Malaysia

Level 16, Uptown 1

1 Jalan SS21/58

Petaling Jaya

Selangor, 47400

Malaysia

Tel: +603 7712 5135

Fax: +603 7725 7768

Email: tgoh@deloitte.com

Website: www.deloitte.com

Theresa Goh is the national transfer pricing leader of Deloitte Malaysia. She is based in Kuala Lumpur and her experience covers tax audits, investigations, planning and advisory for clients in a wide range of industries including manufacturing, professional services, oil and gas.

Theresa has more than 20 years of tax and transfer pricing experience, including the successful completion of many tax planning and consulting assignments in areas such as restructuring, mergers and acquisitions. She has performed transfer pricing studies for clients in many industries and provided assistance to clients in developing strategies for the application of advance pricing agreements (APAs), as well as transfer pricing audit defence.

Theresa's wide range of experience in transfer pricing controversy management includes the preparation of strategies for litigations involving anti-avoidance issues, applicability of alternative transfer pricing methodologies during the course of a transfer pricing audit, and evolving strategies for dispute resolution by employing available avenues such as mutual authority proceedings (MAPs). She recently concluded the second and third APAs for Malaysia.

Key projects Theresa has undertaken include transfer pricing documentation projects for manufacturing, distribution, and service companies, including fast-moving consumer goods, technology-related products, branded apparel, lifestyle goods, food and beverages, and oil and gas; transfer pricing audit defence projects which span various industries including telecommunication, oil and gas, tobacco, pharmaceutical, consumer electronic, and semiconductor industries; and APA applications including Malaysia's first unilateral APA application to the Malaysian Inland Revenue Board (MIRB).

Theresa led Deloitte Malaysia to winning the Malaysia Transfer Pricing Firm of the Year award decided by International Tax Review in 2008. She was voted as a leading tax adviser by International Tax Review in 2008/2009, and as one of the World's Leading Transfer Pricing Advisers by Euromoney in 2009/2011. Theresa was also voted as a leading woman in business law in the Legal Media Group's 2012 Guide to the World's Leading Women in Business Law.

She sits on the council of the Malaysian Institute of Certified Public Accountants and is a member of its tax committee. She is a frequent speaker at conferences focusing on transfer pricing and tax both nationally and abroad. She has presented an APA paper in Tokyo jointly with the MIRB.

Theresa is a certified public accountant and a chartered accountant in Malaysia, a fellow of the Chartered Tax Institute of Malaysia, and a licensed tax agent under the Malaysian Income Tax Act, 1967.

Level 10, 1 Sentral

Jalan Travers

Kuala Lumpur Sentral

50470 Kuala Lumpur

Malaysia

Tel: +6 03 2173 1582

Email: thanneermalai.somasundaram@my.pwc.com

Website: pwc.com/taxcontroversy

SM Thanneermalai is a senior executive director in PwC Taxation Services Sdn Bhd, Malaysia.

He leads the transfer pricing, tax audit and investigation group and is also the president of the Chartered Tax Institute of Malaysia (CTIM). CTIM is Malaysia's premier body for tax professionals, providing effective institutional support to members and promoting convergence of interests with the government, using taxation as a tool for the nation's economic advancement.

Thanneermalai has been practising tax in excess of 30 years and has extensive experience in handling a vast variety of transfer pricing and corporate tax assignments. He specialises in advising multinational corporations and local conglomerates on corporate international tax planning, transfer pricing, tax audits and tax investigations.

His clients span industries such as oil and gas, property development, construction, manufacturing, retail trading, automotive, telecommunications, services, insurance and banking. Thanneermalai's experience in transfer pricing includes tax planning, core transfer pricing documentation, reviewing cost sharing models, developing pricing frameworks and mutual agreement procedures.

Over the years, he has led numerous assignments representing Malaysian taxpayers during transfer pricing audits, tax audits and tax investigations before the Malaysian Inland Revenue Board (IRB). His proven track record in numerous major dispute resolution assignments for clients demonstrates his ability to resolve complex business problems. This has been achieved through in-depth understanding of the specific industry issues, a proactive approach and appreciation of the clients' business needs and goals.

In his role as the President of CTIM, he works closely with a range of regulatory authorities, namely, the Ministry of Finance, Malaysian Industrial Development Authority, Ministry of International Trade and Industry and IRB to contribute towards the development of government policies and legislation.

Thanneermalai regularly contributes to local and international professional journals and is a frequent presenter at seminars and conferences both locally and overseas.