Australia

PwC

One International Towers Sydney

Watermans Quay

Barangaroo NSW 2000

Australia

Tel: +61 2 8266 6858

Email: michael.bersten@pwc.com

Website: pwc.com/taxcontroversy

Michael Bersten has been a senior partner within the PwC Australia tax controversy and dispute resolution (TCDR) practice since founding the practice in 2004. The practice now comprises 30 professionals and eight partners.

Michael is a member of the TCDR global leadership team and leads the PwC TCDR practice in the Asia Pacific region. He also leads PwC's global general anti-avoidance rules team and is chairman of the PwC Australia tax policy panel. Michael is a member of the firm's global tax policy core group and is active in the BEPS debate.

As a Big 4 firm partner since 2001, Michael has acted in many of the major tax controversies in Australia, predominantly in the publicly listed and global business sectors. His work ranges from legal services in relation to reviews, audits, disputes and litigation to strategic advice on tax risk management and legal advice on major transactions, especially on Part IVA.

Michael has extensive experience assisting clients in the assessment and management of their tax controversies (audits, disputes and litigation) and tax risk in Australia. He consults globally, particularly in Asia.

As the former Australian Taxation Office (ATO) deputy chief tax counsel and deputy Australian government solicitor, Michael has a strong understanding of ATO policy and practice, and experience at assisting clients achieve the best possible outcomes in negotiations with the ATO.

Deloitte Australia

225 George Street

Sydney, NSW 2000

Australia

Tel: +61 2 9322 7770

Email: ficraig@deloitte.com.au

Website: www.deloitte.com

Fiona Craig, Deloitte Australia, leads Deloitte's Asia Pacific transfer pricing practice and specialises in dispute resolution of transfer pricing matters. Fiona is a qualified arbitrator and trained negotiator.

Fiona has enjoyed 25 years with Deloitte in Australia and the UK, including almost 20 years dedicated to transfer pricing. She is extremely well connected through the Deloitte network and ensures the best controversy skills, experience and insights are brought to Deloitte clients.

Fiona is currently assisting many multinational corporations address challenges raised by tax authorities, particularly challenges stemming from new legislation in Australia and the recent increased scrutiny of governments on the tax arrangements of multinationals. Fiona's experience in defending transfer pricing maters through negotiations with revenue authorities both in advance pricing agreements and audit matters has resulted in successful outcomes for some of the largest global players in the technology, pharmaceutical and energy sectors.

Fiona increasingly advises on global transfer pricing controversy management strategies as a result of the increased reporting and sharing of financial and tax information for multinationals.

Deloitte Australia

225 George Street

Sydney NSW 2001

Australia

Tel: +61 (0) 421 050391

Email: bradedwards@deloitte.com.au

Website: www.deloitte.com

Bradley Edwards, Deloitte Australia, joined the tax transfer pricing team in March 2015. Before joining Deloitte, Brad was an assistant deputy commissioner in the Australian Taxation Office (ATO) with 31 years of tax administration experience. Brad has more than 17 years of international tax experience specialising in transfer pricing and was one of the ATO's competent authorities involved in negotiating mutual agreement procedure (MAP) double tax relief and advance pricing agreement (APA) cases. Brad was the ATO's Joint International Tax Shelter Information Center (JITSIC) delegate located in London from September 2011 to January 2013 and represented the ATO at the OECD on Working Party 6. This experience has enabled Brad to develop a strong global revenue administration network. On Brad's return to Australia in 2013, he took on a leadership role in the ATO's energy and resources (E&R) industry sector and was responsible for developing the ATO's 2014/15 E&R risk mitigation strategy. In 2014 he took on a broader leadership role in public groups and international (PGI) and was on the PGI executive leadership team with broad responsibility for identification of and mitigation of all risk in the ATO's large market sector. As an operational leader in the ATO, he was involved in resolving many disputes the ATO had with taxpayers in the large market.

Since joining Deloitte Australia's transfer pricing team, Brad has been providing advice to multinational groups on tax risks and how best to obtain certainty in the current BEPS environment.

Brad brings ATO insights into strategic dispute considerations for clients. These insights can be beneficial to early dispute resolution and for maintaining or building relationships with the ATO. Brad provides assistance with ATO engagements both strategically and operationally. He has strong negotiation skills that have proven helpful to clients in addressing voluntary disclosures, transfer pricing audit and APA discussions, as well as penalty and interest remission considerations.

