UK

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 MAP, 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).

Field Court Tax Chambers

3 Field Court

Gray's Inn

London WC1R 5EP

UK

Tel: +44 (0)20 3693 3700

Email: pb@fieldtax.com

Website: www.fieldtax.com

Philip Baker is a barrister and Queen's Counsel, practising from Field Court Tax Chambers in Gray's Inn. He was called to the bar in 1979, began practising in 1987 and took silk in 2002. He became a bencher of Gray's Inn in 2011. He specialises in international tax issues, with a particular emphasis on double tax conventions, and on European Union law and taxation. He has a particular interest in the European Convention on Human Rights and taxation.

Before moving into practice, Philip taught law for seven years at the School of Oriental and African Studies, London University. He was subsequently a visiting professorial fellow at Queen Mary University of London, and is now a senior associate fellow of the Institute of Advanced Legal Studies, London University and a visiting professor at Oxford University. He is the author of 'Double Taxation Conventions' and 'International Tax Law' and the editor of the 'International Tax Law Reports'.

In recent years, Philip has been involved in litigation in the UK tax tribunals and the Court of Justice of the European Union concerning consortium relief for losses under non-discrimination provisions and EU law (Felixstowe Docks), and is part of the Irish government legal team in the Apple state aid case. He has also acted as an expert witness in India (Vodafone) in the US (Entergy, PPL, Bank of New York) in Norway (Transocean) and other countries. He has also been involved with several arbitrations on tax-related issues. He appears on behalf of the Mauritius government in Privy Council appeals.

Philip's advisory practice covers UK and international tax law and EU tax law (including state aid), and extends to both private client matters (largely cross-border issues) and corporate matters, including multinational group tax issues.

Philip is a member of the permanent scientific committee of the International Fiscal Association, the Financial Secretary's Tax Professional Forum, and the international tax committee of the Law Society.

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 over 10 years and is the national head of the private client department, as well as co-leader of Deloitte's UK tax disclosure and transparency team operating in the private market. 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, LDF 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.

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

Mayer Brown

201 Bishopsgate

London EC2M 3AF

UK

Tel: +44 20 3130 3645

Fax: +44 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. Sandy advises on a number of controversy related matters, including APA's 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 LLP and with a leading international legal practice.

PwC Legal

1 Embankment Place

London WC2N 6DX

UK

Tel: +44 (0) 191 269 4441

Mobile: +44 (0) 7525 925707

Email: andy.j.brown@pwclegal.co.uk

Website: www.pwc.com/taxcontroversy

Andy Brown is one of the UK's leading tax disputes practitioners with more than 20 years' experience representing clients in both direct and indirect tax dispute resolution. He is a partner in PwC Legal's tax disputes team and is the lead for the tax crime and investigations practice.

Andy primarily advises clients who are subject to HM Revenue and Customs (HMRC) criminal and civil investigations for tax fraud as to how they should deal with issues, and advises at all stages of the investigation, including the initial criminal investigation and disclosure work through to formal criminal proceedings and prosecutions. This also includes elements of tax litigation at the Tax Tribunal, challenges by way of the Judicial Review and Magistrate and Crown court work.

His practice is international in nature with many clients operating outside of the UK and it covers private clients through to large corporates.

Clifford Chance

10 Upper Bank Street

London, E14 5JJ

UK

Tel: +44 (0)20 7006 2044

Email: liesl.fichardt@cliffordchance.com

Website: www.cliffordchance.com

Liesl Fichardt leads Clifford Chance's tax dispute resolution practice and is one of the UK's leading tax disputes practitioners. She has extensive experience in tax litigation, negotiating with revenue authorities and settling disputes. She possesses considerable court and tribunal experience including conducting cases in the Tax Tribunal, the Courts of Appeal and the Court of Justice of the European Union.

Liesl practiced as a tax barrister for 13 years and previously acted as a judge in the High Court of South Africa. She is Chairperson of the UK branch of the International Fiscal Association. She is recognised in leading legal directories for her outstanding success and for consistent positive feedback from clients and peers.

Liesl leads arguably the most experienced group of partners and associates who deal with tax investigations, litigation and dispute resolution. The combination of local expertise and a 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 ongoing tax and VAT matters covering the entire range of tax dispute resolution. This includes:

• 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.

