Australia

680 George Street

Sydney, NSW 2000

Australia

Tel: +61 2 9248 5601

Email: Howard.adams@au.ey.com

Website: www.ey.com

Howard is a partner in EY Australia's tax controversy practice based in Sydney and leads a team of more than 20 professionals who specialise in tax office investigations, revenue disputes, administrative law and taxpayers' rights when under audit. Howard is also the leader of EY's Asia Pacific tax controversy practice and is the managing partner of EY Law.

Howard has practised in this field since 1989 and is a solicitor of the High Court of Australia and a barrister of England and Wales. He has a keen interest in alternative dispute resolution and throughout his career has been involved in numerous mediations and arbitrations locally and internationally.

Howard's team regularly advises corporate clients and high net worth individuals in preparation for revenue authority investigations. The team provides the following services:

• Management of Australian Taxation Office (ATO) risk reviews and audits, including:

• Guidance and practical management of the ATO audit process (including response to information requests and developing protocols and procedures for handling ATO relationships);

• Strategic review of client positions to determine appropriate taxpayer outcomes;

• Testing the strength of technical positions, including reviewing documentation and supporting evidence; and

• Managing the evidentiary process, including maintaining legal professional privilege, accountants' concession and Board Workpaper Concession.

• Assisting taxpayers form a strategic plan to object to assessments and amended assessments and proactively managing the process to ensure that the objection is determined efficiently by the ATO.

• Consideration of alternative dispute resolution options and determining the relevant option that is suitable for the dispute, including informal and formal settlement processes.

• EY has dedicated tax litigation experience, with many disputes resulting in reported decisions of the Australian courts which have shaped the Australian tax landscape. Such decisions include capital gains tax, withholding tax, application of the general anti-avoidance provisions and indirect taxes.

• EY assists taxpayers to develop and manage formal policies and procedures to meet the ATO's 'good tax corporate governance' requirement and manage tax risks.

201 Sussex Street

Sydney NSW 2000

Australia

Tel: +61 2 8266 6858

Email: michael.bersten@au.pwc.com

Website:www.pwc.com.au

Michael Bersten has been a senior partner within the PwC Australia tax controversy practice (tax litigation and tax audits) since founding the practice in 2004. The practice now comprises 30 professionals and eight partners.

Michael leads the PwC global tax controversy and dispute resolution 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 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 Tax 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.

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 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 (APA) 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 agreement.

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

550 Bourke Street

Melbourne, VIC 3000

Australia

Tel: +61 3 9671 7541

Mobile: +61 448 877 085

Email: adezilva@deloitte.com.au

Website: www.deloitte.com

Aldrin is the national leader of Deloitte Australia, an entity which specialises in taxation litigation, alternative dispute resolution and the provision of legal taxation advice to domestic and multinational public companies.

Aldrin has been involved in taxation litigation since the late 1990s and is now involved in several taxation matters that are before the Administrative Appeals Tribunal, Federal Court, Full Federal Court and High Court of Australia. In addition, Aldrin is the lead taxation adviser on several multi-billion dollar transactions.

10 Shelley Street

Sydney, NSW 2000

Australia

Tel: +61 2 9335 8422

Email: jgeale@kpmg.com.au

Website: www.kpmg.com/au

As the head of KPMG's legal and tax services and a partner with KPMG in Australia, Jeremy has extensive commercial tax and legal experience. He previously worked as a barrister specialising in tax and in-house as the GST manager for Qantas Airways.

The combination of his negotiation skills, legal skills, advocacy and commercial experience represents a unique skill set in the tax and legal field.

Jeremy has acted for many of Australia's largest companies, successfully negotiating resolutions to tax disputes and audits across all taxes, including income tax, capital gains tax, superannuation, GST, excise and R&D. He is working with clients at the forefront of cross-border disputes, assisting them to prepare for and manage audits related to the Australian Taxation Office's project on base erosion and profit shifting. While Jeremy has and continues to successfully represent many of his clients in court proceedings, he and his team of tax dispute specialists have been particularly successful in deploying alternative dispute resolution to bring about early and effective resolution of his client's tax disputes. He also works closely with clients as transactions occur, to ensure tax positions are documented and supported by evidence, putting clients in the best position to avoid the possibility of future tax disputes.

Jeremy is an external member of the Australian Taxation Office's public ruling panel, the co-chairman of the Tax Institutes of Australia's GST committee and a member of the Tax Committee of the Law Council of Australia.