Deloitte Australia

Level 14, 550 Bourke Street

Melbourne Victoria 3000

Australia

Tel: +61 3 9671 7370

Mobile: +61 404 049 545

Fax: +61 3 9691 8442

Email: jfabijancic@deloitte.com.au

Website: www.deloitte.com

James Fabijancic, Deloitte Australia, is the national leader of the Australian legal practice specialising in the areas of tax controversy and litigation services. James has more than 15 years of experience assisting clients in complex dispute matters against the Australian revenue authorities. He has acted for a number of high-profile multinationals, major corporates and high-wealth groups in relation to rulings, reviews, audits, settlements and has instructed in numerous Federal Court and Tribunal matters, working with Australia's leading tax barristers.

He has been involved in a range of diverse matters relating to international tax, transfer pricing, research and development tax concession entitlements, withholding tax, corporate tax issues and the application of the general anti-avoidance rule (GAAR), including appearance at the GAAR panel. James works with his clients through the entire dispute life cycle from transaction implementation with "audit readiness" support, defence strategy and planning and Part IVC and declaratory relief applications.

James holds a BCom/LLB from the University of Melbourne where he is now a member of the Law School's tax group advisory board, is a member of the Tax Institute and Law Institute of Australia and was part of the working group in relation to the recent Australian foreign investment reforms.

Deloitte Australia

550 Bourke

Melbourne 3000

Australia

Tel: +61 (03) 9671 7508

Mobile +61 0414 942 589

Fax : +61 (03) 9691 8175

Email: grjanes@deloitte.com.au

Website: www.deloitte.com

Greg Janes, Deloitte Australia, is a senior corporate tax partner with more than 35 years of experience in income tax. Greg has achieved national prominence as an adviser in relation to complex tax controversy matters. He is recognised by International Tax Review as one of Australia's leading practitioners in tax controversy matters.

He has specialised in tax controversy for more than 10 years at Deloitte where he has successfully acted for a range of high-profile clients in respect of Australian Taxation Office (ATO) audit activity and formal taxation disputes.

Before joining Deloitte, Greg held numerous key leadership roles within the ATO, including assistant commissioner, large business and international segment, a role which he held for seven years. He has also worked as senior tax counsel, group head for the appeals and review programme, and leader of the ATO's complex audit programme in Victoria.

PwC

Freshwater Place

2 Southbank Boulevard

Southbank VIC 3006

Australia

Tel: +61 3 8603 0363

Mobile: +61 4 0199 4371

Email: ashley.king@au.pwc.com

Website: pwc.com/taxcontroversy

Ashley King is a tax controversy partner with PwC and has 30 years' tax experience, including 20 years with the Australian Taxation Office (ATO). Ashley has achieved national prominence and is regularly called upon by the media and the tax profession for his views on tax controversy matters in Australia. Ashley was one of the youngest tax officers to have been promoted to the position of assistant commissioner in the ATO in 2001, and was senior assistant commissioner (large business and international division) when he left the ATO to join PwC in 2007.

Ashley specialises in advising clients in different industries on the strategic management of ATO reviews, audits and disputes, including negotiating settlements and advising on tax audit defence. Ashley has a deep knowledge of ATO policies and decisions impacting tax controversy including settlements, rulings, audits, access visits, information and assessment powers and the general anti-avoidance rule (GAAR), and has deep relationships across the ATO. Ashley brings unique insight to tax issues and has acted as witness and expert witness in numerous tax matters, for both the ATO and clients.

By combining his extensive ATO experience and insight, Ashley has been instrumental in negotiating numerous large tax audit settlements in the banking, investment, mining, oil and gas industries, including disputes in relation to cross-border finance, investment structures, transfer pricing and anti-avoidance provisions. He has also successfully assisted many clients in obtaining positive ATO rulings.

Ashley graduated from the University of New South Wales with a master's degree in tax law and from the University of Canberra with bachelor degrees in commerce and accounting. Ashley is a registered tax agent and chartered tax adviser, and represents the Australia and New Zealand Chartered Accountants on the ATO's dispute resolution committee. Ashley is also a member of the Australian Tax Institute's legal and dispute resolution committee.

