life-sciences team, where she assists start-ups and developed life-sciences and pharma companies maximise their R&D funding opportunities. Included in this is the provision of detailed training sessions and workshops, analysis and review of record- keeping and innovation processes, and an examination of R&D projects. Karen assists such companies with a focus on their clinical trials, overseas activities, foreign investments within Australia, involvement of exempt entities, and application of a range of grants. Karen assists companies with ATO and IR&D Board audits, development of R&D tax concession and incentive claims, and grant applications. She is focused on knowledge trans - fer and assisting companies with developing systems and processes which maximise their R&D claims, and attainment of grants. Karen holds a master’s degree in law (University of Sydney), diploma of legal studies (University of Technology, Sydney), and bachelor’s degrees in law (University of NSW) and economics (Macquarie University). She is also admitted as a solicitor of the Supreme Court of NSW and is a former member of the Institute of Chartered Accountants Tax Technical Committee. Karen is an external assessor on the Victorian Government’s Panel Voucher Program. Karen is studying an MSc degree in coaching psychology at Sydney University.
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Jill Storey
Jill has more than 20 years of experience providing advice to glob - al organisations and their internationally mobile employees and executives covering issues from taxation, pensions, equity incen - tives, benefits, compensation planning, risk mitigation, social security, cost reduction, global employment companies, aligning policies with business strategy and regulatory compliance.
She was previously a senior partner with a Big 4 firm in the Deloitte UK where she held a variety of leadership roles with responsibil - ity for up to 900 people across five European countries and a Grosvenor Place 225 George Street budget of €100 million. Sydney NSW 2000 In these roles she was involved in setting strategy, develop - Australia ing business plans, delivering budgets, people management and Direct: +61 451 832068 implementing various change management and transformation Email: [email protected] projects including offshoring and digitalising user experiences Website: www.deloitte.com and processes. She has been the lead global service line partner for a num - ber of organisations in the financial services and mining sectors. She is based in Australia and has experience working in the UK and Hong Kong. Jill has a master’s degree in environmental science, an MBA and is a qualified executive coach, as well as holding professional qualifications from the Institute of Chartered Accountants of England & Wales, the Australian Institute of Company Directors and the Chartered Institute of Taxation.
9W|O MwEwNw .IinNt TeArnXa tLiEoAnDalEtaRxS review.com www.internWatOioMnEaNlt aIxNre TvAieXw L.cEoAmDE |R S9 Australia Fiona Cahill Deloitte Rebecca Cohen PwC Jenny Elliott PwC Helen Fazzino PwC Rosheen Garnon KPMG Deborah Jenkins KPMG Ada Lam EY Maria Lui KPMG Carmen McElwain Minter Ellison Jane Rolfe KPMG Judy Sullivan PwC Michelle Tremain PwC Sue Williamson EY
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Barbara Polster
Barbara Polster has been a partner in KPMG Austria’s tax prac - tice for more than 10 years and leads the Austrian M&A tax prac - tice. Before joining KPMG in 2005, she worked for PwC and Arthur Andersen. Barbara has more than 25 years’ experience in serving multinational and major local companies and in advising them on all kinds of Austrian and international tax matters.
She has extensive expertise in corporate and international tax - KPMG Alpen-Treuhand ation, M&A tax structuring, tax due diligence, transfer pricing issues, litigations and arbitration procedures. She acts as lead tax Porzellangasse 51 1090 Vienna partner for larger consumers, manufacturing and telecommuni - Austria cation clients across many sectors and leads a team of tax profes - sionals in Austria specialising in M&A and transfer pricing. Tel: +43 1 313 32-815 Email: [email protected] Barbara and her team have a high reputation for providing Website: www.kpmg.at innovative and practical solutions to Austrian and international clients. They represent their clients very successfully in tax audits, advance pricing agreement (APA) appeal and arbitration procedures and negotiate with tax authorities on a senior level. As frequent lecturer at business institutions and universities she speaks about different tax matters including corporate and group taxation, transfer pricing, impacts of BEPS, financing, cash pooling, R&D incentives and others. She has published several books on international taxation, M&A and cash pooling and private equity and many articles in the area of taxation. Barbara has a master’s degree in business administration and is a certified tax adviser in Austria. She is member of the committee of Austrian tax experts and is actively involved in the professional assessment of draft tax law in her areas of specialisation. Together with other female partners in the Austrian practice, she has initiated the ‘KPMG Ladies Talk’ a breakfast for leading businesswomen held twice a year which is well recognised as an eligible meeting and inspiration point by female business leaders in Austria.
1W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R1S1 Austria Imke Gerdes Baker & McKenzie Ingrid Rattinger EY
Belgium Francoise Baltus Avocats Baltus Caroline Docclo Loyens & Loeff Stephanie Houx Allen & Overy Ine Lejeune Law Square Liesbet Nevelsteen Deloitte Astrid Pieron Mayer Brown Laurence Pinte Liedekerke Wolters Waelbroeck Isabelle Richelle Liedekerke Wolters Waelbroeck Annick van Hoorebeke Baker & McKenzie Isabel Verlinden PwC Annick Visschers Laga
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Marienne Coutinho
Marienne Coutinho is an experienced tax partner at KPMG in Brazil, bringing more than 21 years of international experience to her clients. As partner in charge of international tax, she also leads Brazil’s practices for transfer pricing and deal advisory – M&A tax. Marienne serves as a member of KPMG’s Global International Tax Steering committee, where she helps to devel - op, monitor and implement the firm’s global strategy for inter - KPMG in Brazil national tax. Based in São Paulo, Marienne works with major organisa - Rua Arquiteto Olavo Redig de Campos, 105, 10º andar tions and multinational corporations to assist with complex 04711-904, São Paulo - SP projects, delivering focused practical advice on Brazilian and Brazil international tax matters. Her areas of expertise include supply Tel: +55 (11) 3940 3182 chain management, market entry, BEPS, M&A tax structuring, Fax: +55 (11) 3940 5001 and corporate reorganisations, among others. Marienne also Email: [email protected] assists companies in evaluating the performance and structure of Website: www.kpmg.com/BR their tax functions in Brazil, reviewing processes, performing GAAP analysis, and advising on benchmarking and efficiency improvements. Beyond her client work, Marienne is committed to influencing tax policy and furthering education. She actively represents KPMG before a number of organisations, such as GETAP [Grupo de Estudos Tributários Aplicados], an organisation that congregates major Brazilian companies and senior tax directors, and GET, an association that discusses relevant tax topics with representatives of the administrative tax courts and tax admin - istration. Marienne is a lawyer, and completed post-graduate work in international business affairs at Johns Hopkins University. She is a frequent author on issues related to taxation in Brazil, and is a regular speaker and presenter at tax conferences around the world. She is responsi - ble for the coordination of the KPMG guide, Investment in Brazil , and co-author of the book, The Rise of Brazilian Multinationals . Marienne was the first woman to become a tax partner at KPMG in Brazil and she con - tinues to advocate for the advancement of other professionals, including leading the KPMG diversity initiative in Brazil as the leader of KPMG’s Network of Women, and serving as co- chair of the Brazil Chapter of Women Corporate Directors. She is a member of Mulheres do Brasil, IBEF-Mulher (Brazilian Institute of Finance Professionals) and LIDEM (Women Business Leaders) and teaches at the esteemed Brazilian university FGV (Fundação Getulio Vargas) on diversity in organisations.
1W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R1S3 Brazil Andrea Bazzo Lauletta Mattos Filho Isabel Bertoletti Machado Associados Mariana De Vito Trench Rossi e Watanabe - in association with Baker & McKenzie Daniela Duque Estrada Castro, Barros, Sobral, Gomes Maria Fernanda Furtado Fernandes Trench Rossi e Watanabe - in association with Baker & McKenzie Luciana Galhardo Pinheiro Neto Advogados Maria Eugenia Kanazawa Trench Rossi e Watanabe - in association with Baker & McKenzie Alessandra Machado Trench Rossi e Watanabe - in association with Baker & McKenzie Cristiane Magalhaes Machado Associados Simone Musa Trench Rossi e Watanabe - in association with Baker & McKenzie Raquel Novais Machado Meyer Lucilene Prado Derraik & Menezes Advogados Adriana Stamato Trench Rossi e Watanabe - in association with Baker & McKenzie Ana Cláudia Akie Utumi TozziniFreire Advogados Tatiana Galvao Villani Machado Associados Erika Yumi Tukiama Machado Associados
Bulgaria Dobrinka Shishkova AFA OOD
W14 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R1S4 Canada Carrie Aiken Blake, Cassels & Graydon Monica Biringer Osler, Hoskin & Harcourt Wendy Brousseau McCarthy Tetrault Alexandra Brown Blake, Cassels & Graydon Audrey Diamant PwC Nancy Diep Blake, Cassels & Graydon Cheryl Gibson Dentons Laurie Goldbach Deloitte Nathalie Goyette PwC Jennifer Hanna MNP Alison Jackson EY Erin Jensen KPMG Jodi Kelleher KPMG Claire Kennedy Bennett Jones Martha MacDonald Torys Deborah MacPherson KPMG Lori Mathison Dentons Janice McCart Blake, Cassels & Graydon Siobhan Monaghan KPMG
1W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R1S5 Canada Anu Nijhawan Bennett Jones Kathleen Penny Blake, Cassels & Graydon Gabrielle Richards McCarthy Tetrault Janice Roper Deloitte Wanda Rumball KPMG Michelle Sledz KPMG Carrie Smit Goodmans Manon Thivierge Osler, Hoskin & Harcourt Deborah Toaze Blake, Cassels & Graydon Katri Ulmonen MNP Kimberley Wharram Osler, Hoskin & Harcourt Sabrina Wong Blake, Cassels & Graydon Penelope (Penny) Woolford KPMG
China Xiaoying Chen PwC Julie Cheng Jun He Liqun Gao Deloitte Vivian Jiang Deloitte Daisy Kang PwC
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Colombia Lucy Cruz de Quinones Quinones Cruz Catalina Hoyos Godoy & Hoyos
Croatia Maja Maksimovic KPMG Helena Schmidt Deloitte
1W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R1S7 Cyprus Domicile under Cypriot Tax Law
Surprising as it may seem, most of the advantages of the Cypriot tax regime were, up until recently, directed at non-Cypriot tax residents. This effectively meant that, to enjoy the full benefits of the regime, one had to be a non-resident. The idea behind this was to have a twofold regime, one for Cypriot tax residents and one for investors wishing to use Cyprus as part of their tax planning operations. This distinction at first seems logical and is actually a method applied in many jurisdic - tions with attractive tax regimes. The locals pay their taxes to the government while specific tax incentives are in place to encourage Zoe Kokoni international investors to make new investments. Eurofast Taxand Over the years, the government realised that many individu - als from abroad liked the Cypriot weather and lifestyle so much that they decided to make Cyprus their permanent home. The applicable rule, in accordance with the provisions of the Cypriot Income Tax Law, is that anyone residing for more than 183 days within a given tax year becomes a Cypriot tax resident. Many found the Cypriot tax regime attractive compared with their countries of origin. While the Cypriot regime was advan - tageous for the average individual wishing to enjoy Cyprus on a daily basis, this was not the case for high net worth individuals (HNWIs). More specifically, up until recently, a Cypriot tax res - ident had to pay, on a worldwide basis, a 17% special defence contribution (SDC) on dividends, 30% SDC on interest on bank deposits and 3% SDC on rental income.
Narrowing of SDC In a bid to attract HNWIs, the government has sought to cre - ate a further differentiation in the tax regime of Cyprus by introducing the legal concept of ‘domicile’ as part of a series of amendments to the tax legislation passed in July 2015.
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The concept of domicile was inserted into the provisions of the SDC law, clearly aimed at creating a further differentiation in the tax regime. The end result is that tax residents must also be domiciled in Cyprus in order to be required to pay SDC on dividends, interest on bank deposits and rental income. The legal concept of domicile is not a new concept in Cypriot law. Domicile was already included in the provisions of the Cypriot Wills and Succession Law and is very important for determining which jurisdiction shall govern and regulate the succession of a deceased person. Indeed, the determination of domicile for succession purposes stems from a set of rules based on domicile of origin (where someone was born) and domicile of choice (where someone has decided to make their permanent home). It should be stated, however, that the determination of domicile should be seen as distinct from citizenship or residence. The determination of domicile for succession purposes is based upon specific legal rules and specialist legal advice should be obtained. The new amending provisions of the SDC law provide that a tax resident for the purpos - es of SDC law (and not income tax law) shall be a person also having its domicile of origin in Cyprus in accordance with the provisions of the Wills and Succession Law. Furthermore, the new provisions provide that there shall be an exemption from SDC obli - gations for persons having their domicile of choice in accordance with the Wills and Succession Law outside Cyprus (provided they have not been tax residents in Cyprus under the 183 days rule during the 20 years before the tax year in question) or simply a person who has not been a tax resident of Cyprus for 183 days a year in the last 20 years. It should also be noted that anyone who has been a tax resident of Cyprus for 17 of the last 20 years pre - ceding the tax year in question shall be deemed to have its domicile in Cyprus. This new amendment will have profound effects in the area of tax planning and is expect - ed to place Cyprus on the map as one of the best jurisdictions in the world for the establish - ment of residence for high net worth individuals. Obviously, specialist advice should be obtained from tax and legal experts in order to plan and achieve such tax migration exercis - es in accordance with the new provisions of the SDC law.
