UK

PwC

1 Embankment Place

London WC2N 6DX

UK

Tel: +44 (0) 1612 452 990

Email: david.s.anderson@pwc.com

Website: pwc.com/taxcontroversy

David Anderson is a partner and solicitor and leads PwC's UK indirect tax disputes team. He previously spent a period with HM Customs & Excise (as it then was) solicitor's office and with KPMG. He specialises in advice and dispute resolution in all of the indirect taxes including VAT, customs duty, excise duties, hydrocarbon oils, landfill tax and aggregates levy. He has worked with clients in a wide variety of industry areas that include manufacturing, housing, telecommunications, local authorities, financial services and food and drink industries and has represented clients at all stages of the court structure up to and including the Court of Justice of the European Union.

David's reported cases include Asda Stores Ltd (C-372/06), Colaingrove Limited [2013] UK FTT 116(TC), Colaingrove Limited [2013] UK FTT 312 (TC), Iveco Limited v Revenue and Customs [2013] UK FTT 763 (TC), Taylor Wimpey Plc v Revenue and Customs [2017] UK UT 34 (TCC), Revenue and Customs v Investment Trust Companies [2017] UK SC 29 and London Borough of Ealing v Commissioners of Her Majesty's Revenue and Customs (C-633/15).

David also specialises in helping clients to avoid tax disputes arising. Using a 'litigation lens' to examine a business's indirect tax liabilities and by using technology solutions, David advises clients on how to mitigate the risk of becoming embroiled in an indirect tax dispute and to guard against the actions of indirect tax fraudsters.

David holds professional memberships with the Law Society, the Chartered Institute of Taxation, the VAT Practitioners Group, and is an associate of the Institute of Indirect Taxation. He is a regular speaker at tax conferences and seminars and a frequent contributor to De Voil's Tax Intelligence.

Deloitte UK

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 (0) 207 007 3079; +44 (0) 121 695 5011

Mobile: +44 (0) 7775 807510

Email: saustin@deloitte.co.uk

Website: www.deloitte.com

Shaun Austin, Deloitte UK, has more than 14 years of experience as a partner, and 20 years of experience in transfer pricing.

He has been the partner responsible for the UK regional transfer pricing practice since 2007, and has been the partner in charge of the UK national transfer pricing practice from 2009. Shaun is now European transfer pricing leader.

Shaun has extensive experience in advising a broad range of clients in all areas of transfer pricing including planning, documentation, audit defence and mutual agreement procedures, and debt pricing.

Shaun was listed in the most recent version of Euromoney's Transfer Pricing Expert Guide. He studied at Cambridge University and is a member of the Institute of Chartered Accountants in England & Wales (ICAEW).

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 (0)20 7007 3608

Fax: +44 (0)20 7007 3521

Email: nbarker@deloitte.co.uk

Website: www.deloitte.com

Nigel Barker, Deloitte UK, has been a partner for more than 10 years and is the leader of Deloitte's UK tax disclosure and transparency team. Nigel is a member of the global tax controversy team and advises on the tax transparency agenda including the automatic exchange of tax information and beneficial ownership register regimes.

Nigel has significant experience of advising private clients and private companies on a wide range of tax matters. He has advised on information notices, worldwide disclosure facility (WDF) disclosures and a wide range of HMRC enquiries covering UK residence and domicile status, dual contracts, private equity structures, employee benefit trusts, specific planning arrangements and trust distributions and reporting.

Nigel also works closely with Deloitte's tax policy group in shaping the firm's responses to HMRC consultations on personal tax and disclosure issues.

Nigel has also been heavily involved in advising clients on their approach and methodology to respond to the UK criminal offences of failure to prevent the facilitation of tax evasion.

Mayer Brown

201 Bishopsgate

London EC2M 3AF

UK

Tel: +44 (0) 20 3130 3645

Fax: +44 (0) 20 3130 8951

Email: sbhogal@mayerbrown.com

Website: www.mayerbrown.com

Sandy Bhogal heads Mayer Brown's tax group in London. His experience ranges from general corporate tax advice to transactional advice on matters involving corporate finance, banking, capital markets, asset finance and property. He also has significant experience with corporate tax planning, as well as with advising on the development of domestic and cross-border tax-efficient structures. He advises on a number of controversy related matters, including advance pricing agreements and other ruling processes with HMRC, as well as international and domestic tax technical disputes.

Prior to joining Mayer Brown in 2005, Sandy was associated with Ernst & Young and with a leading international legal practice.

KPMG LLP (UK)

15 Canada Square

Canary Wharf

London

UK

Tel: +44 (0)20 7311 2487

Email: kevin.elliott@kpmg.co.uk

Website: www.kpmg.com/uk

Kevin Elliott has worked for KPMG for 12 years helping corporate and private clients manage their relationships with HM Revenue and Customs (HMRC). Before joining KPMG, Kevin worked at HMRC for 18 years including five years in the large business service coordinating corporate risk assessment and enquiry work.

