UK

Grant Thornton

30 Finsbury Square

London EC2P 2YU

UK

Tel: +44 (0)20 7728 3195

LinkedIn: uk.linkedin.com/in/roopaaitken

Email: roopa.aitken@uk.gt.com

Website: www.grant-thornton.co.uk

Roopa Aitken is a corporate tax partner at Grant Thornton UK with significant experience of advising multinational groups on a wide range of tax matters.

Roopa has had more than 19 years of experience advising a range of business types and size on tax matters. She specialises in EU claims and related tax issues and has advised many clients on the compatibility of UK law with EU law. Most recently she successfully advised in the Philips Electronics case which was heard by the Court of Justice of the European Union.

Roopa's wider tax team and colleagues provide advice concerning all tax matters including indirect taxes and private client tax issues, in addition to corporate tax, thereby ensuring that all aspects of her clients' tax affairs are catered for.

Many of the matters which Roopa advises on have cross-border implications affecting a client's business in numerous jurisdictions. Roopa is able to draw upon the expertise and experience of colleagues in the Grant Thornton International teams from around the world to deliver seamless advice.

Roopa works closely with her specialist colleagues across all of Grant Thornton's service lines to ensure her clients have access to the full breadth of advice and counsel available to support their businesses' developments and wider growth aspirations.

Roopa is a regular presenter at tax conferences and has published numerous technical articles on tax issues. She is on the UK branch committee of the International Fiscal Association and the team has a strong reputation in the market, winning Best International Tax Team at the 2012 Lexis Nexis awards and Best Team in a National Practice at the Taxation awards 2014.

PwC Legal

1 Embankment Place

London WC2N 6DX

UK

Tel: +44 1612 452 990

Email: david.s.anderson@pwclegal.co.uk

Website: pwc.com/taxcontroversy

David leads the indirect tax team at PwC Legal, recent winners at the Tax Awards 2014. He previously spent a period with HM Customs & Excise Solicitor's Office and with KPMG. He specialises in advice and litigation of all 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 which 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. His reported cases include Med Hotels Ltd [2010]UKFTT 120 (TC), Helena Housing Ltd [2010]UKFTT 71 (TC), Asda Stores Ltd [2007]EUECJ C-372/06, Gabem Management Ltd [2007]UKSPC SPC00586, Colaingrove Limited [2013]UKFTT 116(TC), Colaingrove Limited [2013]UKFTT 312 (TC), WM Morrisons Supermarkets PLC [2012]UKFTT 366(TC) and Iveco Limited v HMRC[2013] UKFTT 763 (TC).

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 CTA qualified.

David joined the Solicitor's Office of HM Customs and Excise as an executive officer in 1989 and later became a trainee solicitor. He qualified in 1999 on joining Kent Jones and Done to undertake commercial litigation before moving back into indirect tax litigation in an in-house role in KPMG in 2000. David went on to join PwC Legal's tax litigation team as partner in 2011 to further develop the firm's nationwide practice.

David is a regular speaker at tax conferences and seminars and a frequent contributor to the Tax Journal.

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

Shaun Austin, Deloitte UK, has more than 12 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 'Guide to the World's Leading Transfer Pricing Advisers'. 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. 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 in the High Court and Court of Appeal on the cross-border enforcement of taxes (Ben Nevis). 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 committee of the Law Society.

PricewaterhouseCoopers Legal

1 Embankment Place

London WC2N 6DX

UK

Direct: +44 (0) 191 269 4441

Mobile: +44 (0) 7525 925707

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

LinkedIn: linkedin.com/in/andybrownlegal

Twitter: @AndyBrownTax

Website: pwc.com/taxcontroversy

Andy is one of the UK's leading tax disputes practitioners with more than 20 years' experience of representing clients in both direct and indirect tax dispute resolution. He is a partner in PwC Legal's tax disputes team and is the UK lead for the PwC Europe, Middle East and Africa indirect tax dispute network.

A key focus of Andy's practice relates to investigations work, which includes both civil and criminal work. Andy is a leader in advising clients who are subject to HMRC 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. Andy also regularly advises clients on missing trader fraud cases.

Andy's indirect tax dispute practice involves advising clients both on claims and proceedings in the High Court and the Administrative Court by way of judicial review. He also advises on statutory appeals to the Tax Tribunal and higher courts. A large element of his indirect tax practice revolves around the use of alternative dispute resolution (ADR) in settling disputes.