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Zoe Kokoni
Zoe Kokoni is a director in the International Business Services division at Eurofast Taxand. With more than 20 years of expe - rience in taxation issues, she is the head of the company’s Domestic Tax department. Zoe specialises in the estate duty, the internal tax legislation and its applicability for a great number of years. Her extensive wealth of experience concerning advanced domestic taxation matters has enabled Zoe to provide our com - Eurofast Taxand pany with strong administrative heritage incentives. She is a regular participant and speaker in various interna - Cypress Centre, 5 Chytron Str PO Box 24707 tional and local conferences concerning tax related matters. 1302 Nicosia Cyprus
Tel: +357 22 699 222 Email: [email protected] Website: www.eurofast.eu
W20 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S0 Czech Republic Ditta Hlavackova HLB Proxy Eliska Kominkova Baker & McKenzie Helena Navratilova Kocian Solc Balastik (KSB)
Denmark Vicki From Jorgensen EY Lida Hulgaard Hulgaard Advokater Mette Juul Plesner Bente Moll Pedersen Ronne & Lundgen Bodil Tolstrup Plesner
Finland Kirsti Auranen EY Henna Jovio Borenius
2W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S1 France
Sabina Comis
Admitted to the Paris Bar and qualified in the UK as a solicitor of England and Wales, Sabina Comis is a tax partner and inter - national co-leader of the Private Investment Funds group of Mayer Brown. She has 18 years of wide–ranging tax experience with a strong emphasis on complex corporate tax structurings and financial restructurings, both in France and internationally. She Mayer Brown also regularly represents clients in tax dispute resolutions. Sabina has further become a recognised expert on the cre - 20 Avenue Hoche 75008 Paris ation and structuring of private investment funds (private equi - France ty or real estate vehicles, and joint ventures, among others). Her tax experience, coupled with her funds’ legal and regulatory Tel: +33 1 53 53 36 24 Fax: +33 1 53 96 03 83 know-how, allows Sabina to advise on tailor-made, innovative Email: [email protected] structures for investments in France and throughout Europe, Website: www.mayerbrown.com such as the setting up of: (i) the first dedicated European provider of mezzanine and preferred equity financing for private equity portfolios; (ii) the first French regulated and leveraged investment vehicle for the purchase of discounted debt; and (iii) the first French type endowment fund. Sabina regularly speaks at conferences and is a tax lecturer at the University of Dauphine in Paris (Master 2 of Tax “ Fiscalité de l’Entreprise ”). Sabina joined Mayer Brown in 2007 after 10 years of practice with two of the UK’s ‘Magic Circle’ firms (having worked in their London and New York tax teams for four years and in their Paris tax teams for more than five years). She holds an LLB from the London School of Economics and an LLM from Cambridge University in the UK. In addition to her native Italian, Sabina is fluent in French and English.
W22 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S2 France
Sabine Sardou
Sabine is a partner in Bird & Bird’s international tax group, based in Paris. Sabine Sardou is a highly-reputed specialist in international tax transfer pricing with more than 20 years of experience under her belt. Sabine’s specific focus is on defence, strategic tax planning and documentation work. Her recent assignments include cor - Bird & Bird porate conversions into low-risk structures (limited-risk distrib - utors, agents/commissionaires and consignment manufac - Centre d’Affaires Edouard VII 3 square Edouard VII tures); advance pricing agreements; permanent establishment 75009 Paris issue resolution; extensive negotiation with the French tax France authorities through tax audits and tax litigation and successful Direct: +33 (0)1 42 68 60 86 tax defence memos regarding management fees, complex struc - Tel: +33 (0)1 42 68 60 00 turing (consulting services), and loss-making distributors. Fax: +33 (0)1 42 68 60 11 Email: She has experience across a number of sectors, including [email protected] automotive IT, communications, pharmaceuticals, financial Website: www.twobirds.com services and luxury goods. After 20 years of transfer pricing practice in the internation - al tax department of Big 4 law firms, including PwC, EY and for the last eight years, as a transfer pricing partner of Taj, the French member law firm of Deloitte, Sabine recently joined the very well-known international law firm, Bird & Bird. Sabine teaches transfer pricing and international tax law at several French universities and business schools, and is a frequent participant in professional discussions and training semi - nars. She regularly writes transfer pricing-related articles for tax and business newspapers and magazines. A member of the French Bar, Sabine also holds post-graduate degrees in tax and business law.
2W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S3 France Elisabeth Ashworth CMS Bureau Francis Lefebvre Stephanie Auferil Baker & McKenzie Sonia Bonnabry Lexcom Delphine Bouchet Arsene – Taxand Ariane Calloud Baker & McKenzie Anne-Sophie Coustel Cleary Gottlieb Steen & Hamilton Aurelia de Viry King & Spalding Marie-Odile Duparc CMS Bureau Francis Lefebvre Anne Grousset CMS Bureau Francis Lefebvre Sandra Hazan Dentons Audrey-Laure Illouz FIDAL International/KPMG Sophie Jouniaux Baker & McKenzie Annette Ludemann-Ober Valoris Avocats Marie-Helene Raffin Willkie Farr & Gallagher Elisabeth Riviere PwC/Landwell Caroline Silberztein Baker & McKenzie
GCC (UAE) Fiona McClafferty Deloitte
W24 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S4 Germany
Eveline Beer
Eveline Beer is a partner at KÜFFNER MAUNZ LANGER ZUGMAIER ( KMLZ). She is a lawyer and a certified tax consultant. Eveline Beer started her career in 2004 at one of the Big 4 accounting firms. From the outset, her focus was on VAT. In 2008 Eveline joined KMLZ, a leading German law firm, special - ising in national and international VAT law and customs. KÜFFNER MAUNZ LANGER Eveline was made a KMLZ managing associate in 2010 and ZUGMAIER partner in April 2013. Speditionstraße 21 Eveline advises multinational companies on both domestic 40221 Düsseldorf and international VAT issues. The majority of her clients oper - Germany ate in the retail and automotive sectors. Other clients represent - Tel: +49 (0)211/540953-35 ed by Eveline include equipment manufacturers, while large and Fax: +49 (0)211/540953-99 medium-sized businesses, German corporate groups and for - Email: [email protected] eign companies of all sizes, including DAX 30 quoted compa - Website: www.kmlz.de nies, rely on her VAT expertise in special cases as well as on a routine basis. Eveline’s work on international projects includes undertak - ing VAT reviews, assisting clients with their VAT reporting obli - gations and advising clients on how to reorganise their supply chains. In this respect, she works closely with KMLZ’s network of experienced and leading tax experts in all member states of the European Union, as well as a large number of addi - tional countries. Eveline regularly holds in-house VAT seminars for clients and assists them on-site with their day-to-day business, as well as in the course of VAT audits. Eveline is a deputy member of the European Commission’s expert group for VAT-related issues (VAT Expert Group) and regularly publishes articles in professional magazines. In May 2015 KMLZ opened a second office, in Dusseldorf, with Eveline heading up the team.
2W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S5 Germany
Karen Möhlenkamp
Dr Karen Möhlenkamp is managing partner of WTS and one of the leading experts in indirect and consumption tax in Germany. From 2013 onwards the German newspaper Handelsblatt and Best Lawyers USA have honoured her for being one of the best German tax lawyers. Karen graduated in law at Julius-Maximilians-University
Würzburg and worked at the Department of International Law WTS headed by Prof. Dr. Ranieri to pass her PhD. After being spon - sored as a scholar at the Max Planck Institute (Frankfurt am Peter-Müller-Straße 18 40468 Düsseldorf Main) for European legal history, she took up employment with Germany an international auditing and tax consultancy firm and with the Federation of German Industry (BDI). At BDI, she addressed Tel: +49 (0) 211 200 50 – 817 Email: the key interests of the German industry regarding the German [email protected] environmental tax reform, restructuring of the VAT Law Code Website: www.wts.de and local business tax reform to the German House of Parliament ( Deutsche Bundestag ) and the Federal Tax Department and took part in legal proceedings to the Federal Constitutional Court. At WTS, Karen’s area of focus remains on VAT, energy tax and energy law. She is involved in delivering expert opinions on complex issues and develop - ing optimisation models and reaches a wide audience through numerous publications. As a founding member of the ‘Berlin Tax Discussions’ ( Berliner Steuergespräche ) and German Energy Tax Conference, and as a member of the German Institute of Certified Tax Consultants ( Fachinstitut der Steuerberater ), she also deals with tax topics outside WTS. As the mother of two children she is doing charity work as managing director of the Benedikt Niemeyer Foundation ‘Children Make Music’ programme and is a member of the International Lions Organisation, acting in 2012/2013 as president of the Lions Club Düsseldorf-Leaina.
W26 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S6 Germany Stephanie Alzuhn KPMG Kristina Bexa Clifford Chance Barbara Fleckenstein-Weiland Flick Gocke Schaumberg Claudia Hillek KPMG Nicole Looks Baker & McKenzie Bettina Mertgen Deloitte
Greece Effie Adamidou KPMG Kyriaki Dafni Deloitte Angela Iliadis KPMG
Hong Kong Agnes Chen EY Elaine Chen Clifford Chance Sarah Chin Deloitte Tracy Ho EY Ayesha Lau KPMG Yvonne Law Deloitte
2W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S7 India
Pallavi Joshi Bakhru
Pallavi heads the Tax and Regulatory services group, which spe - cialises in cross-border transactions, regulatory compliance, transaction tax advisory services, transfer pricing, indirect taxes and compliance and outsourcing. Pallavi qualified as a chartered accountant in 1990 and has more than 25 years of post-qualification experience in the field of taxation. Grant Thornton Pallavi’s area of expertise includes inbound and outbound structuring advisory, including regulatory compliance for both 6th Floor, Plot No.19A, Sector 16A, Noida 201301 Indian and overseas investors. She has worked with clients in India getting approvals from the Reserve Bank of India and the Foreign Investment Promotion Board. Tel: +91 120 7109094 Mob: +91 98101 33230 Pallavi has also advised many clients (including listed compa - Email: [email protected] nies) on restructuring their operations. Depending on the driv - ers for restructuring, the advice has varied from merger, demerger, slump sale or a combination of these to rationalisa - tion and optimisation of overseas structures. She has done significant work with corporates on their domestic internal restructuring to consolidate value and min - imise related party transactions. Pallavi is also the People & Culture leader for the India firm; a role she plays in addition to her role as head of tax. She also leads the India – US corridor between the two member firms; an initiative aimed at ensuring that clients of the network get distinctive client service irrespective of their scale and size in locations other than their home jurisdiction and ensur - ing that relationships are grown, added and shepherded within the network. Pallavi has a portfolio of clients which cuts across various industries including information technology/information technology enabled services, manufacturing, aviation financial serv - ices and education, among others. Pallavi is a Fellow Member of the Institute of Chartered Accountants of India. Pallavi is a member of the International Fiscal Association – India Branch. She is also a member of The Indus Entrepeneurs (TiE) Delhi chapter. She is the co-chair of the PHD Chambers committee on International Affairs for North America. Pallavi is a regular speaker on tax issues and has addressed a number of seminars both with - in India and overseas. She actively contributes to newspapers and professional journals in India. She is also a trainer and actively participates in the Grant Thornton International Advanced Manager’s Programme. Pallavi is an independent director on the board of Sona BLW Precision Forgings and Filatex. Filatex is listed on the Bombay Stock Exchange and the National Stock Exchange.
W28 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S8 India
Daksha Baxi
Daksha Baxi joined Khaitan & Co in 2007 to build the firm’s direct and international tax practice. By the time she joined Khaitan she had already gained significant experience working with global organisations and leading Indian international tax advisers. Daksha’s vast experience of working with advisers in several jurisdictions (for 10 years outside of India and more than 20 Khaitan & Co years in India) brings an added level of comfort to clients and professionals. She has significant and valuable expertise on One Indiabulls Centre, 13th Floor, Tower 1 advising in international tax matters involving a variety of cross- 841 Senapati Bapat Marg border structures for investments in India by foreign corporates Mumbai 400 013 and private equity investors as well as acquisitions by Indian India companies outside India. Clients have benefited from her Tel: +91 22 6636 5000 insight pertaining to India entry strategies involving domestic Fax: +91 22 6636 5050 Email: taxation and interpretation of double taxation conventions. [email protected] International not-for-profit organisations, educational institu - Website: www.khaitanco.com tions and other philanthropic organisations also benefit from her expertise. She is well recognised for structuring and setting up of onshore and offshore funds for investments in India. Clients and professionals approach her for her tax expertise encompassing all aspects of direct tax advisory, global restruc - turing and cross-border M&A transactions, complex tax issues in equipment procurement and construction contracts, structured finance and employee equity based compensations ranging from startups to listed companies. She also assists clients in obtaining advance tax rulings to achieve tax certainty. Daksha has been recognised by Chambers & Partners as an Indian tax expert for 2013 and 2014; by Asia Pacific Leading Lawyers as one of the “most highly acclaimed tax profession - als in India”; by Citiwealth Leaders List as a leading tax lawyer for 2013; and by Who’s Who Legal 500 for private client work (the only adviser in India recognised for this). On top of her day-to-day advisory work, Daksha has co-authored numerous articles and papers on cross-border tax issues and her opinion is regularly sought by media publications in India and beyond. She is also a regular speaker at various conferences on taxation organ - ised by the International Bar Association, International Fiscal Association, Society of Trust and Estate Practitioners (STEP), American Bar Association, Foundation for International Taxation and others. Daksha is a qualified chartered accountant and is an honours graduate in economics from the Manchester Metropolitan University, UK) Daksha is a fellow member of the Institute of Chartered Accountants in England and Wales and of the Institute of Chartered Accountants of India, as well as being a member of the Society of Trust and Estate Practitioners, the International Fiscal Association and the Core Group of Bombay Chartered Accountants’ Society.
2W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R2S9 India
Pallavi Dinodia
Pallavi Dinodia is a partner at SR Dinodia & Co Chartered Accountants. The firm is one of the oldest firms in India and is ranked among the top 15 firms across the country. Pallavi has had an outstanding career spanning the past 15 years. During the past decade she has specialised in transfer pric - ing and international taxation, gaining a reputation across India for her expertise in the field. She advises corporates, both SR Dinodia & Co, Chartered domestic and foreign, helping them to fulfil their complex com - Accountants pliance requirements in India. In addition, she acts as a counsel, K-39 Connaught Circus representing clients before quasi-judicial authorities and the New Delhi – 110 001 Income Tax Appellate Tribunal (ITAT) in India on matters India related to transfer pricing, dispute resolution, advance pricing Tel: +91 – 011- 4370 3300 arrangements and the avoidance of double taxation. Email: She has worked extensively with global businesses across [email protected] Asia, the United States and Europe on advisory and transaction - Website: www.srdinodia.com al work, including a stint at a financial services company in Zurich as an in-house counsel. She has combined her under - standing of finance and accounting with her expertise across corporate and tax law to play a strategic role in high value trans - actions for her firm. Succession being mired with complexities, she advises large Indian business families, taking into account the aspirations of the new gen - eration joining the business, and helps with putting structures in place which not only pro - vide for smooth succession but are also tax efficient. Pallavi has represented the Asian region as a board member on the international committee of one of the leading global alliances of independent auditing, tax, accounting and consulting firms. She is also an independent director on the board of a very large listed company. Pallavi authored a best-seller ‘Transfer Pricing Demystified’ published by Bharat Law House in 2013, which was the first book on the practical issues related to transfer pricing in India. Pallavi is regularly invited to speak at tax conferences and at various chambers of com - merce such as the Federation of Indian Chambers of Commerce and Industry (FICCI) and the Confederation of Indian Industry (CII). She has been part of the various tax committees at the Institute of Chartered Accountants of India (ICAI) and has also spoken at numerous ICAI events on complex tax issues. She is also a regular contributor to industry publications. Pallavi graduated with distinction in commerce (Hons) from Lady Shriram College, University of Delhi. She is a fellow member of the Institute of Chartered Accountants of India (ICAI). She also holds a law degree from the University of Delhi. She is a qualified Information System Auditor (DISA) as well as an ICAI certified international tax expert.