Deloitte Australia

Tower 2 Brookfield Place

123 St Georges Terrace

Perth WA 6000

Australia

Tel: +61 8 9365 7960

Fax: +61 8 9365 7001

Email: joleek@deloitte.com.au

Website: www.deloitte.com

Jonathon Leek, Deloitte Australia, is a partner in the legal team in Perth. He is a barrister and solicitor with more than 20 years of experience in Sydney and Perth, including 17 years as a partner in leading law firms and as a barrister at the independent bar.

Jonathon provides direct and indirect tax advice to clients ranging from large Australian and multinational corporations on the full range of corporate, commercial and financial transactions and projects. He has extensive knowledge and experience of obtaining tax rulings, managing tax audits and risk reviews, objecting against assessments, alternative dispute resolution, negotiating settlements, and appealing to courts and tribunals. His clients operate in a broad range of industries including energy, resources, real estate, infrastructure, financial services, media, communications and technology.

Jonathon is an honorary fellow of the University of Western Australia where he lectures in post-graduate tax law (tax dispute resolution and advanced corporate tax). He is a member of the Tax Institute's Western Australian state council and chair of its WA technical committee. He has been recognised as one of Australia's leading tax lawyers in a number of client and peer surveys over many years.

Jonathon holds Bachelor of Economics and Bachelor of Laws degrees from Macquarie University and a Master of Laws degree from the University of Sydney. He also holds post-graduate qualifications in applied finance and international business law and is a chartered tax adviser.

Deloitte Australia

225 George Street

Sydney NSW 2000

Australia

Tel: +61 2 9322 5854

Email: clittle@deloitte.com.au

Website: www.deloitte.com

Colin Little, Deloitte Australia, is the New South Wales leader of the legal practice, specialising in tax controversy and litigation services.

Colin has more than 20 years of experience in the taxation field and for the past 12 years Colin has acted for both public and private sector clients resolving complex taxation disputes, ranging from audit negotiation and resolution, alternative dispute resolution through to litigation in the Federal, Supreme and High Court.

Colin initially spent six years as a senior solicitor for the Australian Government Solicitor, representing the Commonwealth in a range of high profile Federal, Supreme and High Court matters. Moving to private practice, Colin has successfully conducted litigation for clients on a wide range of taxes including income tax, corporate tax, stamp duty, research and development and GST matters, with expertise and experience in Administrative Appeals Tribunal, Supreme Court and Federal Court matters.

Colin also has an impressive and successful record in utilising his legal and tax skills to assist multinationals, large private groups and high-net-worth individuals navigate and settle large-scale audits with the ATO, with particular focus and expertise on transfer pricing R&D and Part IVA matters.

Colin has a Masters of Laws from the University of Sydney and is admitted to practice as a solicitor in the New South Wales Supreme and High Court.

PwC

Riverside Quay

2 Riverside Quay

Southbank Vic 3006

Australia

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

Email: paul.mccartin@pwc.com

Website: pwc.com/taxcontroversy

Paul McCartin is a partner in PwC Australia's tax controversy and dispute resolution team.

Paul has 20 years of tax experience and joined PwC after 12 years working at senior levels of the Australian Taxation Office (ATO), with senior roles including ATO assistant commissioner and authorised competent authority.

Paul's ATO roles included assistant commissioner, public groups and international (audit); Australian delegate on the Joint International Tax Shelter Information Centre (JITSIC) based in Washington DC; senior technical adviser (Office of the Chief Tax Counsel); and providing tax policy advice to the Australian Federal Treasury. These diverse roles have left Paul with relationships with more than 70 ATO assistant commissioners.

Paul now specialises in assisting clients with ATO engagement and tax dispute resolution and has achieved outstanding results for multinational listed companies, large private companies and high-net-worth individual clients on a range of complex and significant tax disputes. In recent times, Paul has acted on behalf of clients to obtain agreement on technical positions with the ATO or resolve disputes on topics including international related party financing, the potential application of Australia's general anti-avoidance rule (GAAR) and the application of Australia's transfer pricing provisions.

In an environment of increasing uncertainty, Paul's ATO early engagement strategies and dispute resolution skills are increasingly sought by clients.