Kevin has experience of helping clients with all aspects of tax enquiries including disclosure issues, responding to HMRC information notices, handling HMRC penalty claims and progressing enquiries through to successful resolution.

In addition to many years of experience in traditional enquiry work, Kevin has been involved with the development of contemporary dispute resolution programmes and has worked on a number of high risk corporate programme (HRCP) projects for large corporate clients and enquiry coordinator programme (ECP) projects for medium-sized clients. Kevin has a deep understanding of these dispute resolution processes and HMRC governance procedures. He has developed excellent working relationships with the key HMRC personnel involved.

Most recently Kevin has assisted the development of alternative dispute resolution (ADR) and the use of mediation as a new means of resolving tax disputes. In 2013, Kevin undertook a secondment at HMRC's dispute resolution unit where he was responsible for managing the ADR pilot for large and complex cases. Kevin has achieved mediator accreditation from the Centre for Effective Dispute Resolution and acts as a co-mediator in resolving tax disputes through facilitated discussions with HMRC.

As well as a deep understanding of the UK dispute resolution landscape, Kevin has been involved in the development of the KPMG global tax disputes resolution and controversy network. Kevin is KPMG's global tax disputes lead for the UK and EMEA region and has practical experience of cross-border tax audits.

39 Essex Chambers

81 Chancery Lane

London WC2A 1DD

UK

Tel: +44 (0) 20 7832 1111

Email: alison.foster@39essex.com

Website: www.39essex.com

Alison Foster QC is the joint head of chambers at 39 Essex Chambers. As a highly successful public lawyer with particular expertise in contentious taxation involving EU law and ECHR matters, she has acted both for the taxpayer and the revenue for the whole of her career. She has appeared in some of the highest profile cases and at all levels of the court and tribunal system. Her in-depth public law and regulatory knowledge, together with her outstanding advocacy, have led to instructions across most areas of taxation – she specialises in complex matters requiring careful, persuasive advocacy.

Much of her private work is confidential, but examples of her reported cases range from the Jaffa Cakes VAT litigation to R. (on the application of de Silva) v Revenue and Customs Commissioners (Court of Appeal) [2016] S.T.C. 1333; [2016] B.T.C. 6; (recently heard in the Supreme Court) involving direct taxation and reliefs concerning the film industry and Isle of Wight & Others v HMRC [2015] EWCA Civ 1303; [2016] P.T.S.R. 620 – a competition law case involving principles of VAT and public law and billions of pounds of alleged lost revenue.

More recently she has successfully defended HMRC's 45% withholding tax in a decision released on July 12 2017. In BAT Industries and others v HMRC [2017] UKFTT 558 (July 12 2017), the First-tier Tribunal found that CTA 2010 Part 8C was lawful. Several companies of the BAT group had appealed against the deduction of withholding tax on payments of restitution interest awarded to BAT as test claimants in the "Franked Investment Income Group Litigation Order". Alison led a team comprising a specialist tax silk and four juniors resisting an EU law and ECHR challenge to a corporation tax measure.

The legal directories list Alison as a leading barrister in each of her specialisations and she is described as "absolutely excellent and everything you want in a silk, "very approachable and clear" and a "wonderful barrister; high on the list for difficult cases". She also won Barrister of the Year 2016 at the Modern Law Awards.

Alison is a deputy high court judge of the Chancery Division.

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 (0) 20 7303 2218

Email: jhenshall@deloitte.co.uk

Website: www.deloitte.com

John Henshall, Deloitte UK, is a partner in the firm's London international tax practice specialising in transfer pricing. In this role, John is responsible for service to clients on all aspects of cross-border pricing arrangements. This has included providing assistance to major multinational enterprises in their dealings with the UK and foreign tax authorities in transfer pricing compliance matters and advance pricing arrangements, as well as reviewing companies' cross-border pricing arrangements for planning – known as mobile income studies. In particular, John has assisted companies in the electronics, retail, biotechnology, defence and general trading industries in the development and/or defence of their tax planning and/or pricing arrangements.

John has a particular interest in the transfer pricing of intellectual property. He has also been consulted by the governments of China and Iran about the modernisation of their approach to international taxation.

John is heading the European global earnings management strategies (GEMS) team, which raises mobile income planning to a higher, more practical level.

Training initially with the UK HM Revenue and Customs, prior to joining Deloitte in 2000, John spent 12 years at another Big 4 firm. He began transfer pricing work in 1991 and has been involved with transfer pricing on a full-time basis for four years. He is regularly published, including in International Tax Review and the International Transfer Pricing Journal, and was co-author of International Transfer Pricing 1999–2000 published by CCH. John also lectures in the UK and Europe on transfer pricing.