W30 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S0 India
Shefali Goradia
Shefali Goradia is a partner with the firm’s corporate tax practice. She has more than 24 years of experience in international tax. Shefali specialises in cross-border taxation. She advises multi - national corporations in designing global holding and operating structures, inbound and outbound investments, cross-border mergers, acquisitions and other corporate reorganisations. She works extensively with leading investment and private equity BMR & Associates LLP fund houses on developing and implementing domestic and international fund structures. She has advised banks in design - BMR House 36 B, Dr R K Shirodkar Marg ing structured finance products. She advises several companies Parel, Mumbai 400 012 in hospitality and pharmaceutical industries on taxation in India. India She also advises IT companies on the taxability of software and Tel: +91 22 6135 7170 e-commerce transactions. She has obtained private rulings for Fax: +91 22 6135 7070 several clients. Shefali is a regular writer and lecturer on international tax topics. She had contributed the India chapter – ‘Is there a Permanent Establishment?’ – for the 63rd IFA Congress held in Vancouver in 2009. She was also appointed as the co-gener - al reporter for the IFA Congress held in Mumbai, India in 2014 on the topic: ‘Cross-border outsourcing – issues, strategies and solutions’. Shefali was voted as one of the region’s preeminent advisers for taxation in the 2011 Asialaw Leading Lawyers survey. She featured in the Guide to the World’s Leading Banking, Finance and Transactional Lawyers 2012 as one of the outstanding practitioners in the field of investment funds and is also listed in The International Who’s Who of Corporate Tax Lawyers and The International Who’s Who of Private Funds Lawyers consecutively from 2009- 2014. She was recognised as among the eight best Indian tax advisers by The Legal 500 and the Tax Directors Handbook 2009 . Shefali represented India in Legal Media Group’s Guide to the World’s Leading Tax Advisers and was recognised as among the top 10 tax advisers in India in World Tax (2004-2006).
3W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S1 India
Malini Mallikarjun
Malini is a senior member with the firm’s indirect tax practice in Mumbai and specialises in indirect taxes such as service tax, VAT, excise and customs duties. She has also dealt extensively with related regulations such as the Foreign Trade Policy and the special economic zone (SEZ) regulations. Malini has been with the firm since January 2005. Before joining the firm, she worked in the tax and regulatory practices at Big 4 firms. She BMR & Associates LLP also worked in-house for three years with an international power company and a leading India-based services company. BMR House 36 B, Dr R K Shirodkar Marg With more than 20 years of experience as an indirect tax spe - Parel, Mumbai 400 012 cialist, she has worked with companies across industries such as India manufacturing, power, IT/ITeS financial services, infrastruc - Tel: +91 22 6135 7025 ture and retail. More specifically, she has been involved in advis - ing clients during various stages of their operations, including set-up, capacity expansion, construction, ongoing operations and internal restructuring, among others. Her role has spanned the provision of advisory services, providing pre- and post-litigation strategic advice including representing companies before tax and regulatory authorities, assisting in counterparty negotiations on tax matters and representing to the cen - tral and state governments on tax policy matters. She has worked with both domestic and international players on matters pertaining to all key indirect taxes in India. Malini is a graduate in law from the National Law School of India University, Bangalore, and is also a member of the International Bar Association. Malini is also part of the GST Working Committee of advisers constituted by the Government of Maharashtra.
W32 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S2 India
Rajeshree Sabnavis
Rajeshree is a partner with BMR & Associates’s corporate tax practice in Mumbai. With a specialisation in tax advisory and transaction tax matters, she has more than 20 years of experi - ence in advising clients on their cross-border acquisitions and implementing the India business strategy for multinationals including implementing the integration strategy post-acquisi - tion. She has also advised multinationals including Fortune 500 BMR & Associates LLP companies in the areas of tax and transfer pricing, and has assist - ed large Indian companies in implementing their transfer pric - BMR House 36 B, Dr R K Shirodkar Marg ing across jurisdictions in the ITES sector. She works with some Parel, Mumbai 400 012 of the larger portfolio investors investing in India including India some of the large institutional investors in managing their tax Tel: +91 22 61357050 compliance and litigation in India. Rajeshree spent almost a decade with the tax practices of Big 4 firms before joining BMR & Associates in October 2004 right from its inception and has continued to be a part of the core team since then. Rajeshree is part of the Direct Taxation Committee with the Bombay Chamber of Commerce where she is a co-chairperson. In this capacity, she has represented India business houses and multinationals on various tax issues before the Central Board of Direct Taxes. Rajeshree is also a member of the EU Chamber of Commerce. She is a qualified chartered accountant and a company secretary.
3W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S3 India
Nanda Shah
Nanda joined DHC as partner providing tax and regulatory services. DHC is an exclusive member firm of Baker Tilly International. Nanda’s previous experience is with a leading law firm, Amarchand & Mangaldas & Suresh A Shroff (AMSS), Mumbai. She was heading the tax practice of AMSS. She also has experi - ence of working at PwC, having worked in the firm’s Mumbai Desai Haribhakti & Co. office for more than a decade. Chartered Accountants Over the years, Nanda has developed substantial experience 701, Leela Business Park, within the field of corporate and international tax, focusing on Andheri-Kurla Road, corporate tax and regulatory advisory services, business restruc - Andheri (E), Mumbai – 400 059 turing, including mergers and acquisitions. She also advises India clients with their tax litigation matters including strategising the Tel: +91 22 6672 9999 approach for large litigation matters. Her clients include Indian Direct: +91 22 6672 9833 Mob: +91 9820331541 companies as well as multinationals, including Fortune 500 Email: [email protected] companies. Website: www.dhc.co.in With an experience of around 25 years, she strives for high client satisfaction based on sound practical solutions, which are implementable. Nanda is a qualified chartered accountant and holds a general law degree. Nanda regularly contributes articles to tax publications and conducts conferences in the profession. She has also co-authored chapters on corporate and international tax topics.
W34 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S4 India Manisha Gupta Deloitte Karishma Phatarphekar KPMG Saloni Roy Deloitte Parizad Sirwalla KPMG Krupa Venkatesh Deloitte
Indonesia Ay Tjhing Phan PwC
3W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S5 Ireland
Cliona Donnelly
Cliona is a partner with William Fry Tax Advisors, the Irish member firm of Taxand. She is a key member of the firm’s Foreign Direct Investment group. She advises multinational and corporate clients on a wide range of issues. She focuses her prac - tice on the establishment of operations in Ireland, cross-border tax planning, mergers and acquisitions, corporate tax compli - ance and international and domestic reorganisations, and repre - William Fry Tax Advisors, sents a number of the firm’s key clients. Taxand Ireland Before joining William Fry Tax Advisors, Cliona started her 2 Grand Canal Square career in KPMG training as a chartered accountant and a char - Dublin 2 tered tax adviser. Cliona is a member of the Irish Taxation Ireland Institute and is a fellow of the Institute of Chartered Tel: +353 1 639 5280 Accountants in Ireland. She is also a member of Taxand’s Email: cliona.donnelly@ Global Knowledge Leaders group, ensuring that enhanced serv - williamfry.com ices are delivered to multinational clients. She is a frequent con - Website: www.williamfry.com tributor to tax publications. Cliona is ranked in the Chambers Global 2015 as a leading individual on corporate tax matters.
W36 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S6 Ireland
Sonya Manzor
Sonya is a partner with William Fry Tax Advisors, the Irish member firm of Taxand. She has more than 15 years’ experience of advising clients across a range of sectors on tax issues includ - ing in the areas of inward investment, intellectual property (IP) and international tax structuring, corporate reorganisations, real estate transactions, and mergers and acquisitions. She advises both domestic and multinational corporations on Irish tax mat - William Fry Tax Advisors, ters including corporate tax, VAT and stamp duty. She is a key Taxand Ireland member of the firm’s Foreign Direct Investment group. 2 Grand Canal Square Sonya is a member of the Law Society of Ireland and the Dublin 2 Irish Tax Institute. She is also a director of the Irish branch of Ireland the International Fiscal Association. Sonya is a frequent speaker Tel: +353 1 639 5212 on tax topics and a contributor to tax publications. She is the Email: co-author of the Irish chapter in the Miller Thompson publica - [email protected] tion entitled ‘Tax Litigation, Jurisdictional Comparisons’ (First Website: www.williamfry.com Edition 2013). Sonya is ranked in the Chambers Global 2015 as a leading individual on corporate tax matters.
3W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S7 Ireland Catherine Galvin Matheson Lorraine Griffin Deloitte Louise Kelly Deloitte Susan Kilty PwC Joan O’Connor Deloitte Catherine O’Meara Matheson Deirdre Power Deloitte Renata Slobodova PwC Joanne Whelan Deloitte
Italy Fulvia Astolfi Hogan Lovells Maria Antonietta Biscozzi EY Paola Camagni Studio Camagni e Associati Aurelia Casali DLA Piper Silvia Confalonieri EY Alessandra Di Salvo Deloitte Barbara Faini Baker & McKenzie Laura Gualtieri Tremonti Vitali Romagnoli Piccardi e Associati Nicoletta Mazzitelli EY
W38 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S8 Italy Maricla Pennesi Baker & McKenzie Cristina Periti Studio Fantozzi & Associati Vania Petrella Cleary Gottlieb Steen & Hamilton Giuliana Polacco Baker & McKenzie Barbara Rossi Deloitte Chiara Tomassetti Deloitte Monica Zafferani Deloitte
Latvia Marina Bickovska BDO Tax Vita Liberte Varul
Lithuania Vita Sumskaite KPMG Jurate Zarankiene Tax Link Baltic
3W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R3S9 Luxembourg
Valerie Tollet
“Like balloons, human beings have to change altitude if they wish to change direction in the winds of life.” Bertrand Piccard
As Valérie Tollet’s career has soared to new heights, this quote has guided her personal philosophy. As a partner in Deloitte
Luxembourg’s Cross-Border Tax-Mergers & Acquisitions Deloitte department, she has also helped others – clients as well as her team and colleagues – to “change altitude” over the past 14 years. 560, rue de Neudorf L-2220 Luxembourg She is experienced in structuring deals for both listed and private clients, and particularly for pan-European and interna - Tel: +352 451 45 2252 tional real estate and infrastructure funds. She assisted many Email: [email protected] Website: www.deloitte.lu investors in establishing their real estate vehicles in Luxembourg – both regulated and non-regulated – and advised on several real estate acquisitions in Europe. Before joining Deloitte in October 2012, Valérie worked with PwC both in Brussels and Luxembourg. Not only is Valérie a highly recognised tax leader in real estate, but she is also reputed for her strong skills in many tax fields, including private wealth management, private equity, financial services industry, infrastructure, and corporate tax. Valérie is an active member of several ALFI (Association of Luxembourg Fund Industry) Real Estate Investment Funds working groups. Valérie is someone who truly inspires the next generation of women and men. Within her team and the 350 professionals in the tax department, she has created a team spirit, fostering innovation and positive competitiveness. She is an active member of the Deloitte Diversity Initiative and acts as the human resources lead for the M&A department. When she joined Deloitte Luxembourg, she had an ambitious aim: for the real estate tax department to reach 15% growth each year. Fast forward three years: she succeeded in meet - ing this goal. Thanks to her interpersonal skills, in-depth understanding of clients and their industries, pragmatism, and sense of humour, she is a trusted adviser to her clients and a leader to her team. She continually builds these relationships to help Deloitte Luxembourg and her clients “change altitude” and soar to greater heights year-on-year.
W40 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S0 Malaysia Theresa Goh Deloitte Adeline Wong Wong & Partners (Baker & McKenzie member firm) Poh Geng Wong Deloitte Irene Yong Shearn Delamore
4W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S1 Malta Introduction to Malta’s corporate income tax regime
Malta continues to position itself as a viable and attractive des - tination for business and investment, in part by virtue of its competitive tax regime. The chargeable income of a Maltese company – which includes its taxable income and capital gains – is taxed at 35%. A number of entities, if structured appropriately, may be exempt from tax, including: • cooperative societies; • certain collective investment schemes; • most retirement funds or retirement schemes; and Kirsten Cassar • organisations of a public character. Camilleri Preziosi A company incorporated in Malta is treated as domiciled and resident in Malta, and is subject to tax on its worldwide income and capital gains. A company that is not incorporated in Malta is resident in Malta if its management and control are exercised in Malta. The test of management and control is usually applied by reference to the place where the shareholder and director meetings are held and where the company’s important decisions are made. Like other taxpayers, a company that is resident but not domiciled in Malta is subject to tax on chargeable income and capital gains arising in Malta and on chargeable income arising outside Malta and remitted to Malta, but not on capital gains arising outside Malta that are received in Malta. That a foreign company has a branch in Malta does not, in itself, constitute res - idency. A company that is neither resident nor domiciled in Malta is taxable on chargeable income and capital gains arising in Malta, unless such income and gains are subject to a specific exemption. Despite the default 35% corporate tax rate, as a result of Malta’s full imputation and tax refund system, the effective tax rate in Malta may be reduced to 5%.
W42 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S2 Malta
Full imputation system Although any shareholder of a Maltese company is, in principle, subject to tax in Malta on any dividends derived from such company, any economic double taxation is relieved through the operation of a full imputation system of taxation. Consequently, the tax paid by the Maltese company on the profits that it distributes as a dividend in favour of its shareholder is credited in full against the Malta tax liability of that shareholder. The 35% default tax rate applicable to companies is equivalent to the maximum progres - sive rate of tax applicable to individuals. Therefore, a dividend distribution received by either a corporate or a natural shareholder (resident in Malta or otherwise) would typically result in no further tax payable at the level of the shareholder. In fact, a shareholder that is subject to tax at a rate lower than 35% may claim a refund of the excess tax paid in Malta at the level of the company. Many states recognise the fact that Malta is one of the few remaining countries to operate a full imputation system. Consequently, most of Malta’s tax treaties effectively enable Malta to continue to operate its full imputation system in a cross-border context.