PwC

One International Towers Sydney

Watermans Quay

Barangaroo NSW 2000

Australia

Tel: +61 (02) 8266 5640

Email: paul.mcnab@pwc.com

Website: pwc.com/taxcontroversy

Paul McNab is a solicitor and senior tax partner at PwC Australia and is a member of the tax controversy and dispute resolution (TCDR) practice. He has more than 30 years of taxation experience, including eight years in the Australian Taxation Office (ATO) compliance branch, where his work included a number of high-profile investigations and the management of the resulting litigation and prosecutions. Over the past 20 years in private practice he has had extensive experience in assisting clients understand the tax risks they face and manage their interactions with the ATO. His work has included reviews of significant transactions, assistance with the assessment and disclosure of tax risk to statutory auditors, management of audits by the ATO and the negotiation of settlements and preparation for and conduct of litigation.

Paul holds an LLB from the Queensland University of Technology and an LLM, with honours, from Sydney Univer sity. He is a chartered tax adviser and is entered on the roll of the High Court of Australia. He has conducted cases in the Administrative Appeals Tribunal, the Federal Court of Australia and the High Court.

He has a strong background in working with companies whose value is significantly driven by intangible assets. He has worked on a number of disputes involving the interaction of Australia's transfer pricing rules and the general anti-avoidance rule (GAAR). Over the past year, he has worked with many global groups (especially US multinationals) on their responses to the Australian government's BEPS initiatives. He has published extensively on (and managed in practice) tax issues in relation to intangible asset-based business models and the management of related transfer pricing disputes.

PwC

One International Towers Sydney

Watermans Quay Barangaroo NSW 2000

Australia

Direct (Sydney office): +612 8266 9156

Mobile: +61413 111 161

Email: eddy.moussa@au.pwc.com

Website: pwc.com/taxcontroversy

Eddy Moussa is a practising tax lawyer with more than 18 years of experience in providing legal advice on taxation matters such as financing, international and domestic restructuring and merger and acquisition transactions.

Eddy is a partner in the PwC tax controversy team. He provides legal advice to mainly multinational clients on taxation matters (including anti-avoidance), and supports clients in resolving disputes with the Australian Taxation Office. This work involves assisting clients under audit or investigation. Eddy also leads alternative dispute resolution processes, briefs counsel and provides anti-avoidance opinions.

Eddy is the deputy chair of the Tax Institute of Australia's NSW State Council. He is also a member of the NSW professional development committee and has published papers on taxation anti-avoidance.

Eddy has bachelor degrees in business and law, and a master's degree in tax. He is a qualified solicitor of the Supreme Court of NSW, practitioner of the Federal and High Court of Australia, a registered tax agent in Australia, and a CTA of the Tax Institute of Australia.

Hall & Wilcox

Level 11, Rialto South Tower

525 Collins Street

Melbourne, VIC 3000

Australia

Tel: +61 3 9603 3683

Email: peter.murray@hallandwilcox.com.au

Website: www.hallandwilcox.com.au

Peter Murray is a prominent tax adviser with more than 30 years' experience. He has been listed in The Best Lawyers in Australia in tax law every year since 2013 and is also a recommended tax lawyer in Australia and a leading tax lawyer in Victoria in Doyle's Guide to the Australian Legal Profession.

Peter leads the Hall & Wilcox tax controversy and dispute resolution practice, which comprises of five partners and 12 professionals. Formerly, Peter was a senior partner of KPMG and a founding partner of KPMG Law. Peter is also a past president of The Tax Institute, Australia's premier tax industry body. Peter is active in tax policy development and participates in tax policy consultation with the Treasury and the Australia Taxation Office (ATO).

Peter is an external member of the ATO's general anti-avoidance rule (GAAR) panel, which advises the ATO on the application of the GAAR to issues arising out of tax audits, investigations and private ruling requests from taxpayers.

He is also a fellow of the Institute of Chartered Accountants, a chartered tax adviser and on the roll of the High Court of Australia.

Peter has extensive experience acting for public and privately owned corporate groups (both listed and internationally owned, and high-net-worth families) in the management of risk reviews, audits, disputes and litigation. Peter also advises on major transactions, including in relation to the potential application of Part IVA.

His specific areas of specialisation include assisting clients in the assessment and management of their tax disputes and providing advice on corporate group reorganisations, mergers and acquisitions, including domestic, inbound and outbound investment, thin capitalisation and debt/equity, capital/revenue characterisations, tax consolidation and repatriation of profits.