Deloitte UK

Four Brindleyplace

Birmingham, B1 2HZ

UK

Tel: +44 (0) 121 695 5722

Email: ojarratt@deloitte.co.uk

Website: www.deloitte.com

Oliver Jarratt, Deloitte UK, is a director in the litigation, advisory and settlement (LAS) team, and leads the advisory part of LAS in the UK.

Oliver and his team help to resolve clients' disputes with HMRC by the most appropriate and cost-effective means (such as negotiation, alternative dispute resolution or tribunal litigation), and they are involved in a wide range of consultancy work with complex technical angles. The vast majority of Oliver's work relates to VAT, but he also advises on customs duty and environmental taxes, assisting clients of all sizes, from multinational to local. Oliver works across all industries, but with particular emphasis on the consumer business and automotive sectors.

Deloitte UK

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 (0) 20 7007 0871

Email: jamarsh@deloitte.co.uk

Website: www.deloitte.com

Jason Marsh, Deloitte UK, has been a partner in the corporate tax practice in London since 2001. He joined Deloitte UK in 1991. He is a qualified mediator (by the Centre for Effective Dispute Resolution (CEDR)) and has been a founding member of the Deloitte UK tax risk management and resolution team since 2007.

Jason has gained extensive experience working with corporate clients, and HM Revenue and Customs (HMRC), to resolve tax disputes through HMRC's high risk corporate programme (HRCP), managing corporate risks programme (MCRP) and collaborative dispute resolution (CDR) processes and governance frameworks.

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 (0) 207 007 6568

Mobile +44 (0) 7813 292806

Email: edmorris@deloitte.co.uk

Website: www.deloitte.com

Edward Morris, Deloitte UK, specialises in transfer pricing dispute prevention and resolution. He has been instrumental in setting up Deloitte's global TP controversy team, consisting of former tax administration personnel and in particular former government competent authorities. This network has a global reach and expertise and helps clients with mutual agreement procedures, advance pricing agreements and TP enquiry resolution.

In a previous role, Edward worked for HMRC as a tax inspector and as UK competent authority, at the EU Commission and also at the various OECD working parties concerned with tax treaties, transfer pricing and permanent establishments.

Edward helps clients across all industry sectors deal with the increasingly complex world of tax disputes. Edward has also appeared consistently in Euromoney's Transfer Pricing Expert Guide since joining Deloitte.

39 Essex Chambers

81 Chancery Lane

London WC2A 1DD

UK

Tel: +44 (0) 20 7832 1111

Email: ksc@39essex.com

Website: www.39essex.com

Kelly Stricklin-Coutinho is a barrister at 39 Essex Chambers, where she specialises in tax disputes, international tax and EU tax.

Her tax disputes experience includes litigation at every level of English court and tax tribunal, and cases before the CJEU. She has represented claimants in judicial review proceedings across a wide range of taxes, direct and indirect. She has acted in arbitral proceedings, including those with tax issues. Kelly has also acted on a number of high value enquiries in respect of both international tax issues and on domestic tax disputes, and on a number of high value settlements.

Kelly's clients include a broad range of multinationals, FTSE 100 and 250 companies, local authorities, government bodies, major insurers, high-net-worth individuals and SMEs.

Her experience includes the following.

High value tax enquiries on a number of issues, including controlled foreign corporations, debt cap, group and loss relief; double tax treaty disputes; advising on the compatibility of aspects of corporation taxes with state aid law; settlements; and restitution claims.

Representing a client in their complaint before the European Commission; acting in a proposed reference to the CJEU in respect of VAT avoidance and abuse; acting as junior counsel in a proposed group litigation order in respect of 300 claimants; advising in respect of compound interest claims; advising on VAT in respect of land and property; and claims for restitution.

Anti-dumping duty; import duty and VAT; environmental taxes (landfill tax, climate change levy, aggregates levy); and inheritance tax.

Kelly trained at the Directorate General for Taxation and Customs at the European Commission, in the direct tax policy analysis unit where she was involved in the proposal for and drafting of a proposed directive on double tax dispute resolution.

Prior to joining 39 Essex Chambers, she worked in the award winning team running the FII GLO (dividend tax), the CFC and Dividend GLO (CFCs and portfolio dividends), the Thin Cap GLO (thin cap and transfer pricing) and the Marks & Spencer (final losses) cases. She also advised on high-value tax enquiries. She has experience of working in a Big 4 firm.

Kelly is a visiting lecturer at King's College London where she convenes the EU tax law module on the LLM, part of the international tax law pathway and the EU law pathway.

She is ranked in the Legal 500 for VAT and for EU Law.