Tax refund system Over time, Malta has developed its imputation system to allow for a tax refund mechanism applicable at the level of the shareholders. A shareholder in receipt of dividends distributed out of certain profits of a Maltese company can claim a refund of the tax paid in Malta by such company on those profits. The amount of the refund to which the shareholder is entitled depends on: • the nature of the underlying profits out of which the dividend is distributed by the com - pany; and • the claiming of double taxation relief by the company on such profits. In most cases, the refund entitlement of a shareholder would be six-sevenths of the Malta tax suffered by the Maltese company on the profits out of which the dividend is distributed. However, this rate may be reduced in the following circumstances: • Where the profits out of which a dividend is distributed consist of passive interest or roy - alties, the refund is reduced to five-sevenths of the Malta tax suffered on those profits. • A tax refund at the rate of two-thirds of the Malta tax applies to dividends distributed out of certain profits in respect of which the distributing company has claimed a foreign tax credit to relieve cross-border double taxation. On the other hand, a company in receipt of dividends (or gains) derived from an invest - ment that qualifies as a participating holding may either: a) elect to apply the participation exemption, in which case such income (or gains) will be exempt from Malta tax; or b) include such income (or gains) as part of the taxable income of the Maltese company, which would entitle its shareholder in receipt of a dividend out of those profits to a full refund of the Malta tax paid by the company on that income (or gains). No such tax refunds as those referred to above can be claimed in connection with income derived, directly or indirectly, from immovable property situated in Malta. In addition, in certain situations – for example, where the Maltese company is beneficially owned by Malta resident and domiciled individuals – income derived by said company on which tax refunds are claimed requires reclassification as investment income and is taxable accordingly.
4W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S3 Malta
Double-tier structures While this is not required, due to the fact that any shareholder is entitled to claim tax refunds, a double-tier structure may have a number of advantages for the taxpayer, such as postpon - ing dividend payments to non-residents, thereby deferring any foreign tax charges without incurring any further tax in Malta. In certain jurisdictions it may also be beneficial to use a double-tier structure to ensure that the total income (including any tax refund) being received by the non-resident share - holder is received in the form of a dividend, which may be taxed more favourably (for exam - ple, exempt where a participation exemption regime is in place) in its country of residence than any tax refund. Moreover, no withholding taxes are levied on distribution of the divi - dends or payment of interest and royalties to non-resident shareholders. There are also no taxes or restrictions on export of the dividends from the Maltese company.
W44 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S4 Malta
Kirsten Cassar
Dr Kirsten Cassar is an associate forming part of the corporate and finance practice group at Camilleri Preziosi. Kirsten graduated as Doctor of Laws from the University of Malta after submitting a thesis on the ‘Developments to Article 7 of the OECD Model Tax Treaty and Commentary in light of the OECD 2010 Report on the Attribution of Profits to Permanent
Establishments’. Shortly after, Kirsten embarked on an LLM in Camilleri Preziosi corporate and securities law at the University of London. Kirsten practises in the areas of direct and indirect tax mat - Level 3, Valletta Buildings South Street ters, primarily in the provision of domestic and international tax Valletta, VLT 1103 advisory and tax restructuring services, including providing Malta advice particularly in the remit of identifying implications of, Tel: +356 2567 8117 and devising tax efficient structures for, local as well as cross- Email: kirsten.cassar@ border transactions. camilleripreziosi.com Website: Kirsten also regularly assists in advising clients on the corpo - www.camilleripreziosi.com rate law aspects of a wide range of transactions and other areas including corporate finance, M&A and capital markets. This provides clients with comprehensive insight on a wide range of matters which might have an impact on any particular transac - tion whether strictly related to the fiscal implications of a trans - action or otherwise.
4W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S5 Mexico
Roxana Gomez-Orta
Roxana M Gomez-Orta has 20 years of professional experience and is a member of Baker & McKenzie’s tax practice group which has been recognised as a highly recommended global tax practice by Chambers Global 2014 and as a recommended tax practice in Mexico by Chambers Latin America and International Tax Review .
She joined the firm in 2001, and was appointed national Baker & McKenzie partner of Baker & McKenzie Abogados in July 2007. Roxana focuses her practice on tax, administrative and con - Oficinas en el Parque Torre Baker & McKenzie Piso 10 stitutional matters. She has advised multinational and local com - Blvd Antonio L Rodriguez 1884 Pte panies in connection withtax planning, matters involving undue Monterrey, NL 64650 collections of contributions by the tax and administrative Mexico authorities, and tax litigation. Tel: + 52 81 8399 1308 She has published articles in Defensa Fiscal , IDC Asesor Email: roxana.gomez-orta@ Jurídico y Fiscal Puntos Finos Players Práctica Fiscal bakermckenzie.com , , , , Website: www.bakermckenzie.com Corporate Business Taxation Monthly , Maquila Reynosa , Periódico El Norte , Periódico Milenio , Inter -American Trade Report and Tax Notes International, among others. Roxana has been named one of the leading tax lawyers in Mexico by the magazine Defensa Fiscal in consecutive years from 2007, and as a tax controversy leader by International Tax Review 2014. She is a member of the Academia de Derecho Fiscal de Nuevo León, AC, Chapter Nuevo León and was appointed as member of the board, acting as the treasurer dur - ing 2008-2009. For 2015-2016, she is serving as an advisory member of the board. She obtained a law degree from the Universidad de Monterrey in 1996 and further obtained a master’s degree in tax law from the Universidad Autonoma de Nuevo Leon in 2001. Roxana speaks both English and Spanish.
W46 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S6 Mexico
Cecilia Montaño
Cecilia Montaño is a Deloitte Mexico indirect tax partner and Mexican and Latin American service line leader, specialised in foreign trade, customs and indirect tax. She has more than 18 years of experience in foreign trade. Cecilia became a Deloitte Mexico partner in 2008. Before joining Deloitte, Cecilia spent several years as a logis - tics and customs compliance manager in the private sector. Deloitte Mexico Cecilia helps multinational companies identify indirect tax opportunities and has worked with clients around the world on 489, P 6 Col. Cuauhtémoc 6501 Mexico City projects involving due diligence, customs audits and tax strate - Mexico gies relative to investments in Mexico, among others. Cecilia has extensive experience in compliance consulting. Tel: +52 55 50 80 64 19 Email: cmontanohernandez@ She works with clients operating across many industries includ - deloittemx.com ing the automotive, pharmaceutical, oil and gas, mining, ener - Website: www.deloitte.com gy and manufacturing sectors, among others. She received a bachelor’s degree in foreign trade and cus - toms from the Instituto Teconólogico de Monterrey , and is about to conclude a master’s in business administration, with a foreign trade specialisation, from the same institution. Cecilia is vice president of the Mexican Importers and Exporters Association (ANIERM), vice president of the Logistics & Customs committee at the Mexican Trade Council (COMCE), and is also an adviser for the National Maquiladora Council (INDEX) and par - ticipates as an active member of the most relevant associations in Mexico related to foreign trade and customs. She has a strong relationship with the Mexican government in topics related to foreign trade and customs and regularly participates strategically with the authorities on relevant projects.
4W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S7 Mexico Karina Perez Delgadillo PwC
W48 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S8 Netherlands
Suzanne den Breems
Suzanne den Breems is a principal in Ryan’s Amsterdam office and practice leader for European VAT, managing all aspects of the firm’s European VAT practice. Suzanne specialises in repre - senting and advocating for global Fortune 500 clients across a wide spectrum of industries on various VAT aspects . Suzanne has played an instrumental role in building Ryan’s
European VAT Recovery and Consultancy practice. Founded in Ryan 2011, the practice has since grown to more than 40 employees, centrally located throughout Europe. World Trade Center Amsterdam Tower G, Level 6 Previously, Suzanne was co-founder and partner of a Dutch Strawinskylaan 685 tax law firm that specialised in VAT and real estate transfer tax. 1077 XX Amsterdam She was also a manager for an international accounting and tax Netherlands law firm. In the public sector, she served as an officer in the Tel: +31 (0) 20 570 3520 Municipal Legal Advice Centre. Fax: +31 (0) 20 570 3525 Email: Suzanne lectures on various tax topics for Ryan clients and [email protected] the Ryan Professional Development Programme. Additionally, Website: www.ryan.com she is a frequent speaker for the International Air Transport Association. Suzanne was chief editor of the monthly tax law magazine, Fiskaal . She has also written various articles published in the International Tax Review and co-authored the Kluwer VAT Memo from 2002–2005. Suzanne holds a master of laws (LLM) degree, with an emphasis in indirect tax law, from the University of Leiden and a post-university degree from the Dutch Order of Academic Tax Advisors, and is accredited in tax assurance from Nyenrode Business University. She is also a member of the Dutch Association of Academic Tax Advisors.
4W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R4S9 Netherlands Mounia Benabdallah Baker & McKenzie Milja Bormann-Bakker Deloitte Juliana Dantas Baker & McKenzie Marja de Best Loyens & Loeff Margreet Nijhof Baker & McKenzie Trudy Perie Loyens & Loeff Agata Uceda KPMG Monique van Herksen EY Annet van Veldhuizen PwC
New Zealand Kirsty Keating EY
W50 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S0 Norway Method for gross up of net salary for cross-border employees
Norwegian authorities have for a number of years enforced a practice implying that net salary shall be grossed up in accor - dance with Norwegian tax rates, regardless of the tax amount actually paid in countries outside of Norway. Given that the employee is on an assignment in a country where there is no tax on income, or where the income tax is lower than in Norway, the taxation of the employee is based on a hypothet - ical benefit . Consequently, costs for the employer are higher both on the total tax liability and potentially higher for calculating social secu - Cathrine Bjerke Dalheim rity contributions both for the employer and for the employee. KPMG Norway The question has been tried both in lower and higher courts and in both cases the court ruled in the government’s favour. The question, as such, is of principal character and it may be appealed to the Supreme Court.
Legal basis The Ministry of Finance has clearly stated that the net salary agreement is a taxable benefit and is considered gained already when the contract between the employer and employee is signed. The benefit is considered taxable on accrued basis when the net salary is paid. The tax authorities’ view is that the employer in Norway is obliged to calculate the correct gross salary as if the employee was working in Norway. One argument given is that the term ‘net salary’ is not defined in the legislation and that Norwegian tax principles and rates must therefore apply. Avoidance of dou - ble taxation is ensured either under reference to the applicable tax treaty or Norwegian domestic law. The lower and higher court expressed significant doubt with regard to correct interpretation of the law, but ultimately
5W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S1 Norway concluded that it shall be the responsibility of the legislators to clarify in law or secondary law if the practice is unreasonable. Our opinion is that this is incorrect. As a starting point, there is not a clear legal basis to deviate from the rule and principle that the taxable basis is an actual benefit given from the employer, either as a cash salary or as benefits in kind. The principle of legality, general tax principles and de lege ferenda considerations weigh considerably against the lawfulness of the administrative practice followed by Norwegian tax authorities.
Practical consequences Instead of including the actual paid taxes in the host country and accruing this to the point of payment in accordance with the cash basis, Norwegian authorities require that the net salary is grossed up in accordance with Norwegian tax rates in advance of any actual tax pay - ments. The marginal tax rate in Norway is 47.2% (including employee social security rate of 8.2%) and the employer social security rate is 14.1%. As an example, a Norwegian employee on assignment in Dubai, where there is no tax on salary income, will not pay any tax on the salary income in Norway given that he fulfills cer - tain criteria. Social security contributions must, however, be paid. In a case like this, the con - sequence for the Norwegian tax authorities view will be as follows:
Income Employer soc sec Employee soc sec Total $250,000 (net) 35,250 20,500 55,750 $472,000 (grossed up) 66,552 38,704 105,256 The difference in payable social security amounts is $49,500.
Cost saving opportunities As the current administrative practice is supported by two court cases, the latest ruled July 6 2015, it is not an option to deviate from the practice and guidelines given by the Norwegian tax authorities. However, it is important to emphasise that the employers social security con - tribution may be avoided if the payroll is placed outside of Norway and the employee is not a member of the Norwegian social security scheme.
Litigation set to continue As the current situation in many contexts implies unreasonable and unnecessary costs for the employer, it is important to review the companies’ tax policy in cases where the employer has a significant number of assignees from Norway to other countries, especially if the assignees work in countries with significantly lower tax rates than in Norway. The higher court decision is not legally binding, as the deadline for appeal has not yet expired. It remains uncertain at this point if the case will be appealed and, if appealed, whether it will be approved for a Supreme Court decision. Due to the principle character of the question and the doubt expressed in the previous courts, we believe it is likely that the case will be approved for entry if appealed.
W52 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S2 Norway
Cathrine Bjerke Dalheim
Cathrine Bjerke Dalheim is an attorney-at-law. She is a partner in KPMG Law Advokatfirma and head of global mobility serv - ices in Norway. She has more than 17 years of experience with cross-border employments. She has worked with global mobili - ty since 1998. She started working for KPMG in 2000 and, before this, she worked at Norsk Hydro, corporate expatriate services. KPMG Huset / The global mobility services team is specialised in advising KPMG Law Advokatfirma employers and employees on global mobility, cross-border busi - Sørkedalsveien 6 ness trips and short-term and long-term secondments. Her field 0306 Oslo of expertise covers international tax and social security planning, Norway cost projection, strategic HR and policy advice, employment Tel: +47 4063 9055 law, and pension and insurance related topics. Email: Cathrine has substantial experience in advising multinational [email protected] corporations, headquartered both inside and outside of Website: www.kpmg.com/no Norway, on international tax matters. Through her deep and varied experience with strategic global mobility, she also has knowledge within corporate tax, transfer pricing and VAT, enabling her to evaluate risk exposure under the different employment structures. Since 2004, she has built a separate service, specialised in assisting foreign companies with temporary business activities in Norway and the services comprise of handling all employers’ obligations such as payroll, registration of employees, immigration, corporate tax compliance, VAT representation and so on. During her years in KPMG, she has covered different roles, such as head of markets for the firm, COB for the law firm and being a member of the Executive Committee. Cathrine is admitted to practise before the courts in Norway.
5W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S3 Norway
Tonje Christin Norrvall
Tonje Christin Norrvall is attorney-at-law and partner in KPMG Law Advokatfirma, as well as taking the lead on international private clients (IPC). Tonje has more than 27 years of experience with tax and global mobility, starting as consultant and group leader with the Norwegian tax authorities, as tax manager with Norske Shell and, since 2003, tax partner at KPMG in Norway. KPMG Law Advokatfirma Tonje has substantial experience in advising multinational corporations on international tax and social security aspects, as Sørkedalsveien 6 0306 Oslo well as in executive remuneration planning and preparation of Norway incentive plans. She also gives advisory services to high net worth individuals. Tonje assists clients in concluding non-bind - Tel: +47 4063 9223 Email: [email protected] ing advice agreements with the Norwegian tax authorities with respect to share transactions. Tonje has vast experience as the lead partner on numerous global engagements. She is also an experienced speaker and a board member of KPMG. Tonje is admitted to practice before the courts in Norway.
