Australia

Partner, Tax Controversy & Dispute Resolution

PricewaterhouseCoopers

Melbourne

+61 412861551

paul.mccartin@pwc.com

www.pwc.com.au/tax-controversy.html

Paul is one of Australia's leading tax controversy and dispute resolution advisors. He has over 20 years tax experience and spent over half his career as a senior ATO executive. Paul brings an unparalleled understanding of the ATO and its approach to audits. He uses this knowledge to resolve tax disputes on the best possible terms for his clients.

Paul was the lead advisor to a global energy company involved in a cross border financing dispute. He led the collation of evidence, appeared at the GAAR Panel and led the negotiations. The potential adjustment was $1.5b and 50% penalties. Paul achieved negotiated settlement and no penalties were imposed.

Paul played a lead role in audit defence and settlement negotiations for an ASX listed company. The potential adjustment was $500m and was later resolved on favourable terms with no penalties.

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Controversy management

The Tax Institute (Australia)

Chartered Accountants (Australia & New Zealand)

Masters of Taxation Law

Tax Controversy Partner

PricewaterhouuseCoopers Australia

Sydney

+61 411366123

paul.mcnab@pwc.com

www.pwc.com.au/tax-controversy.html

Bar admissions: Admitted as a Solicitor and Barrister in the Supreme Court of New South Wales Entered in the High Court of Australia Register of Practitioners

More than thirty years of experience in Australian taxation law. Specialising in resolution of disputes with Federal and State Revenue authorities.

Management of audits and negotiations on behalf of taxpayers, conduct of tax litigation in the Administrative Appeals Tribunal, State and Federal Courts.

• Commissioner of Taxation v Financial Synergy Holdings Pty Ltd [2016] HCATrans 232 (7 October 2016

• John Holland Group Pty Ltd v FCT [2015] FCAFC 82

• Adams Bidco Pty Ltd v Chief Commissioner of State Revenue [2018] NSWSC 735

Audit defence, Pre-litigation, Litigation, Controversy management, International tax advisory

Automotive, Consumer goods and services, Financial services, Food and beverage, Gaming, Industrials, Media, Mining, Pharma and life sciences, Tech and telecoms

Chartered Tax Adviser, Australia

LL.B, QUT

LL.M (Hons), Sydney

Grad Dip Legal Practice Law, College of Law NSW

Partner

PwC

Sydney

+61 282669156

eddy.moussa@pwc.com

pwc.com.au

Languages: English

Bar admissions: Solicitor of the Supreme Court, Federal Court and High Court of Australia

Eddy is a Tax Lawyer and Partner in the Tax Controversy Practice in Australia. He leads major complex audit defence for multinational and large private businesses. Areas of focus include anti avoidance, transfer pricing,WHT, financing and IP cases.

• Eddy has assisted clients under audit in a variety of industry sectors including Financial Services, infrastructure, FMCG, Technology and Real Estate.

• He has also successfully resolved debt pricing, anti avoidance, transfer pricing cases involving material amounts of tax and penalties at stake.

• Eddy has also published papers on evidence in tax disputes, anti avoidance, and taxation of intellectual property matters.

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Controversy management

Member of the Law Society of NSW

Chairperson – State Council of the NSW Tax Institute of Australia

Bachelor of Business , Bachelor of Law – University of Technology Sydney

Masters of Taxation , University of Sydney

Partner

PwC

Melbourne

+61 (3) 8603 4133

simon.rooke@pwc.com

www.pwc.com.au

Languages: English

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 over 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 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.

Restructuring, Transactions, M&A, Financial services, Corporate taxes, Audit defence, Dispute resolution, Litigation, Controversy management, Tax consulting, International tax advisory

Automotive, Consumer goods and services, Financial services, Pharma and life sciences

Law Council of Australia, Law Institute of Australia, Chartered Accountants Australia and New Zealand, Tax Institute

Bachelor of Laws (LLB); Bachelor of Commerce (B.Com), University of Tasmania, 1994

Practical Legal Training, College of Law, 2008

Legal partner – tax controversy and national leader for tax litigation and alternative dispute resolution

PwC

Barangaroo, Sydney

+61 2 8266 0197

judy.sullivan@pwc.com

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 over 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.

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. She also leads PwC's charities and not-for-profits practice in Australia.

Australian and ASPAC Leader – Tax Dispute Resolution & Controversy

KPMG Law

Melbourne

+61 400 988 723

angelawood@kpmg.com.au

home.kpmg.com/au/en/home/services/tax/advisory/dispute-resolution-controversy.html

Languages: English

Bar admissions: Admitted as a Barrister & Solicitor of the Supreme Court of Victoria, Federal Court of Australia and High Court of Australia

Angela is Australian & ASPAC Lead Partner for Tax Dispute Resolution & Controversy, representing large corporate taxpayers across the tax dispute continuum (transaction stage, reviews, audits, objections and litigation), drawing on extensive experience running significant litigation for the Commissioner of Taxation, to efficiently resolve disputes.

Angela currently acts for taxpayers in several significant audit/litigation matters including a AUD$1 billion ATO audit of an infrastructure stapled structure (specific and general anti-avoidance provisions, deductibility of expenses between related parties and investors (domestic /offshore)), mineral royalty litigation for mining industry, reviews for transport and technology clients, large ATO audits of automotive and commodities clients (TP / anti-avoidance).

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Litigation

Automotive, Banking, Consumer goods and services, Energy, Gaming, Industrials, Mining, Natural resources, Oil and gas, Pharma and life sciences, Tech and telecoms, Transport, Utilities

Chartered Tax Adviser – The Tax Institute of Australia

Member – Law Institute of Victoria

Law Council of Australia – Member of Victorian Tax Committee

University of Melbourne – Member of Tax Advisory Board (Melbourne Law School)

Bachelor of Laws & Bachelor of Arts, Monash University (1994)