Andy also has a number of clients with direct tax disputes. He has extensive experience in handling and advising on tax avoidance litigation in the Tax Tribunal as well as direct tax fraud and disclosures to government authorities including HMRC.

Deloitte UK

Abbots House

Abbey Street

Reading, RG1 3BD

UK

Tel: +44 (0) 118 322 2376

Email: rcoombes@deloitte.co.uk

Richard Coombes has been a tax specialist since 1985 and has specialised in transfer pricing since 1992. He spent 16 years with HMRC, the UK tax authority, as a corporate tax and transfer pricing expert, including seven years as a transfer pricing specialist in HMRC's London head office. While in the head office, he undertook a range of operational and policy roles, including working on some of the UK's largest transfer pricing investigations, acting as lead inspector in several rounds of high profile litigation, delivering national programmes of training in transfer pricing, PE and business model reorganisations, acting as competent authority, and advising the UK Government on legislative and procedural reform.

Richard has worked in Deloitte UK's transfer pricing practice for 12 years. He is experienced in business model and transaction flow design, and specialises in planning, design and defence of transfer pricing structures, with a particular emphasis on intellectual property and intangibles. He also uses his tax authority experience to help lead Deloitte UK's tax authority transfer pricing work – being advance pricing agreements (APAs) and dispute resolution (including enquiry defence and competent authority work). In the last three or four years, Richard has advised on MAPs and APAs between the UK and more than a dozen of its treaty partners, including the first ever UK-Poland APA. Richard also remains active in devising and delivering training and in public speaking and technical writing.

Richard has an MA from Cambridge University and his hobbies include writing music and studying Russian.

PricewaterhouseCoopers

1 Embankment Place London WC2N 6RH

UK

Tel: +44 (0)20 7804 5260

Fax: +44 (0) 20 7804 2299

Email: peter.cussons@uk.pwc.com

Website: pwc.com/taxcontroversy

Peter Cussons is an international corporate tax consultant at PwC. Peter qualified as a chartered accountant in 1978, and qualified as an associate of the Chartered Institute of Taxation (CIOT) in 1979.He became a partner in Price Waterhouse in 1987.

Peter had for many years lead PwC's EU direct tax group and as a client partner has had a wide range of UK and internationally-based corporate clients.

Peter's previous relevant experience includes acting as instructing accountant in the ACT Class 2 & 3 Group Litigation Orders (High Court and Court of Appeal) and in the Depreciation in Stock case (Special Commissioners, High Court and House of Lords).He has also acted as instructing accountant in the Marks-and-Spencer PLC v Halsey case (High Court, Court of Appeal, ECJ, First-Tier Tribunal and Upper Tier Tribunal).

Peter chairs the Large Business and International Committee of the Tax Faculty of the ICAEW, and is a member of the ICAEW Tax Faculty technical committee. Peter is also a member of the international tax committee of the CIOT.

Peter is the only Big 4 representative on the Confederation of British Industry's main tax committee.

He is a frequent contributor to various tax publications and is cited in the Financial Times and other papers/journals regularly. Peter is also on the editorial board of the Tax Journal and is a guest lecturer at Queen Mary, University of London.

Peter has also been instrumental in various direct tax infringement proceedings by the European Commission and has led or assisted some high profile group litigation orders (GLOs) in the UK, including the recently granted Stamp Taxes GLO.

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 contentious tax practice and is one of the UK's leading tax disputes practitioners. She has extensive experience in tax litigation, negotiations with revenue authorities and settlement of 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 British Branch of the International Fiscal Association. She is recognised in leading legal directories including International Tax Review's Tax Controversy Leaders Guide for her outstanding success and for consistent positive feedback from clients and peers.

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

• 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.

KPMG

15 Canada Square, Canary Wharf

London E14 5GL

UK

Tel: +44 20 73113053

Email: paul.harrison@kpmg.co.uk

Website: www.kpmg.com/uk

Paul Harrison joined KPMG in the UK in 1995 after nine years as a senior tax inspector with HM Revenue & Customs (HMRC), where he occupied senior positions and handled the largest cases of suspected fraud and avoidance.

Paul leads a national UK team of professionals dedicated to helping clients deal with contentious tax matters of all kinds. Paul personally leads the largest and most complex contentious tax controversy projects and has advised a diverse range of clients from multinational corporations to high net worth individuals. Paul is recognised by his peers and by HMRC as a leading tax professional and has forged strong professional relationships with many senior HMRC officials. In addition to his national role, Paul is also KPMG International's EMEA leader within the Global Tax Dispute Resolution & Controversy Services network.