W54 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S4 Norway Hanne Skaarberg Holen Arntzen de Besche
Philippines Maria Carmela Peralta RG Manabat (KPMG) Benedicta Du-Baladad Du-Baladad Du-Baladad
Poland Aneta Blazejewska-Gaczynska EY Dominika Cabaj DLA Piper Renata Dluska MDDP Kalina Figurska-Rudnicka MDDP Karina Furga-Dabrowska Dentons Iwona Georgijew Deloitte Karolina Gizicka EY Aneta Gniewkiewicz Paczuski & Taudul Tax Advisors Patrycja Gozdiowska SSW (Spaczynski, Szczepaniak i Wspolnicy) Katarzyna Janik Independent Katarzyna Klimkiewicz-Deplano Advicero/Green Real Accounting Sylwia Migdal EY Dorota Pokrop EY Monika Poteraj DLA Piper
5W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S5 Poland Elzbieta Serwinska MDDP Ewelina Stamblewska-Urbaniak Crido - Taxand Joanna Stawowska Deloitte Marta Szafarowska MDDP Agnieszka Talasiewicz EY
Portugal Rose Areias PwC Catarina Belim Vieira de Almeida Serena Cabrita Neto PLMJ Carla Castelo Trindade Independent Clotilde Celorico Palma Eduardo Paz Ferreira Rita Chambel Vieira de Almeida Susana Claro PwC Maria Cravo BTOC Tax Tania de Almeida Ferreira Cuatrecasas Goncalves Pereira Claudia Reis Duarte Uría Menéndez Raquel Fernandes CMS Rui Pena & Arnaut Conceicao Gamito Vieira de Almeida Maria Ines Assis PLMJ
W56 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S6 Portugal Marta Machado de Almeida Rogerio Fernandes Ferreira & Associados (RFF) Rita Magalhaes Vieira de Almeida Alexandra Martins KPMG Catarina Matos EY Patricia Matos Deloitte Joana Nunes dos Reis Deloitte Tania Pereira Independent Marta Pontes Uría Menéndez Monica Santos Costa EY Teresa Teixeira Mota Vieira de Almeida Maria Torres PwC Isabel Vieira dos Reis Garrigues - Taxand
Romania Angela Rosca TaxHouse Taxand Romania
5W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S7 Russia Raisa Alexakhina Deloitte Irina Dmitrieva White & Case Elena Dremova (Puginskaya) PwC Maria Kostenko Baker & McKenzie Natalia Kuznetsova PwC Ekaterina Lazorina PwC Alexandra Lobova EY Ekaterina Malygina PwC Maria Mikhaylova PwC Galina Naumenko PwC Irina Panina KPMG Yana Proskurina PwC Natalia Vozianova PwC Anna Zvereva Dentons
W58 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S8 Singapore
Felicia Chia
Felicia is a director in KPMG’s Transfer Pricing practice and the Financial Services Transfer Pricing lead in Singapore. She has extensive experience in providing transfer pricing advisory services to multinational corporations across a multi - tude of industries in Singapore, the United States and the Asia Pacific region. Felicia has advised her clients on transfer pricing planning and documentation projects to determine proper KPMG in Singapore arm’s-length compensation for tangible property, intangibles and intercompany services. She has also assisted in the prepara - 16 Raffles Quay #22-00 Hong Leong Building tion of cost allocation studies for global/regional headquarters Singapore 048581 and was involved in audit defence assistance and transfer pricing risk analyses. Tel: +65 6213 2525 Fax: +65 6220 9419 In addition, Felicia has been involved in the negotiation and Email: [email protected] implementation of unilateral and bilateral advance pricing Website: www.kpmg.com.sg arrangements (APAs) and mutual agreement procedures (MAPs). She has led several value chain management projects and advised clients on complying with the OECD-BEPS guid - ance. Felicia is a regular speaker on global transfer pricing at client seminars and published a number of articles on transfer pricing issues. She holds a bachelor’s degree in law and a bachelor’s of commerce (double major in accounting and finance) from the University of Western Australia, and is an accredited tax practitioner with the Singapore Institute of Accredited Tax Professionals.
5W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R5S9 Singapore
Gan Hwee Leng
Hwee Leng is a partner of the Indirect Tax practice and has sub - stantial experience in GST-related matters both as a regulator and a business adviser. She has assisted businesses in responding to audit queries from the Inland Revenue Authority of Singapore (IRAS), in seeking tax rulings and advising on tax and penalties risk management. Hwee Leng has also been actively involved in advisory, compliance work, reviews and liti - KPMG in Singapore gation support for various industry sectors. Before joining KPMG, Hwee Leng was a senior tax officer 16 Raffles Quay #22-00 Hong Leong Building with the IRAS for 15 years. She was involved in tax policy mat - Singapore 048581 ters on GST, corporate tax, advance income tax ruling, interna - tional taxation, transfer pricing and tax treaties. In IRAS, Hwee Tel: +65 6213 2813 Fax: +65 6220 9419 Leng was part of the GST implementation team that drafted the Email: circulars on the laws, regulations and GST guidelines for busi - [email protected] nesses and the public. She is also involved in the audit of GST- Website: www.kpmg.com.sg registered businesses, setting up of GST policy, fine-tuning the GST system and overseeing amendments of GST laws, imple - mentation of the GST rate increase in Singapore and conduct - ing trainings on GST. In her current role, Hwee Leng serves as a GST Assisted Self-help Kit (or ASK – introduced by the IRAS as a self-assess - ment package designed to help GST-registered businesses effectively manage their compli - ance) reviewer and indirect tax adviser for public, multinational and local organisations. She is a frequent speaker at GST seminars for clients and the public, and a training instructor with the Singapore Institute of Accredited Tax Professionals. Hwee Leng is also a regular contributor to the International Tax Review (ITR) and KPMG International’s indirect tax publications. She is also one of the contributors for ‘Goods and Services Tax – Law & Practice’, which provides practical advice on the adminis - trative and compliance aspects of GST in Singapore. For the past two years, including this year, ITR has recognised Hwee Leng as a leading indirect tax adviser in Singapore. She has a bachelor’s degree in accountancy (second honours) from the National University of Singapore and a master’s in public administration/international tax programme from Harvard University. Hwee Leng is also a fellow of the Institute of Chartered Accountants in England and Wales.
W60 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S0 Singapore Nicole Fung PwC Ken Loon Ong Drew and Napier Dawn Quek Baker & McKenzie.Wong & Leow Chai Sui Fun PwC
South Africa Julia Boltar Group 621 Christel Brits EY Cinzia de Risi EY Roula Hadjipaschalis KPMG Nazrien Kader Deloitte Anthea Scholtz Deloitte Annemarie Schroeder Deloitte Virusha Subban Bowman Gilfillan Yasmeen Suliman KPMG Natasha Vaidanis KPMG Suzanne van der Merwe Deloitte Louise Vosloo Deloitte Patricia Williams On Your Side
6W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S1 Spain Maria Antonia Azpeitia Baker & McKenzie Isabel Lopez-Bustamante Deloitte Belen Palao bln palao abogados Natalia Pastor KPMG Alejandra Puig Deloitte Ana Royuela Baker & McKenzie Montserrat Trape KPMG Sonia Velasco Cuatrecasas Goncalves Pereira Esther Zamarriego Santiago Garrigues - Taxand
W62 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S2 Sweden
Ulrika Grefberg
Ulrika is a partner at Svalner Skatt & Transaktion, and is one of the leading indirect tax advisers in Sweden. For more than 15 years she has advised Swedish and foreign companies, from small to listed companies in a wide range of business sectors. Ulrika’s main focus areas are telecom, energy, retail, automo - tive, health care, transportation and cargo handling, pharma - ceutical and public service. Ulrika is often engaged to assist in Svalner Skatt & Transaktion lobbying and preparation of draft laws. Another main focus area is litigation. Ulrika is advising and Smålandsgatan 16 111 46 Stockholm representing clients in litigations mainly within the area of indi - Sweden rect tax. Ulrika is also regularly enlisted as a lecturer at conferences Tel: +46 8 528 01 275 Fax: +46 8 528 01 260 and seminars. Mobile: +46 76 899 69 10 Before joining Svalner Skatt & Transaktion, Ulrika’s previ - Email: [email protected] ous roles included a stint as a tax lawyer at Ernst & Young, as Website: www.svalner.se well as at the Swedish Tax Agency and District Court. Ulrika holds an LLM from Uppsala University. She speaks (and works in) both Swedish and English and has published articles in various publications.
6W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S3 Sweden
Ylva Hestréus
Ylva Hestréus is on the indirect tax team at Deloitte Sweden. She has worked with VAT matters for more than 20 years, including 11 years with the Swedish Tax Agency. Her work with the Tax Agency included five years as a legal expert focusing on the financial sector. For the last 12 years, Ylva has worked as a VAT adviser with continued focus on clients within the financial sector. She is also Deloitte Sweden responsible for Deloitte Sweden’s VAT/financial services indus - try team. Ylva is a trusted adviser for many large companies in Rehnsgatan 11 SE-113 79 Stockholm the financial sector and gives advice to medium and large com - Sweden panies relative to complex VAT matters, correspondence with the Tax Agency and so on. Ylva has also worked with VAT issues Tel: +46 752 46 26 87 Email: [email protected] for Swedish and international companies in connection with the Website: www.deloitte.se acquisitions of groups in Sweden. She is a frequent lecturer at VAT seminars and has authored several articles on VAT. Ylva earned a master’s degree in law from the University of Stockholm in 1992 and is certified as a tax adviser by FAR, the institute for authorised accountancy professions in Sweden. Ylva is also a board member in policy matters of taxation for FAR.
W64 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S4 Sweden
Monica Söderlund
Monica joined Grant Thornton Sweden in August 2009 as head of tax. Monica’s previous in-house experience is with IKEA Services as global head of tax, as well as having held advisory positions with KPMG and Arthur Andersen/Deloitte. She also has expe - rience of working as an official at the Swedish Tax Agency.
In the profession Monica has developed substantial expertise Grant Thornton within the field of corporate and international taxation focusing on inward investments, restructuring and mergers and acquisi - Sveavägen 20 PO Box 7623 Stockholm, SE-103 94 tions. Sweden Today, Monica primarily focuses on leading the Swedish tax practice, which comprises more than 75 tax consultants dealing Tel: +46 (0)7068 700 02 Email: in all areas of domestic and international taxation. [email protected] Monica strives for high client satisfaction based on pragmat - Website: www.grantthornton.se ic and commercial tax advice. Monica is a member of the council of the tax department at FAR, the institute for the accounting profession in Sweden, as well as FAR’s tax authorisation committee.
6W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S5 Sweden Mylene Beiming PwC Lina Engman Skeppsbron Skatt - Taxand Sweden Susann Lundstrom KPMG Tina Zetterland KPMG
W66 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S6 Switzerland
Elizabeth Barendregt
Inspired by KPMG’s multidisciplinary approach, Elizabeth recently joined KPMG to lead the firm’s indirect tax practice in Western Switzerland. At KPMG, Elizabeth works with multinational and national clients in all sectors with a special focus on energy and commod - ity trading. She works closely with her clients to develop their global Indirect tax strategy taking into account their organisa - KPMG tional and supply chain structure and manages their VAT on a global basis. She focuses on value creation specifically in the era Rue de Lyon 111 PO Box 347 of Big Data, an area in which she helps clients transform their CH-1211 Geneva 13 trade data into value. Elizabeth holds a master’s degree in Switzerland finance and is an AITI chartered tax adviser (CTA) and associ - Tel: +41 58 249 65 02 ate of the Irish Taxation Institute. Email: [email protected] Originally, Elizabeth started her career at Ernst & Young in Website: www.kpmg.com Beirut as a tax consultant while she was still at university. In 2001, she was seconded to Ernst & Young in Dublin where she worked for nine years. During her career at Ernst & Young, Elizabeth worked for many different clients and industries which contributed to the development of her experience in international indirect tax. While in Dublin, in addition to the CTA, she also completed a diploma in investment fund services to better understand the investment fund clients she was serving at that time. In 2010, Elizabeth decided to move to Geneva Switzerland as an international VAT manager at PwC, and quickly rose through the ranks as a result of her capabilities, hard work and determination. Elizabeth’s international experience helps her understand different cultures and how to deal with people with different backgrounds. In addition to this, she speaks English, French, Arabic, Armenian and a little Dutch as she is married to a Dutchman.
6W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S7 Switzerland Marieke Bakker Loyens & Loeff Maja Bauer-Balmelli Tax Advisors & Associates Sarah Dahinden PwC Nicole Fragniere Meyer Gillioz Dorsaz & Associes Barbara Henzen EY Michaela Merz PwC Britta Rehfisch ADB Corinne Scagnet Deloitte
Taiwan Sophie Chou EY Josephine Peng Lee and Li Glendy Yuan Deloitte
Tunisia Sonia Louzir Deloitte
W68 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S8 Turkey
Güler Hülya Yılmaz
Guler Hülya Yilmaz is a sworn certified financial consultant who leads the cross-border tax service line and has been responsible for the transfer pricing (TP) service line in the Turkish tax prac - tice since June 2006. She started her career as an independent auditor in the audit department of the former Arthur Andersen in 1989 after her graduation from university. Hülya has spe - cialised in international tax consultancy services since she began Deloitte her career at Deloitte in 1993 after her post-graduate studies. She has significant experience in tax consultancy and tax plan - Deloitte Values House Maslak Mahallesi, Eski Büyükdere ning that involves transfer pricing, legal and international tax Cad. No:1 aspects. She has also been actively involved in tax structuring for Maslak No 1 Plaza major M&A projects in Turkey. 34398, Maslak – Sarıyer, Istanbul Turkey Hülya became a tax partner in Deloitte Turkey’s tax practice on June 1 2006 (as the first female tax partner within the Big 4 Tel: +90 212 366 60 72 Mobile: +90 533 275 70 03 in Turkey). She is also the country leader for the life science and Email: [email protected] healthcare industry and is the Tax Learning Leader in Deloitte Website: www.deloitte.com Turkey. She also has significant experience in serving multination - al firms in the energy sector. She advises multinational clients in tax matters related to permanent establishment issues, application of tax treaties, restructuring, tax and TP related tax audit cases. Her transfer pricing work covers TP documentation and planning projects across various sectors; cost allocation analysis and cost-sharing agreements; tax analysis of IP transfer or migration plans; TP audit defence; unilateral APA applications; TP analysis of contract R&D applications; and comparative analysis of the treatment of relat - ed party transactions in the New Turkish Commercial Code versus the Turkish Capital Market Law, considering the underlying TP implications. Hülya is experienced in tax modeling and consultancy for energy project companies operat - ing under the financing models of ‘build-operate-transfer’ (BOT) and ‘transfer of operation rights’ (TOR). She provides transfer pricing consultancy regarding unbundling transactions in the energy industry (generation, transmission, distribution, shared services and so on) under alternative tax structures. Hülya also provides TP documentation studies for the trading of spe - cific materials in the mining sector (used in power generation) between related parties. She also has experience in income and profit attribution in relation to ‘turnkey projects’. Hülya speaks English and Turkish and has working knowledge of French. She holds a bachelor of arts degree in business administration from Marmara University and a master’s degree in business administration from the Bogazici University. She is a sworn financial consultant; a member of the Istanbul Chamber of Sworn Financial Consultants; a member of the Turkish branch of IFA; a member of the Association of Foreign Investors in Turkey (YASED) working group on life sciences and healthcare; and a member of the healthcare committee in the American Business Forum in Turkey, part of the American Chamber of Commerce (AmCham) Turkey.