550 Bourke

Melbourne 3000

Australia

Direct: +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 is a senior corporate tax partner of Deloitte Australia with more than 34 years' 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 journal as one of Australia's leading practitioners in tax controversy matters. He has specialised in tax controversy for more than a decade at Deloitte where he has successfully acted for a range of high profile clients in respect of ATO audit activity and formal taxation disputes.

Before joining Deloitte, Greg held numerous key leadership roles within the Australian Taxation Office, including assistant commissioner for the 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.

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 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 companies.

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 arrangements.

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

Freshwater Place

2 Southbank Boulevard

Southbank VIC 3006

Australia

Tel: +61 3 8603 0363 (office)

Mob: +61 4 0199 4371 (mobile).

Email: ashley.king@au.pwc.com

Website: pwc.com/taxcontroversy

Ashley is a tax controversy partner with PwC and has more than 25 years' tax experience, including 20 years with the Australian Taxation Office (ATO). Ashley was one of the youngest tax officers to have been promoted to assistant commissioner in the ATO in 2001, and was senior assistant commissioner for Large Business and International Tax division when he left the ATO to join PwC in 2007.

Ashley specialises in advising a broad range of clients in different industries on the strategic management of ATO reviews, audits and disputes, including negotiating settlements and advising on tax audit defence tactics. He also provides advice on complex tax law, administration and tax litigation matters.

Ashley has a deep knowledge of ATO operational policies and decision making processes – including settlements, rulings, audits, access visits, information and assessment powers and the general anti-avoidance rule (GAAR) – and has deep relationships across all levels of 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 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's 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.

Freshwater Place

2 Southbank Boulevard

Southbank Vic 3006

Australia

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

Email: paul.mccartin@au.pwc.com

Website: pwc.com/taxcontroversy

Paul McCartin is a partner in PwC Australia's tax controversy team, specialising in pre-litigation tax dispute resolution across a range of matters and various tax topics.

Paul joined PwC after 12 years working at senior levels of the Australian Taxation Office and uses this experience and significant networks to achieve favourable outcomes for his 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's ATO experience is recognised and highly sought after by clients to assist them to resolve a range of complex disputes.

Paul uses his ATO technical and compliance experience, coupled with his understanding of the 'ATO mindset', to specialise in assisting clients to strategically and effectively manage ATO 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.

Darling Park

201 Sussex Street

Sydney NSW 2000

Australia

Tel: +61 2 8266 9156

Mobile: +61 413 111 161

Email: eddy.moussa@au.pwc.com

Website: www.pwc.com.au

Eddy is a practising tax lawyer with more than 15 years' 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.

Eddy has also advised a number of multinational organisations 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.

Eddy is on the Education Committee of the Tax Institute of Australia and has published papers on taxation anti-avoidance.

Bachelor of business

Bachelor of law

Master's of tax

Solicitor of Supreme Court of NSW

Practitioner of the Federal and High Court of Australia

Registered tax agent in Australia

CTA of the Tax Institute of Australia

2 Southbank Boulevard

Southbank

Melbourne 3006

Australia

Tel: +61 3 8603 4133 / +61 422 004038

Email: simon.rooke@au.pwc.com

Website: 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.

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.

Over the past eight years he has developed 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's 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.

201 Sussex Street

Sydney NSW 2000

Australia

Tel: +61 2 8266 0197

Email: judy.sullivan@au.pwc.com

Website:www.pwc.com.au

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 Tax Office (ATO) Dispute Resolution Working Group. She is also a chartered tax adviser (The Taxation Institute) and on the roll of High Court Legal Practitioners.

Judy is a leading tax lawyer and litigator in Australia. She joined PwC in 2013, and was formerly the tax partner heading up the Sydney tax disputes practice at top tier law firm King & Wood Mallesons.

For 25 years, Judy has guided multinationals, major corporates and high 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 to bring the ATO and taxpayers together to achieve early engagement and resolution of disputes through ADR processes including settlement discussions, mediation and early neutral evaluation. She regularly co-presents with the most senior ATO officers in relation to ADR.

As cross-border transactions are under intense ATO scrutiny, multinationals must prepare to defend potential disputes relating to tax issues, particularly in light of Australia's recent changes to transfer pricing rules (affecting debt financing, international marketing arrangements and intellectual property), international investments, and anti-avoidance rules. Judy has extensive expertise across these topics and other important areas such as resources and private equity.

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 is an international tax and transfer pricing partner and leader of the national transfer pricing practice of Deloitte Australia. 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 Big 4 accounting 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, IP 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 (APAs) 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.