Australia

PwC

201 Sussex Street

Sydney NSW 2000

Australia

Tel: +61 2 8266 6858

Email: michael.bersten@pwc.com

Website: www.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

Grosvenor Place

225 George Street

Sydney NSW 2000

Australia

Tel: +61 2 9322 7770

Mobile: +61 410 045 300

Email: ficraig@deloitte.com.au

Website: www.deloitte.com

Fiona Craig, Deloitte Australia, has 20 years of experience with Deloitte UK and Deloitte Australia, including 15 years specialising in transfer pricing. Fiona's primary focus is in the globally dynamic area of transfer pricing controversy, providing strategic and practical advice to taxpayers engaging with revenue authorities on both audit defence and advance pricing agreement matters.

Her impressive track record in achieving successful transfer pricing outcomes includes experience in implementing and pricing tax efficient structures for large listed and privately owned multinational organisations and obtaining subsequent fiscal agreements.

Fiona advises clients in a variety of sectors with particular focus on the energy and resources, technology and pharmaceutical sectors.

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 over 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, R&D 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 full range of the 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, 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 the London-based 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; senior tax counsel, group head – appeals and review programme; and leader of the ATO's complex audit programme in Victoria.

Deloitte Australia

Grosvenor Place

225 George Street

Sydney NSW 2000

Australia

Tel: +61 2 9322 7578

Mobile: +61 419 205 001

Email: mkenny@deloitte.com.au

Website: www.deloitte.com

Mark Kenny, Deloitte Australia, has 31 years' experience in providing taxation services, specialising in international tax and transfer pricing. His experience includes implementing and pricing tax efficient structures for large listed and privately owned multinational enterprises.

Mark has managed both transfer pricing reviews and audits (including a joint audit involving two tax jurisdictions), as well as the negotiation of advance pricing agreements.

Mark advises clients in a variety of sectors with a particular focus on manufacturing, engineering, technology, pharmaceuticals, and retail including luxury goods.

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: www.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 Tce

Perth WA 6000

Australia

Tel: +61 8 9365 7960

Email: joleek@deloitte.com.au

Website: www.deloitte.com

Jonathon Leek, Deloitte Australia, is a solicitor and barrister with more than 20 years of experience as a tax specialist.

Jonathon is experienced in advising Australian and multinational enterprises in relation to direct and indirect taxes 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, appealing to courts and tribunals, and negotiating settlements, including by mediation.

Jonathon is also experienced in acting for clients operating in a broad range of industries including energy, resources, real estate, infrastructure, financial services, media, communications, and technology.

PwC

Freshwater Place

2 Southbank Boulevard

Southbank Vic 3006

Australia

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

Email: paul.mccartin@pwc.com

Website: www.pwc.com/taxcontroversy

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

Paul has over 18 years of tax experience and joined PwC after 12 years working at senior levels of the Australian Taxation Office (ATO). Paul specialises in pre-litigation dispute resolution and has achieved outstanding results for clients. While at the ATO, Paul performed a variety of senior compliance and technical roles including working as an assistant commissioner in the public groups and international and the aggressive tax planning business lines. Paul is a former ATO Competent Authority and was also the ATO's delegate on the Joint International Tax Shelter Information Centre (JITSIC) based in Washington DC from 2009-2010.

In an environment of increasing revenue authority collaboration, Paul's ATO and international tax administration experience is recognised and highly sought after by clients to assist them to resolve a range of complex international disputes.

Paul uses his ATO technical and compliance experience, coupled with his understanding of the ATO and international tax administration 'mindset', to specialise in assisting clients to strategically and effectively manage risk reviews, audits and objections.

Paul has particular expertise in managing disputes with the ATO having resolved a number of significant and complex matters for listed public companies, private groups and high-net wealth individuals.

PwC

201 Sussex St

Sydney

Australia

Tel: +61 (02) 8266 5640

Email: paul.mcnab@au.pwc.com

Website: www.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 last 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 last 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

Darling Park

201 Sussex Street

Sydney NSW 2000

Australia

Tel: +612 8266 9156

Mobile: +614 1311 1161

Email: eddy.moussa@au.pwc.com

Website: www.pwc.com/taxcontroversy

Eddy Moussa is a practising tax lawyer with over 17 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.