6W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R6S9 Turkey Duygu Gultekin Baker & McKenzie Uluc Ozcan Erdikler - Taxand Guler Hulya Yilmaz Deloitte
Ukraine Victoria Chornovol Deloitte Viktoria Fomenko Dentons Vita Forsiuk Jurimex Iryna Marushko Lavrynovych & Partners Svitlana Musienko DLA Piper Tatiana Zamorska KPMG
W70 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S0 UK
Roopa Aitken
Roopa Aitken is a corporate tax partner at Grant Thornton UK with significant experience of advising multinational groups on a wide range of tax matters. Roopa has had more than 19 years of experience advising a range of business types and sizes on tax matters. She specialises in EU claims and related tax issues and has advised many clients on the compatibility of UK law with EU law. Most recently she Grant Thornton successfully advised in the Philips Electronics case which was heard by the Court of Justice of the European Union. 30 Finsbury Square London EC2P 2YU Roopa’s wider tax team and colleagues provide advice con - UK cerning all tax matters including indirect taxes and private client in addition to corporate tax, thereby ensuring that all aspects of Tel: +44 (0)20 7728 3195 LinkedIn: her clients’ tax affairs are catered for. uk.linkedin.com/in/roopaaitken Many of the matters which Roopa advises on have cross-bor - Email: [email protected] Website: der implications affecting a client’s business in numerous juris - www.grant -thornton.co.uk dictions. Roopa is able to draw upon the expertise and experi - ence of colleagues in the Grant Thornton International teams from around the world to deliver seamless advice. Roopa works closely with her specialist colleagues across all of Grant Thornton’s service lines to ensure her clients have access to the full breadth of advice and counsel available to sup - port their businesses’ developments and wider growth aspirations. Roopa is a regular presenter at tax conferences and has published numerous technical arti - cles on tax issues. She is on the UK branch committee of the International Fiscal Association and the team has a strong reputation in the market, winning ‘Best International Tax Team’ at the 2012 Lexis Nexis awards and ‘Best Team in a National Practice’ at the Taxation awards 2014.
7W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S1 UK
Karen Cooper
Karen is a partner in Osborne Clarke’s tax department and leads the firm’s employee benefits practice. She has more than 20 years’ experience advising a broad range of clients on the design, implementation and communication of the full range of employee benefits and share schemes. Karen works for a diverse range of clients from owner man - aged businesses through to global multinationals. She is Osborne Clarke renowned for her ability to devise commercially effective remu - neration strategies to incentivise and motivate key individuals 2 Temple Back East Temple Quay within an organisation. She also advises clients and their interna - Bristol BS1 6EG tionally mobile employees on tax efficient remuneration packages. DX 7818 Bristol Karen acts on a broad range of corporate transactions and UK advises remuneration committees in relation to all-employee Tel: + 44 (0) 117 917 3628 and senior executive equity schemes. Fax: + 44 (0) 117 917 3629 Mobile: + 44 (0) 7753 832 328 Karen qualified as a lawyer in 1995 and joined Osborne Email: karen.cooper@ Clarke as a partner in 2001. She is ranked as a leading individ - osborneclarke.com ual by the legal directories for her work on employee benefits. Website: www.osborneclarke.com Karen is an active member of the Share Plan Lawyers Organisation, and is a member of the Share Schemes Committee for the Quoted Companies Alliance. She is the author of the directors’ remuneration chapter of Sweet & Maxwell’s A Practical Guide to Corporate Governance and the share schemes chapter in Jordan’s Company Administrations. She writes for key tax publications and is a regular speaker at industry conferences. She holds a BA in jurisprudence from Oxford University.
W72 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S2 UK
Liesl Fichardt
Liesl Fichardt leads Clifford Chance’s contentious tax practice and is one of the UK’s leading tax disputes practitioners. She has extensive experience in tax litigation, negotiations with rev - enue authorities and settlement of disputes. She possesses con - siderable court and tribunal experience including conducting cases in the Tax Tribunal, the courts of appeal and the Court of
Justice of the European Union. Clifford Chance Liesl practiced as a tax barrister for 13 years and previously acted as a judge in the High Court of South Africa. She is chair - 10 Upper Bank Street London E14 5JJ person of the British Branch of the International Fiscal UK Association. She is recognised in leading legal directories including International Tax Review ’s Tax Controversy Leaders Tel: +44 (0)20 7006 2044 Email: Guide for her outstanding success and for consistent positive [email protected] feedback from clients and peers. Website: www.cliffordchance.com Liesl leads arguably the most experienced group of partners who deal with tax investigations, litigation and dispute resolu - tion. The combination of local expertise and global network allows Clifford Chance to handle complex disputes effectively and efficiently, whether in the UK or any other jurisdiction. Clifford Chance advises multinationals, financial institutions, corporates and high net worth individuals on a number of tax and VAT matters covering the entire range of tax dispute res - olution including: • Prevention related advice, risk assessments and risk management; • Tax audits and tax raids; • Tax compliance related advice; • Investigations (both civil and criminal); • Negotiation and drafting of settlements with tax authorities; • Cross-border disclosure requests from tax authorities; • Tax litigation before national and international courts, specialist tax tribunals, the courts of appeal and the Court of Justice of the European Union; • Parliamentary, European Commission and similar investigations; • Lobbying revenue authorities on the formulation of tax legislation and guidelines; and • Enforcement proceedings.
7W3 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S3 UK
Erika Jupe
Erika Jupe is a partner in Osborne Clarke’s corporate tax prac - tice and heads the international tax practice group. She is also a member of Osborne Clarke’s international council. She has more than 20 years’ experience advising both UK and multina - tional clients on a broad range of tax issues. Her work includes both standalone tax consultancy work as well advising on a broad range of transactions including merg - Osborne Clarke ers and acquisitions, financings, joint ventures and restructur - ings. Her practice covers cross-border tax issues, partnerships, 2 Temple Back East Bristol BS1 6EG value added tax and international employee tax issues. UK Erika advises clients across a broad range of sectors and rep - resents many of the firm’s biggest corporate clients on their Tel: +44 (0)117 917 4260 Fax: +44 (0)117 917 4261 transactions, with a particular emphasis on life science compa - Email: [email protected] nies and representing investment funds on formation, invest - Website: www.osborneclarke.com ment and restructuring activity. She works with many international clients of the firm, often representing overseas companies investing in the UK and Europe, or acting for European clients investing further afield. In such cases, she works closely with lawyers in Osborne Clarke’s international offices. Erika qualified as a lawyer in 1990 and joined Osborne Clarke in 1997, becoming a partner a year later. She is a member of the UK branch commit - tee of the International Fiscal Association and is a frequent speaker on tax developments and contributor to tax publications. She is the author of the chapter on e-commerce in Tolley’ s Tax Planning. Erika is ranked in the UK legal directories as a leading individual on corporate tax mat - ters.
W74 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S4 UK
Francesca Lagerberg
Francesca Lagerberg is the global leader for tax services at Grant Thornton International, the sixth largest global accounting organisation with $4.7 billion in revenues and operations in 130 countries. Additionally, Francesca also serves as a member of the Grant Thornton global leadership team and is responsible for Grant Thornton European member firms and global legal issues. She is the only woman running a global tax practice Grant Thornton among the six largest global accounting organisations. Before seconding to Grant Thornton International in 2013, Melton Street, Euston Square London NW1 2EP Francesca was the head of tax for the Grant Thornton UK mem - UK ber firm. She has worked in tax for more than 20 years and her main focus today is helping the Grant Thornton network grow Tel: +44 (0) 20 7728 3454 Email: its tax practices and attract, retain and develop talent in the [email protected] whole network by encouraging a consistent and inspiring cul - Website: www.grantthornton.com ture in which people can thrive. Under Francesca, Grant Thornton has taken global leader - ship positions on a number of tax issues important to business, including most recently, global transfer pricing. In her thought leadership role, she is a regular commentator on radio and TV and in print, having appeared in numerous major press outlets including the Harvard Business Review , the Wall Street Journal , the Financial Times , Reuters, Bloomberg TV and BBC-TV . She is actively involved in lobbying for better, clearer and more proportionate tax legisla - tion around the globe. She spoke recently on improving the relationship between tax interme - diaries and revenue authorities at the annual conference of the Intra-European Organisation of Tax Administrators. She also is on the UK’s Tax Professionals Forum, chaired by the UK’s financial secretary, the role of which is to oversee the implementation of the government’s commitment to reforming the framework for developing tax policy and making tax law. Francesca is a past chairman of the Tax Faculty of the Institute of Chartered Accountants in England & Wales (ICAEW) and is a past council member of the Chartered Institute of Taxation (CIOT). She is a fellow of the ICAEW and the CIOT, and is a qualified barrister and coach. She has written and edited many tax publications and has won awards for lectur - ing in tax and for her role in private client tax work. Francesca leads on women in business issues for Grant Thornton including this year’s research on the path to leadership and is engaged in promoting the commercial case for more diversity at the senior and board level in business.
7W5 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S5 UK
Wendy Nicholls
Wendy has more than 25 years’ international experience advis - ing clients in the UK and overseas and is a member of the Grant Thornton members firms’ Global Transfer Pricing Leadership team and is acknowledged in the Euromoney/Legal Media Group Guide to the World’s Leading Transfer Pricing Advisers and the Guide to the World’s Leading Women in Business Law.
She sits on the Business and Industry Advisory Committee Grant Thornton (BIAC) to the OECD and the Joint Transfer Pricing Forum which consists of government, tax authority and business repre - Grant Thornton House Melton Street sentatives, and has the remit to help solve practical transfer pric - Euston Square ing issues within the EU. London NW1 2EP Wendy works with businesses across many industries, special - UK ising in those where intellectual property is important. Her Tel: +44 (0)20 7383 5100 work encompasses transfer pricing documentation (master file Fax: +44 (0)20 7383 4715 Email: [email protected] and country file) as well as planning for international expansion Website: and growth, and dealing with the resolution of disputes. She www.grant -thornton.co.uk also helps businesses navigate the changes arising from the G20/OECD project on base erosion and profit shifting (BEPS).
W76 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S6 UK
Heather Self
Heather Self is a partner (non-lawyer) in international law firm Pinsent Masons’ market-leading tax disputes practice. With more than 30 years’ experience in tax, she has been an in-house tax director and a senior adviser at HMRC and is part of a multidis - ciplinary team advising on a wide range of corporate tax disputes. Heather’s in-house experience was as group tax director at
Scottish Power, which at the time was a FTSE 100 energy com - Pinsent Masons pany. She had responsibility for all tax matters and advised on numerous corporate transactions, including the $5 billion dis - 30 Crown Place Earl Street posal of the regulated US energy business. At HMRC, she London EC2A 4ES worked on complex disputes with FTSE 100 companies, and UK was a specialist adviser to the utilities sector, where she was Tel: +44 (0)161 662 8066 involved in policy issues on energy generation and renewables. Email: heather.self@ Her current practice is focused on the large corporate mar - pinsentmasons.com Website: ket, where she advises companies on technical issues and dispute www.pinsentmasons.com resolution. Clients have said that the combination of her expe - rience has meant that she can “see things from all sides” and is able to give insights into the behaviour of HMRC as an organ - isation, as well as praising her client engagement. Heather is a frequent speaker and commentator on tax in print and broadcast media, and regularly appears on pro - grammes such as BBC Breakfast, Wake up to Money and the Today programme. She is a member of the CBI Tax Committee and a CEDR accredited mediator. She also tweets as @hselftax.
7W7 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S7 UK Renata Ardous Mazars Amanda Brown KPMG Helen Buchanan Freshfields Bruckhaus Deringer Lydia Challen Allen & Overy Jane Curran Deloitte Nikol Davies Taylor Wessing Annie Devoy PwC Karen Eckstein Simpson & Marwick Sarah Falk Freshfields Bruckhaus Deringer Alison Foster QC 39 Essex Chambers Heather Gething Herbert Smith Freehills Sonia Gilbert Clifford Chance Zena Hanks Saffery Champness Kendra Hann Deloitte Diane Hay PwC Louise Higginbottom Norton Rose Fulbright Karen Hughes Hogan Lovells Julie Hughff KPMG Kristine Jarve EY
W78 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S8 UK Anbreen Khan Deloitte Sarah Lee Slaughter and May Sara Luder Slaughter and May Jane McCormick KPMG Gabrielle McParlin EY Aparna Nathan Devereux chambers Nicola Shaw Gray’s Inn Tax Chambers Kelly Stricklin-Coutinho 39 Essex Chambers Fiona Walkinshaw Deloitte Philippa Whipple, QC 1 Crown Office Row
7W9 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R7S9 US Women in tax: The US perspective
It’s a good time to be a female tax lawyer in the United States. While, most certainly, more needs to be done, women have made significant progress in the US in recent years. Two women have been commissioners of the IRS: Peggy Richardson and Shirley Peterson. Peggy was Commissioner for four years, and Shirley, following her tenure as Commissioner, has sat on a number of large corporate boards of directors. A third woman, Linda Stiff, also served as an acting IRS commis - sioner. I remember the first time that I met Shirley. She was dressed Jennifer Fuller in beautifully attractive clothes. It impressed me as a young Fenwick & West female tax attorney to meet her. A woman could be both suc - cessful and beautifully dressed. In the US Treasury Department, Danielle Rolfes serves as International Tax Counsel. In the IRS, two deputy associate chief counsels (international) are female, Anne Deveraux and Margie Rollinson, and two international branch chiefs, Elizabeth Karzon and Barbara Felker, are women. It wasn’t long ago that Phyllis Marcus was also an international branch chief. These are talented, as well as important, people. Danielle and Barbara, for example, went to Harvard Law School. There have also been notable and encouraging developments in the private practice of tax law. The California Bar Tax Section has had eight female chairs of the Tax Section, and the New York State Bar Tax Section has had five women serve as chair. Most of this happened in recent years. More needs to be done in the tax world, however. The US Tax Court, which has 18 sitting judges, has only five female judges. These are impressive judges, indeed, but it would seem there should be more than only five women on the court. Judge Marvel, for example, recently wrote the court’s opinion in one
W80 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R8S0 US of the most significant decisions in recent years in the Tax Court, Altera v Commissioner . Altera involves an effort by the IRS to overrule an earlier decision in Xilinx v Commissioner , by issuing a new regulation. Judge Marvel, writing for a unanimous court, held that in this situation the IRS did not apply proper administrative review procedures and wrote a regula - tion that is contrary to the guiding arm’s-length standard. While as a practitioner I was pleased to see that the taxpayer was successful in this important case, the more impressive thing to me was the understanding and intellect that went into the court’s opinion. Judge Marvel did an excellent job. A few years ago, I had a trial with Judge Cohen in Illinois Tool Works v Commissioner . She was the Tax Court’s first female Chief Judge. At that time, there were only two other women on the court. While five female members of the court today suggests some improvement, I think there should be more. I was at a dinner in New York last year and met Erika Nijenhuis, a senior tax partner with Cleary Gottlieb Steen & Hamilton and a past chair of the NYS Bar Association Tax Section. It was great talking with her. It made me think of that term – dare I use it – “old boy’s net - work,” but there we were: two successful tax lawyers, female and beautifully feminine. Two judges spoke at the dinner, too. Both were female. It is an exciting time for women tax lawyers in the US. Things have improved so much since the time of Supreme Court Justices Ginsburg and O’Connor who graduated with very high honours from law school but could not get jobs with a law firm because they were female. We’ve made great progress, but as I said above, more is needed to continue moving in the right direction and eradicate gender bias entirely.