Peter's clients include a range of multinational, public and private entities, professional services firms and high-net worth family groups across a broad range of industries.

PwC

2 Southbank Boulevard

Southbank

Melbourne 3006

Australia

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

Email: simon.rooke@au.pwc.com

Website: pwc.com/taxcontroversy

Simon Rooke is a legal partner in PwC's Melbourne tax controversy practice.

Simon specialises in working with clients to resolve complex and sometimes intense disputes with the Australian Taxation Office (ATO).

Simon has 20 years of taxation experience, including 12 years in international tax and M&A tax, which have led to several significant ATO investigations, up to and including litigation. Simon has been recognised in 2009 and 2011 as one of Australia's leading tax advisers in International Tax Review's guide to the world's leading tax firms.

Simon has extensive experience in assisting clients manage ATO disputes, including ATO risk reviews, ATO audits, settlement negotiations, alternative dispute resolution and litigation. Simon's approach is to take a respectful and educative approach to ATO investigations, while rigorously protecting a client's rights (both at law and under ATO practice and policy).

Simon's experience has also ranged from navigating through the increasingly aggressive ATO approach to information gathering, to seeking private binding rulings on contentious tax matters, to assisting companies with 'ATO readiness' during initial public offerings, to litigation against the ATO when other avenues of dispute resolution are exhausted.

Simon holds bachelor degrees in commerce and law. He is a chartered accountant in Australia and New Zealand, a chartered tax adviser, holds a graduate diploma in applied finance and a graduate diploma in legal practice. Simon is also a member of the Law Institute of Victoria and a member of the Law Council of Australia's business law section.

PwC

One International Towers Sydney

Watermans Quay

Barangaroo NSW 2000

Australia

Tel: +61 2 8266 0197

Email: judy.sullivan@pwc.com

Website: pwc.com/taxcontroversy

Judy Sullivan is a legal partner – tax controversy – and the national leader for tax litigation and alternative dispute resolution (ADR) at PwC.

Judy holds a BEc/LLB from the Australian National University and LLM from Sydney University. She is a member of the advisory panel to the Board of Taxation and a member of the Australian Taxation Office (ATO) dispute resolution working group. She is also a chartered tax adviser (The Taxation Institute) and on the High Court's roll of legal practitioners.

Judy is a leading tax lawyer and litigator in Australia. She joined PwC in 2013, and was formerly the tax partner leading the Sydney tax disputes practice at top tier law firm King & Wood Mallesons.

For 25 years, Judy has guided multinationals, major corporates and high-net-worth individual clients through tax reviews, audits, negotiations and litigation across all areas of federal and state taxes. She has run or worked on seminal Australian tax cases in the Administrative Appeals Tribunal, Federal Court and High Court, as well as the NSW Supreme Court. She instructs and works with the leaders of Australia's tax bar.

With the ATO's shift to 'real time' engagement with taxpayers, Judy focuses on opportunities to work closely with the ATO and taxpayers to bring them together to achieve early engagement and resolution of disputes through ADR processes including settlement discussions, mediation and early neutral evaluation.

As cross-border transactions and corporate structures are under intense ATO scrutiny, (with significant additional ATO resources now applied to 'taskforces'), multinationals and major corporates must prepare to defend potential disputes in relation to their structures, transactions and pricing approaches.

Judy has extensive expertise across these topics and other important areas such as resources and private equity.

Judy also has a keen interest in pro bono matters, and has won the New South Wales Law Society Award for her pro bono work representing artists and establishing their practices as businesses for taxation purposes.

Deloitte Australia

Grosvenor Place

225 George Street

Sydney NSW 2000

Australia

Tel: +61 2 8260 4539

Email: chrisjthomas@deloitte.com.au

Website: www.deloitte.com

Christopher Thomas, Deloitte Australia, is an accomplished transfer pricing specialist with a proven track record in Australia, Asia, Europe, and North America. Chris was the Australian competent authority for 18 years and negotiated advance pricing agreements (APAs) and mutual agreements with a wide range of countries over that period. He was a key player in the development and implementation of Australia's transfer pricing compliance and bilateral dispute programmes.