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 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: +44 121 695 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 some 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

Athene Place

66 Shoe Lane

London EC4A 3BQ

UK

Tel: +44 20 7007 0688

Email: akhan@deloitte.co.uk

Website: www.deloitte.com

Anbreen Khan, Deloitte UK, is the head of the dispute resolution group, specialising in indirect taxes. She is a partner, based in London, with expertise and significant experience in dealing with indirect taxes and in particular dispute resolution work. Anbreen advises a wide spectrum of clients and has advised in a number of landmark VAT cases in the UK and at the Court of Justice of the European Union including The Rank Group plc; and Everything Everywhere (formerly T-Mobile). Other notable cases include: Marks & Spencer Plc; and Association of Investment Trust Companies/JP Morgan Fleming. These cases have made an outstanding contribution to UK business and the development of tax policy.

Anbreen has extensive experience in dealing with complex VAT legal issues and negotiations in relation to collaborative tax dispute resolution. Anbreen leads a group of tax specialists in the UK who provide a dedicated dispute resolution service across both indirect tax and corporate tax. The team has a high market profile, winning the 'UK Best VAT Team' award twice in 2007 and 2009 and was voted the 'Best Big 4 Tax Team' in 2011.

Anbreen is a qualified lawyer. She is a former winner of the 'Rising Star' award for The Tax Journal's Indirect Tax Awards and is also a member of the Institute of Chartered Accountants England and Wales. Anbreen was recently listed as an indirect tax expert in the 2012, 2013, 2014 and 2015 editions of the Indirect Tax Leaders guide.

Deloitte UK

2 New Street Square

London, EC4A 3BZ

UK

Tel: +44 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 & 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: +44 207 007 6568

Mobile +44 7813 292806

Email: edmorris@deloitte.co.uk

Website: www.deloitte.com

Edward Morris, Deloitte UK, has advised on many transfer pricing issues across many industries and has been instrumental in forming Deloitte's global Competent Authority network of ex-government and specialised expertise to help clients with all forms of dispute resolution and dispute prevention. In particular, Edward has helped many clients negotiate successful advance pricing agreements (APAs) and mutual agreement procedures (MAPs) and to resolve ongoing transfer pricing enquiries.

Edward joined Deloitte UK in 2009 after a career in the head office international division of Her Majesty's Revenue and Customs (HMRC). He was involved in a range of international tax issues and problems but specialised in transfer pricing, PEs and treaty matters and represented the UK at the OECD.

Edward served as the UK delegated Competent Authority for MAP and EU arbitration cases. This work involved dispute resolution as well as dispute prevention work on APAs, with fiscal authorities around the world.

Previously, Edward led many of HMRC's transfer pricing enquiries into the biggest and most complex cases, including involvement in litigation work before the UK courts.

Edward enjoyed a two and half year secondment to Brussels, where he served on the secretariat to the EU Joint Transfer Pricing Forum (JTPF), helping to update the EU Arbitration Convention and the various associated codes of conduct. Edward's magnum opus was the EU APA guidelines adopted by all 28 member states.

Edward has also spent considerable time at the OECD, attending Working Party 6 on transfer pricing (including the sub-groups on dispute resolution and business restructuring), either for the UK or as Commission observer and latterly as a private sector representative. Edward also attends meeting of the EU JTPF. Edward's eminence in the wider international tax field was recognised by the OECD when he was asked to speak at the 50th anniversary celebration of the OECD Model Tax Convention and by IFA in 2011 when Edward participated in the opening plenary session on business restructuring. Edward has appeared consistently in Euromoney's Transfer Pricing Expert Guide since joining Deloitte.

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 20 7007 6580

Email: trowbotham@deloitte.co.uk

Website: www.deloitte.com

Tom Rowbotham, Deloitte UK, is a tax partner and is responsible for the firm's strategy in the area of tax disputes. He is also a member of the global tax controversy management executive team and leads the service line in relation to all disclosure facilities. Tom has worked for large international businesses, owner-managed businesses, and high-net worth individuals and has extensive experience in dealing with all forms of tax dispute.

Before joining Deloitte UK, Tom worked for 20 years as an inspector of taxes for HM Revenue & Customs (HMRC). Tom led many significant cases where HMRC raised inquiries or requested information from clients and external referrals across all aspects of industry.

As Tom's main focus is advising clients on dealings and interactions with HMRC, his experiences from working on both the side of the inspector and the client prove invaluable in providing practical commercial strategies. Tom is advising a number of clients with regard to HMRC's initiatives around tax transparency and exchange of information.

Some highlights of Tom's project experiences include significant and varied issues covering many industry sectors delivering client-favorable outcomes, information requests from HMRC, which are both sensitive and potentially commercially damaging, disclosures to HMRC in areas of uncertainty to achieve a controlled outcome reflecting appropriate commercial pressures, and requests by UK and other jurisdictions under tax information exchange agreements (TIEAs).