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Cathleen Bucholtz
Cathleen Bucholtz is the managing director and National Unclaimed Property Practice leader for the Unclaimed Property Solutions Team of True Partners Consulting. Cathleen has extensive experience in all aspects of unclaimed property includ - ing audit defence, comprehensive diagnostic reviews, statistical sampling, development of leading practices, and annual compli - ance. Before joining True Partners Consulting, Cathleen held True Partners Consulting the Western Region Unclaimed Property Practice leader for LLC KPMG, and before 2002, was part of the National Unclaimed 633 West Fifth Street, Suite 6200 Property Team for Arthur Andersen. Los Angeles, CA 90071 Cathleen has more than 23 years of experience in unclaimed US property and state and local tax consulting and auditing, and Office phone: +1 213 417 2501 has represented numerous Fortune 500 clients in the defence of Fax: +1 213 417 2551 both unclaimed property and sales and use tax audits, resulting Cell: +1 805 558 9285 Email: in hundreds of millions in total client savings. [email protected] Cathleen also has extensive experience in unclaimed proper - Website: www.tpctax.com ty consulting for the healthcare, financial services, insurance, manufacturing, and retail industries. Before entering public accounting in the late 1990s, Cathleen was a senior sales tax auditor and field audit supervi - sor for the California State Board of Equalisation. Cathleen has spoken before numerous trade and professional organisations including the Unclaimed Property Professionals Organisation (UPPO), American Payroll Association, Institute for Professionals in Taxation (IPT), and the National Business Institute (NBI). In addition, she regularly collaborates on unclaimed property semi - nars geared toward the education of individuals in private industry. Cathleen was recently pub - lished in the Spring 2015 issue of the Journal of State Taxation : Frequently Asked Questions About Unclaimed Property. Cathleen is now serving as the co-chair for the UPPO’s Leadership Development Committee. Previously Cathleen served as co-chair for UPPO’s Mentors Committee as well as four years as UPPO’s Education Committee co-chair, where she helped develop a multi-track educational agenda for the organisation’s conferences attended by hundreds of participants annually. Cathleen earned a bachelor’s degree in business economics from the University of California, Santa Barbara and is a licensed certified public accountant (CPA).
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Elizabeth Erickson
Elizabeth Erickson is a partner in the law firm of McDermott Will & Emery and is based in the firm’s Washington, DC office. She is a member of the US & International Tax practice group, and focuses her practice on tax controversies, including tax liti - gation. Elizabeth represents clients in disputes before the US Tax
Court, US district courts, the Internal Revenue Service Appeals McDermott Will & Emery and Examination Divisions, and the Internal Revenue Service National Office. Substantive issues in dispute in these matters The McDermott Building 500 North Capitol Street, NW have included capitalisation and change in method of account - Washington, DC 20001 ing issues; captive insurance; accounting for redemption of pre - US mium coupons; abandonment loss issues; section 1341 claims; Tel: +1 202 756 8097 the tax treatment of settlement payments and legal fees, includ - Fax: +1 202 756 8087 ing tax reporting requirements; transfer pricing issues; and tax Email: [email protected] advantaged transactions. She also has substantial experience Website: www.mwe.com assisting clients with alternative dispute resolution techniques at the pre-filing, exam and appeals stages. Elizabeth is a frequent speaker on tax controversy matters, and was recognised as a ‘rising star’ in tax controversy in the 2014 edition of The Legal 500 United States . She was also named a 2014 ‘Tax Controversy Leader’ by the International Tax Review . Elizabeth is the hiring partner for the Washington, DC, office, and is a former co-chair of the Pro Bono and Community Service committee for the Washington, DC office. Elizabeth is admitted to practice in the District of Columbia. Her representative experience includes acting in ITOCHU International v American Tire Distributors ; Securitas Holdings v Commissioner ; Goodrich Corp v United States ; USAA v United States and USAA v Commissioner ; Capital One Fin Corp v Commissioner ; Washington Mutual v United States ; Hercules v Commissioner ; and Mary Kay Hold Corp v Commissioner. Elizabeth received her JD ( cum laude ) from Georgetown University Law Centre, and bachelor’s ( magna cum laude ) and master’s degrees in accountancy from Florida State University.
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Jennifer Fuller
Jennifer Fuller is a senior partner in the tax group at Fenwick & West in Mountain View, California. She was included for the fifth time as one of the world’s top 25 women tax advisers in Euromoney’s World’s Leading Women Business Lawyers (2015). Jennifer was named ‘America’s Best in Tax Dispute Resolution’ by Euromoney at its 2014 and 2015 Americas
Women in Business Law Awards Dinner. She also has been on Fenwick & West Euromoney’s Women in Business Law shortlist three times for the award ‘Best in Tax’. 801 California Street Mountain View, CA 94041 Jennifer’s work during 2015 included large-corporate tax lit - US igation and M&A matters, including work on some of the recent and widely publicised inversion transactions. Tel: +1 650 335 7284 Email: [email protected] Jennifer is on the Executive Leadership Committee of the Website: www.fenwick.com International Fiscal Association, which is a highly-regarded worldwide association of leading tax advisers, and has appeared regularly in Euromoney’s World’s Leading Tax Lawyers . Jennifer has served as the Northern California chair for the California State Bar International Tax Committee. She has spoken at and chaired numerous seminars on international tax subjects, while her articles have appeared in Tax Notes International magazine and in Tax Notes magazine. Whittier College awarded Jennifer its Alumna Achievement Award in 2013 “for superior accomplishments in her career”. Later that year, she was elected to serve on the Whittier College Board of Trustees, a position she still holds. A tax partner at Fenwick for more than 20 years, Jennifer plays an instrumental role in the firm’s tax practice. The firm has represented six of the Fortune top 10 companies, more than 50 of the Fortune 100 and more than 100 of the Fortune 500 companies in federal tax matters. Jennifer also has been included in Euromoney’s Guide to the World’s Leading Tax Advisers, Law and Business Research’s International Who’s Who of Corporate Tax Lawyers, ITR’s Leading Lawyers in the Western US, Euromoney’s Guide to the Leading US Tax Lawyers, and International Tax Review’s Best Tax Advisers in North America .
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Kathryn Keneally
Kathy Keneally serves as the chair of civil and criminal tax litiga - tion in DLA Piper’s global tax group. Before joining the firm, Kathy served as the assistant attorney general for the Tax Division of the US Department of Justice (DoJ), where she oversaw the work of more than 350 attorneys in civil, criminal and appellate tax litigation nationwide.
During her tenure as the head of the DoJ Tax Division, DLA Piper Kathy developed and implemented key tax enforcement initia - tives in close cooperation with IRS leadership. She worked 1251 Avenue of the Americas New York, NY 10020-1104 closely with DoJ leadership, US attorneys, and senior officials at US federal and state regulatory agencies, including the Federal Reserve Board of Governors, the New York Federal Reserve, Tel: +1 212 335 4582 Fax: +1 212 884 8559 the Securities and Exchange Commission, and the New York Email: Department of Financial Services. As the nation’s top tax pros - [email protected] ecutor, she oversaw precedential action against financial institu - Website: www.dlapiper.com tions. Attorney general Eric G Holder, Jr recognised Kathy by awarding her the Edmund J Randolph Award for Outstanding Service to the US Department of Justice and the Nation, the highest honour the Attorney General may bestow on a DoJ employee. Kathy focuses her practice on civil and criminal tax contro - versy matters, government investigations, and white collar criminal defence. She has more than 30 years of experience representing large corporations, financial institutions, closely held businesses and high-net-worth individuals in civil and criminal tax matters and non-tax crim - inal defence matters. She is an experienced trial lawyer, and has also resolved matters with the IRS and other federal agencies without proceeding to litigation. She also assists clients who seek to come into compliance ahead of an investigation. Kathy is a leader in the legal community. She has served as a vice chair of the American Bar Association Section of Taxation, and chaired two of the Section of Taxation’s commit - tees – the Committee on the Standards of Tax Practice and the Committee on Civil and Criminal Tax Penalties. She is now a regent of the American College of Tax Counsel, and serves as a chair of the National Institutes on Tax Controversy and Criminal Tax Fraud. Recently, Kathy was named by Tax Analysts as one of the top 10 people “who left their mark on policy, practice and administration in 2014”.
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Ginny Buckner Kissling
Ginny Buckner Kissling is president of US operations and prin - cipal in Ryan’s Dallas office where she leads 1,500 employees across the United States, as well as 230 employees in Hyderabad, India. Ginny is responsible for all aspects of service delivery operations within the United States and India, which includes 19 practices and 81 sub-practices, quality assurance, and business development. She is a technical expert specialising Ryan in providing transaction tax services, including multistate audit defence representation, research, reverse audits, and transaction Three Galleria Tower 13155 Noel Road tax education on a national basis. In addition to transaction tax Suite 100 services, Ginny is an industry-recognised expert in the Texas Dallas, TX 75240-5090 Enterprise Zone Program, which is a business incentive for cap - US ital investment and new or retained jobs, and other state and Tel: +1 972 934 0022 local incentives in Texas. Fax: +1 972 725 0479 Email: [email protected] Ginny lectures on various tax topics for Ryan clients. Website: www.ryan.com Additionally, she has appeared as a speaker for the Council on State Taxation, Institute for Professionals in Taxation, Interstate Tax Corporation, National Business Institute, and New York University’s Institute on State and Local Taxation. She has writ - ten articles for the New York University, Institute on State and Local Taxation and for the Institute for Professionals in Taxation. She received the 2010 Dallas Business Journal ’s 40 Under Forty Award and was a 2014 Women in Business honoree. Ginny has served as executive director (1996–2000) and secre - tary/treasurer (1993–1995) for the Dallas/Fort Worth State Tax Association and held sev - eral leadership roles with the Institute for Professionals in Taxation, including chairing the Sales and Use Tax Symposium, chairing the Membership Promotion and Public Relations committee, and serving as a committee member for its annual conference. Additionally, Ginny served as chair, Development Committee (2009-2011); chair-elect, Executive Committee (2012); chair, Executive Committee (2013); and Executive Committee board member (2014) of the Executive Committee of the University of North Texas Department of Accounting Advisory Board. She serves on the advisory board for New York University’s Institute on State and Local Taxation, and belongs to the North Prestonwood chapter of the National Charity League. Ginny holds an MSc degree in accounting with an emphasis in taxation and a BSc degree in accounting, both from the University of North Texas.
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Helen Lemmon
Helen Lemmon is the principal-in-charge of Ryan’s Pittsburgh office where she is responsible for quality service delivery of tax services to multinational companies. She also served as Ryan’s practice leader for the US credits and incentives practice. Previously, Helen was an office managing partner, regional part - ner-in-charge of state and local tax (SALT) services, partner-in- charge of US credits and incentives services, and a location Ryan leader for SALT at a national accounting firm. Before that, Helen was a SALT manager for a Fortune 500 company. One PPG Place Suite 2810 Helen has served as a board member and co-chair for the Pittsburgh, PA 15222 Existing Business Committee of the Pittsburgh Regional US Alliance, the boards of Girls Hope and Winchester Thurston Tel: +1 412 535 4400 School, the board of Robert Morris University, the board and Fax: +1 412 535 4403 executive committee of the Pittsburgh Symphony. Email: [email protected] Helen has lectured on business incentives and credits, Website: www.ryan.com appearing as a speaker for various clients and organisations, including the Council on State Taxation; the Institute for Professionals in Taxation; New York University, Institute on State and Local Taxation; Tax Executives Institute; and the Texas Taxpayers and Research Association. She previously co-hosted a radio programme, The Business Journal, discussing relevant business topics with a focus on economic impact. Helen was also featured on Our Region’s Business, a business affairs programme co-produced by the Allegheny Conference and Cox Broadcasting that provides business news, information, and commentary related to the Pittsburgh region. Helen has written articles for The Tax Executive, Pittsburgh Business Times, Construction Accounting and Taxation, and Journal of Multistate Taxation . She was the winner of the 2010 Top 25 Women in Business Awards by the Pittsburgh Business Times and is a certified member (CMI) of the Institute for Professionals in Taxation. She holds a bachelor of science degree from Indiana University of Pennsylvania.