He has also advised a number of multinational enterprises on international tax issues including cash repatriation, investment structuring, withholding tax and treaty issues.

Eddy also has an interest in the taxation of intellectual property in Australia and has written papers on the topic.

He is on the NSW state council of the Tax Institute of Australia and the NSW professional development committee of the Tax Institute of Australia 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 StreetMelbourne, VIC 3000

Australia

Tel: +61 3 9603 3683

Email: peter.murray@hallandwilcox.com.au

Website: www.hallandwilcox.com.au

Peter Murray is a pre-eminent tax adviser with more than 30 years' experience. He is recognised as a leading Australian tax lawyer in Doyles' Guide to the Australian Legal Profession.

Peter leads the Hall & Wilcox tax controversy and dispute resolution practice, which now comprises 12 professionals and five partners. 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 wealth 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 characterisation, 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: www.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

201 Sussex StreetSydney NSW 2000

Australia

Tel: +61 2 8266 0197

Email: judy.sullivan@pwc.com

Website: www.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 wealth 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

Woodside Plaza

Level 14, 240 St Georges Terrace

Perth, WA 6000

Australia

Tel: +61 8 9365 7122

Email: jvanrhyn@deloitte.com.au

Website: www.deloitte.com

Jacques van Rhyn, Deloitte Australia, is an international tax and transfer pricing partner and leader of the national transfer pricing practice. He is a qualified attorney and has been practising for more than 20 years, several of which were spent leading national and regional transfer pricing teams in the Big 4 firms.

Before relocating to Australia in 2009, Jacques was the Africa regional transfer pricing leader for another Big 4 firm. He has gained extensive experience serving clients across Africa, Australia and Asia Pacific in various industries including energy and resources, mining and oil field services, automotive and pharmaceuticals. Jacques has managed several multi-jurisdictional international tax and transfer pricing projects for multinational groups, ranging from global business reorganisations, global documentation, intellectual property (IP) tax planning and dispute resolution.

He provides service across multiple countries leveraging his strong global networks, knowledge of the OECD guidelines, double tax treaties and in-country transfer pricing rules, and awareness of revenue authorities' enforcement of these rules in various jurisdictions including South Africa, Australia, China, UK and other African countries. Jacques has led a number of significant transfer pricing cases and audits, and negotiated favourable advance pricing agreements in several jurisdictions.

Jacques has been listed in Euromoney's guide to the world's leading transfer pricing advisers in both South Africa and Australia. He is a regular presenter at various international tax and transfer pricing conferences and forums, and is a contributor to various tax and industry publications.

KPMG Australia

147 Collins Street

Melbourne, Vic 3000

Australia

Tel: +61 3 9288 6408

Email: angelawood@kpmg.com.au

Website: www.kpmg.com/au

Angela Wood is the national lead partner of the tax dispute resolution and controversy team with KPMG Australia. Angela is also the Asia Pacific leader within KPMG International's global tax dispute resolution and controversy services network.

With 20 years' experience representing the Australian Taxation Office (ATO) and taxpayers in tax litigation and dispute resolution at KPMG, Angela assists multinationals, large private groups and high-wealth individuals to successfully navigate to efficient and early resolution of disputes at all points along the tax controversy continuum. She gets involved in early-engagement with the ATO at the transaction stage, through to requests for rulings, ATO risk reviews and audits, along with objections and litigation.

Angela's Australian and ASPAC practice focuses on effective management of tax dispute risk across a range of industries, including energy, mining, finance, automotive, infrastructure, IT/technology and retail. She has extensive experience in dispute management in relation to transfer pricing, income tax, general anti-avoidance provisions and Australia's recently enacted Multinational Anti-avoidance Law. To bolster taxpayer positions, Angela specialises in multi-jurisdictional evidence gathering, designed to positively influence outcomes in alternative dispute resolution processes in reviews, audits and litigation.

Prior to joining KPMG Australia, Angela was a partner in an Australian law firm, where she represented the ATO in relation to its most significant and complex tax litigation in the Federal Court of Australia and High Court of Australia.