PwC

1 Embankment Place

London WC2N 6RH

UK

Tel: +44 (0)20 7212 5157

Mobile: +44 (0)7979 805737

Email: diane.hay@uk.pwc.com

Website: pwc.com/taxcontroversy

Diane is a special adviser, international tax, at PwC.

From 2004 to 2008 Diane was the deputy director at HM Revenue & Customs with responsibility for a wide range of international corporate tax issues, including transfer pricing, controlled foreign companies (CFCs), company residence and double tax relief. She led the reorganisation of transfer pricing administration in the UK and was the first chair of HMRC's Transfer Pricing Board. Diane led the team that litigated the UK's only substantive transfer pricing case, DSG Retail Ltd and others v HMRC (2009), as well as preparing three other major cases for potential litigation.

As the UK's competent authority, she had responsibility for the mutual agreement procedure (MAP) and the advance pricing agreement (APA) programmes. She also served on the OECD's Working Party 6 Bureau on Multinational Enterprises and was the HMRC representative on the OECD Committee on Fiscal Affairs.

After leaving government, Diane joined PwC in London as a special adviser on international corporate tax and became one of the first members of PwC's global tax controversy and dispute resolution network. Her areas of expertise are APAs, dispute resolution and helping clients engage successfully with HMRC. Diane is now advising on several APAs with some of the world's largest and most well-known businesses across all sectors. In the areas of dispute resolution, Diane advises on both domestic and international cases where she can leverage her excellent relationships with HMRC and other tax authorities.

More recently, she has been working with an increasing number of clients who are looking to move their headquarters or centralise their businesses or move assets in the UK by helping them to obtain certainty on their future tax treatment across a wide range of issues. Diane has maintained her many relationships at senior levels in both HMRC and HM Treasury which give her a special insight into working with tax officials, as well as excellent access to them.

Deloitte UK

Four Brindleyplace

Birmingham, B1 2HZ

UK

Tel: +44 121 695 5722

Email: ojarratt@deloitte.co.uk

Oliver Jarratt is a director with Deloitte UK in the Litigation, Advisory and Settlement (LAS) team, and leads the advisory part of LAS in the United Kingdom.

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 value added tax (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

Anbreen Khan is the head of the dispute resolution group of Deloitte UK, specialising in indirect taxes. She is a partner with Deloitte UK, 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; Everything Everywhere (formerly T-Mobile). Other notable cases include: Marks & Spencer Plc; 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

Jason Marsh joined Deloitte UK in 1991 and has been a partner of the Deloitte UK corporate tax practice in London since 2001. 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 with 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

Since joining Deloitte UK, Edward Morris 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 were the EU APA Guidelines adopted by all 27 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 Guide to the World's Leading Transfer Pricing Advisers since joining Deloitte.

PwC

1 Embankment Place

London WC2N 6RH

UK

Office: +44 (0)20 7213 3238

Email: christopher.p.orchard@uk.pwc.com

Website: pwc.com/taxcontroversy

Chris Orchard is a partner in PwC's tax knowledge and innovation group specialising in indirect taxes (primarily VAT). Chris has been working in indirect tax for 16 years and before that had operational management experience in the leisure industry.

Chris is the lead PwC partner in the Investment Trust Companies case. That case concerns restitution for customers who have suffered VAT that was passed on to them by suppliers and which had been imposed by domestic statutory provisions which breached EU law. Restitution and reimbursement to taxpayers of unlawfully levied taxes is one of Chris's particular interests. Chris has experience of resolution and litigation of indirect tax disputes across a wide variety of industry sectors including both private and public sectors.

Deloitte UK

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 20 7007 6580

Email: trowbotham@deloitte.co.uk

Tom Rowbotham is a tax partner with Deloitte UK, 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 business, 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) the UK revenue authority. 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 regards to the current 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

Deloitte UK

Hill House

1 Little New Street

London, EC4A 3TR

UK

Tel: +44 20 7007 4397

Email: fwalkinshaw@deloitte.co.uk

Fiona is a litigation specialist with more than 20 years' experience of resolving complex commercial and tax disputes. She joined Deloitte UK as a partner in September 2009 to head up the direct tax litigation offering within Deloitte's wider dispute resolution group. She has experience of both domestic and EU tax litigation and has represented clients in the tax tribunals, the domestic courts and the European Court of Justice. She has also had considerable experience of alternative dispute resolution (ADR) methods such as mediation and expert determination.