He led bilateral negotiations and was responsible for the strategic management of the Australian Taxation Office's transfer pricing risk and compliance priorities internationally through forums such as the OECD, the Pacific Association of Tax Administrators (PATA) and the Study Group for Asian Tax Administrations (SGATAR).

Since joining the private sector, he has demonstrated his commitment to client service and has built up a strong profile within the Australian tax market, with a focus on controversy management.

He has been able to add value to his clients in managing their transfer pricing risk profile as they negotiate reviews and disputes with the ATO. He has also led several detailed performance/risk evaluations of his client's global operations and supply chains.

Deloitte Australia

Riverside Centre, 123 Eagle St

Brisbane QLD 4000

Australia

Tel: +61 7 3308 7226

Mobile: +61 414 586 241

Email: jvanrhyn@deloitte.com.au

Website: www.deloitte.com

Jacques Van Rhyn, Deloitte Australia, is an international tax and transfer pricing partner, based in Brisbane. He leads the Brisbane tax practice with a focus on energy and resources. Jacques has been in professional practice for 29 years, including 19 years in international tax and transfer pricing practices in Big 4 firms, and 10 years practising as a commercial attorney in an in-house capacity and for his own account.

Jacques has extensive experience advising multinational companies on various cross-border tax and transfer pricing issues, especially in the energy and resources sector, with a specific focus on mining, oil and gas, and related services companies.

Jacques has managed several multi-jurisdictional cross-border projects for multinational groups, from both a compliance perspective (documentation reports) and a planning perspective (for example, business model optimisation, structuring, and the establishment of group transfer pricing policies). Jacques is able to provide a seamless service offering across multiple countries given his strong global networks, knowledge of both the OECD guidelines and in-country transfer pricing rules, and awareness of revenue authorities' attitudes towards the enforcement of these rules in several jurisdictions.

Jacques has been listed in Euromoney/Legal Media Group's Transfer Pricing Expert Guide in both South Africa and Australia, as well as in the guide to the world's leading controversy lawyers. He has published various articles on international tax and transfer pricing, mining and oil and gas, and contributed to various intellectual property publications.

Jacques has led a number of significant transfer pricing cases and audits, and negotiated favourable unilateral and bilateral advance pricing agreements in several jurisdictions. To ensure timely and efficient resolution of disputes for clients, Jacques develops and implements strategies of engagement with revenue authorities to help obtain favourable settlement outcomes in a collaborative manner.

Jacques' experience includes:

• Assisting with M&A and business reorganisations, international structuring, the development of transfer pricing strategies, and obtaining rulings for clients in relation to complex technical areas, including intangibles planning;

• Pricing of LNG, establishment, pricing and defence of marketing and procurement hubs;

• Analysis of entire value chain and pricing of gas at various phase points applying the profit split method;

• Advising on shipping structures, pricing, and contractual terms and conditions;

• Resource rent taxes; and

• Attribution of profits to permanent establishments.

KPMG Australia

Tower Two

727 Collins Street

Melbourne, VIC 3008

Australia

Tel: +61 3 9288 6408

Email: angelawood@kpmg.com.au

Website: www.kpmg.com/au

Angela Wood leads KPMG Law's tax dispute resolution and controversy team in Australia, as well as across the ASPAC region. Angela provides specialist tax dispute management and resolution advice and develops proactive, efficient and early solutions to tax controversy. Angela is also the Victorian state lead for KPMG's tax division.

Angela focusses on proactive, efficient and early resolution of disputes, acting for multinational corporate taxpayers from a wide variety of sectors, including automotive, infrastructure, technology, media and entertainment and mining, achieving successful outcomes at risk review, audit, objection and litigation stages.

Angela assists multinationals to navigate the various taxation dispute resolution processes, preparing for and advising taxpayers in large scale mediations and early neutral evaluations relating to transfer pricing, income tax, the superannuation guarantee charge, general anti-avoidance provisions, including Australia's Part IVA, Multinational Anti-Avoidance Law and the diverted profits tax rules.

Angela specialises in multi-jurisdictional evidence gathering designed to bolster taxpayer positions in reviews, audits and litigation and positively influence outcomes in resolution processes with the Australian Taxation Office.

Angela also has extensive experience acting for Australia's Commissioner of Taxation in relation to his most significant and complex tax litigation and audits.