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Jane Wells May
Jane Wells May is a partner in the law firm of McDermott Will & Emery and is based in the firm’s Chicago office. Jane heads the firm’s State & Local Tax practice group and serves on the firm’s Management Committee. She focuses her practice on state and local tax matters. Jane represents businesses in connection with state and local tax controversies at the audit, administrative and judicial levels McDermott Will & Emery around the United States. Her clients include companies in manufacturing, retailing, food and beverage, pharmaceuticals, 227 West Monroe Street Chicago , IL 60606-5096 automotive, healthcare, energy, technology and insurance US industries. Jane serves as national coordinating counsel to a number of Fortune 500 companies, providing strategic counsel Tel: +1 312 984 2115 Fax: +1 312 984 7700 and audit defence on all their state and local tax matters across Email: [email protected] the country, including litigating in administrative and judicial Website: www.mwe.com venues when necessary. She has successfully litigated state and local tax matters raising a variety of statutory and constitution - al issues. Jane has defended numerous internet sellers in several states against cases brought under state whistleblower statutes, including the Illinois False Claims Act, alleging fraudulent fail - ures to collect and remit use tax. Jane also advises business clients on tax planning matters and represents athletes and entertainers in connection with employment contract issues. A member of the Director’s Advisory Group for the State of Illinois, Jane is a regular speaker at seminars on state and local tax issues. She is a member of the Chicago Bar Association’s State and Local Tax committee and is admitted to practice in Illinois. Jane has been named a Leading Tax Lawyer in the Legal 500 United States, which states that she has “built a noteworthy local and state taxes practice”. She has also been ranked by Chambers USA since 2008, which notes that she “is full of energy and brings a wealth of experience to the work”. Furthermore, say the Chambers rankings, Jane is “excellent from an advocacy point of view” and is considered a “strategic leader” in state and local tax. She has also been regularly named an Illinois Super Lawyer in the tax area by Law & Politics . Jane received her bachelor’s degree (with honours) from Wittenberg University in 1980 and her JD from the Vanderbilt University School of Law in 1986. At Vanderbilt University, Jane was senior articles editor of the Vanderbilt Law Review and a member of Order of the Coif and Moot Court Board.
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Michele McGuire
Michele is the principal in charge of Deloitte Tax’s (US) Customs and Global Trade practice and sits on Deloitte’s Global Indirect Tax Executive Committee which manages a net - work of more than 550 import and export specialists from around the world. Michele has more than 25 years of experience advising clients on numerous global trade matters. Michele specialises in Deloitte Tax the operational side of global trade, helping clients assess and design their global trade management process including auto - 111 South Wacker Drive Chicago, IL 60606 mated solutions. Michele’s deep regulatory and operational US background allows her to apply real life practical solutions for her clients, which are not only compliant with a myriad of glob - Tel: +1 312 486 9845 Fax: +1 312 247 9845 al trade regulations but are also efficient and effective. Mobile: +1 312 927 9845 Specifically, Michele has extensive experience in advising Email: [email protected] Fortune 500 companies in numerous global trade management areas including; global regulatory import and export require - ments, first sale for export planning and implementation; opti - misation of and compliance in their use of international trade agreements; customs related party valuation compliance and strategy; global import and export risk assessments; designing and implementing global import and export compliance programmes and rollout of automat - ed export and import systems and training. Before joining Deloitte Tax, Michele was a partner in Andersen’s US international trade and customs group. Before Andersen, Michele spent five years as an associate attorney at a Chicago-based law firm where she advised clients on numerous customs and international trade related matters. She also worked as a visiting attorney in the international litigation department of a large London law firm. Michele earned her bachelor of science degree from Indiana University, juris doctor degree from the John Marshall Law School, and master’s of law in international transactions from the McGeorge School of Law in Salzburg, Austria and Sacramento, California. Additionally, Michele is a US licensed customs broker.
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Larissa Neumann
Larissa Neumann focuses her practice on US tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on acquisitions, restructurings and transfer pricing issues. She has successfully represented clients in federal tax controversies at the audit level, in appeals and in court.
Larissa appears as a rising star in Euromoney’s Guide to the Fenwick & West World’s Leading Tax Advisers. Euromoney selected Larissa for inclusion in the Americas Women in Business Law Awards Silicon Valley Center 801 California Street shortlist for Best in Tax Dispute Resolution in 2014 and Rising Mountain View, CA 94041 Star: Tax, in 2015. US Larissa frequently speaks at conferences for professional tax Tel: +1 650 335 7253 groups, including the Tax Executives Institute, International Email: [email protected] Fiscal Association, Pacific Rim Tax Institute, Bloomberg, and Website: www.fenwick.com the American Bar Association. She is the ABA International Law Tax Liaison. Larissa has published several articles, including recently: • US Tax Overview , Euromoney’s LMG Rising Stars 2015 • US transfer pricing litigation update, International Tax Review (March 2015) • Areas of TP Scrutiny in a pre- and post-BEPS World, International Tax Review (February 2015) • US International Tax Developments , The Euromoney Corporate Tax Handbook 2015 • US Transfer Pricing Developments , International Tax Review (2014) • US Tax Developments , International Tax Review (December/January 2013) • US International Tax Developments , The Euromoney Corporate Handbook 2012 • Character and Source of Income from Internet Business Activities , The Contemporary Tax Journal (July 2011) • The Application of the Branch Rule to Partnerships , International Tax Journal (July – August 2010) Fenwick has one of the world’s top tax planning and tax transactional practices, according to International Tax Review (2014 and 2015) and is first tier in tax, according to World Tax 2015. International Tax Review gave Fenwick its San Francisco Tax Firm of the Year award a total of six times and its US Tax Litigation Firm award a total of three times. International Tax Review also named Fenwick its Americas M&A Tax Firm of the Year in 2012.
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Jean Pawlow
Jean A Pawlow is a partner in the global law firm of McDermott Will & Emery. She serves on the firm’s Management Committee and Finance Committee and she is co-chair of the firm’s tax controversy practice. US News and Best Lawyers named McDermott ‘Tax Litigation Firm of the Year’ for 2014. Jean has been involved in representing businesses and indi - viduals on significant tax controversy matters for 25 years. McDermott Will & Emery Substantive issues in dispute have included transfer pricing issues under Code section 482, tax advantaged transactions, tax 500 North Capitol Street, NW Washington, DC 20001 accounting issues, insurance tax matters, the tax treatment of US financial instruments, foreign tax credit and research credit 275 Middlefield Road, Suite 100 issues, leveraged leases, credit card interchange and original Menlo Park, CA 94025 US issue discount (OID), excise taxes, reasonable compensation, estate and gift tax issues, and charitable contribution deduc - Tel: +1 202 756 8297 Tel: +1 650 815 7558 (CA) tions. She also advises on California and District of Columbia Fax: +1 202 756 8087 state tax controversies. Email: [email protected] Jean has litigated cases before the US Tax Court, the Court Website: www.mwe.com of Federal Claims, US district courts, US Courts of Appeal and the Supreme Court. She also has extensive experience with IRS alternative dispute resolution (ADR) procedures, including fast track settlement, rapid appeals, post-appeals mediation, pre-fil - ing agreements and CAP audits. She frequently represents clients who are being audited by the IRS Global High Wealth Industry Group. Jean is a frequent writer and speaker on tax controversy matters and has appeared on CBS and CNBC. She is the contributing editor of a 2015 book on global tax controversies. The Legal 500 has named Jean a leading lawyer every year since 2009, and quoted a client who described her as “a pleasure to work with, clever, an excellent advocate, personable and pos - sessed of an instinctive business understanding”. She has been nationally ranked as a leading tax litigation lawyer in every edition of Chambers USA since 2010 as “one of the preeminent tax lawyers in the US” and noted for her “dedication to client service”. Jean was also listed in Best Lawyers in America in 2012, 2013 and 2014. She serves on the Tax Committee for the US Court of Federal Claims Advisory Council and is a fellow of the American College of Tax Counsel. Jean received her bachelor’s degree (with high honours) from University of California at Berkeley in 1985 and her JD ( cum laude ) from Harvard Law School in 1988. Her representative docketed cases include: Dine Equity v Commissioner ; DiMare v Commissioner ; Estate of Stanton v Commissioner ; John Hancock Life Insurance v Commissioner ; Siemens v Office of Tax & Revenue ; Novitsky v Siemens ; Ambassador Blankenship v Commissioner ; USAA v United States and USAA v Commissioner ; Goodrich v United States ; Boeing v United States ; Wal-Mart Stores v Commissioner ; and Texas Instruments v Commissioner .
9W1 O|M wENw wI.Nin TtAeXrn LaEtiAoDnaElRtaS xreview.com www.internaWtioOnMaEltNax IrNev TiAewX. cLoEmAD |E R9S1 US Darcy Alamuddin Deloitte Lauren Angelili Cravath Swaine & Moore Barbara Angus EY Mary Bennett Baker & McKenzie Kim Blanchard Weil Gotshal & Manges Kim Boylan White & Case Linda Carlisle Miller & Chevalier Loren Chumley KPMG Erin Collins KPMG Manal Corwin KPMG Carol Dunahoo Baker & McKenzie Michelle Ferreira Greenberg Traurig Kathleen Ferrell Davis Polk & Wardwell Miriam Fisher Latham & Watkins Patricia Gimbel Lewis Caplin & Drysdale Michiko Hamada BDO Jill-Marie Harding Alvarez & Marsal, Taxand Geralyn Hurd Crowe Horwath Cynthia (Cindy) Hustad Deloitte
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1 Crown Office Row, 79 Deloitte, 4, 6, 7, 8, 9, 10, 12, 15, 16, 17, 39 Essex Chambers, 78, 79 24, 27, 35, 38, 39, 40, 41, 47, 50, 55, ADB, 68 56, 57, 58, 61, 62, 64, 68, 69, 70, 78, Advicero/Green Real Accounting, 55 79, 89, 92, 93, 94 AFA OOD, 14 Dentons, 15, 24, 55, 58, 70 Allen & Overy, 12, 78 Derraik & Menezes Advogados, 14 Alvarez & Marsal Taxand, 92 Desai Haribhakti & Co. Chartered Arntzen de Besche, 55 Accountants, 34 Arsene – Taxand, 24 Devereux chambers, 79 Avocats Baltus, 12 DLA Piper, 38, 55, 70, 85 Baker & McKenzie, 12, 17, 21, 24, 27, 38, Drew and Napier, 61 39, 46, 50, 58, 62, 70, 92, 93, 94 Du-Baladad, 55 Baker & McKenzie.Wong & Leow, 61 Duff & Phelps, 94 BDO, 92 Eduardo Paz Ferreira, 56 BDO Tax, 39 Erdikler - Taxand, 70 Bennett Jones, 15, 16 Eurofast Taxand, 18, 20 Bird & Bird, 23 EY, 10, 12, 15, 17, 21, 27, 38, 50, 55, 56, Blake Cassels & Graydon, 15, 16 57, 58, 61, 68, 78, 79, 92 bln palao abogados, 62 Fenwick & West, 80, 84, 90 BMR & Associates, 31, 32, 33 FIDAL International/KPMG, 24 Borenius, 21 Flick Gocke Schaumberg, 27 Bowman Gilfillan, 61 Freshfields Bruckhaus Deringer, 78 Brewer Morris, 3 Garrigues – Taxand, 57, 62 BTOC Tax, 56 Gillioz Dorsaz & Associes, 68 Buchanan Ingersoll & Rooney, 93 Godoy & Hoyos, 17 Camilleri Preziosi, 42, 45 Goodmans, 16 Caplin & Drysdale, 92 Grant Thornton, 28, 65, 71, 75, 76 Castro Barros Sobral Gomes, 14 Gray’s Inn Tax Chambers, 79 Cleary Gottlieb Steen & Hamilton, 24, 39, Greenberg Traurig, 92, 93, 94 93 Group 621 Advocates, 61 Clifford Chance, 27, 73, 78 Herbert Smith Freehills, 78 CMS Bureau Francis Lefebvre, 24 HLB Proxy, 21 CMS Rui Pena & Arnaut, 56 Hogan Lovells, 38, 78 Cooley, 93 Hulgaard Advokater, 21 Cravath Swaine & Moore, 92 Independent, 55, 56, 57 Crido – Taxand, 56 Jun He, 16 Crowe Horwath, 92 Jurimex, 70 Cuatrecasas Goncalves Pereira, 56, 62 Khaitan & Co, 29 Davis Polk & Wardwell, 92, 93 King & Spalding, 24 Kocian Solc Balastik (KSB), 21
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KPMG, 10, 13, 15, 16, 17, 27, 35, 39, 50, Rimon Law, 93 51, 57, 58, 59, 60, 61, 62, 66, 67, 70, Rogerio Fernandes Ferreira & Associados 78, 79, 92, 93 (RFF), 57 KPMG Alpen-Treuhand, 11 Ronne & Lundgen, 21 KPMG Huset / KPMG Law Advokatfirma, Ryan, 5, 49, 86, 87 53 Saffery Champness, 78 KPMG Law Advokatfirma, 54 Shearn Delamore, 41 Küffner Maunz Langer Zugmaier, 25 Simpson & Marwick, 78 Laga, 12 Skadden Arps Slate Meagher & Flom, 93 Latham & Watkins, 92 Skeppsbron Skatt - Taxand Sweden, 66 Lavrynovych & Partners, 70 Slaughter and May, 79 Law Square, 12 SR Dinodia & Co Chartered Accountants, Lee and Li, 68 30 Lexcom, 24 SSW (Spaczynski Szczepaniak i Wspolnicy), Liedekerke Wolters Waelbroeck, 12 55 Loyens & Loeff, 12, 50, 68 Steptoe & Johnson, 94 Machado Associados, 14 Studio Camagni e Associati, 38 Machado Meyer, 14 Studio Fantozzi & Associati, 39 Matheson, 38 Svalner Skatt & Transaktion, 63 Mattos Filho, 14 Tax Advisors & Associates, 68 Mayer Brown, 12, 22 Tax Link Baltic, 39 Mazars, 78 TaxHouse Taxand Romania, 57 McCarthy Tetrault, 15, 16 Taylor Wessing, 78 McDermott Will & Emery, 83, 88, 91 Thompson & Knight, 93 MDDP, 55, 56 Torys, 15 Miller & Chevalier, 92, 93, 94 TozziniFreire Advogados, 14 Minter Ellison, 10 Tremonti Vitali Romagnoli Piccardi e MNP, 15, 16 Associati, 38 Morrison & Foerster, 93 Trench Rossi e Watanabe – in association Norton Rose Fulbright, 78 with Baker & McKenzie, 14 On Your Side, 61 True Partners Consulting, 82 Osborne Clarke, 72, 74 Uría Menéndez, 56, 57 Osler Hoskin & Harcourt, 15, 16 Valoris Avocats, 24 Paczuski & Taudul Tax Advisors, 55 Varul, 39 Pinheiro Neto Advogados, 14 Vieira de Almeida, 56, 57 Pinsent Masons, 77 Wachtell Lipton Rosen & Katz, 94 Plesner, 21 Weil Gotshal & Manges, 92 PLMJ, 56 White & Case, 58, 92 Proskauer Rose, 93 William Fry Tax Advisors Taxand Ireland, PwC, 10, 12, 15, 16, 17, 35, 38, 48, 50, 36, 37 56, 57, 58, 61, 66, 68, 78, 93, 94 Willkie Farr & Gallagher, 24 PwC/Landwell, 24 Wong & Partners (Baker & McKenzie Quinones Cruz, 17 member firm), 41 RG Manabat (KPMG), 55 WTS, 26
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