Australia

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. He remained leader of the practice – which now comprises 30 professionals and six partners – until 2011.

Michael co-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 tax policy panel as well as being a member of the firm's global tax policy core group.

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 Craig leads Deloitte Australia's cross-border tax practice – a team with more than 120 full time specialist practitioners in the areas of transfer pricing, international tax, M&A and stamp duty.

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 a particular focus on the energy and resources, technology and pharmaceutical sectors.

10 Shelley Street

Sydney, NSW 2000

Australia

Tel: +61 2 9335 8422

Email: jgeale@kpmg.com.au

Website: www.kpmg.com/au

As a partner with KPMG Tax Law, and a partner with KPMG in Australia, Jeremy has extensive commercial tax and legal experience. He previously worked as a barrister specialising in tax law, a solicitor in a large national firm, and GST manager at Qantas Airways.

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

Jeremy has acted as counsel in a range of tax cases involving: income tax, capital gains tax, superannuation, GST, excise and R&D.

Jeremy is an external member to the Australian Taxation Office's public ruling panel and a member of the Taxation Institute of Australia's GST committee and of the Tax Committee of the Law Council of Australia.

Deloitte Touche Tohmatsu

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

Greg Janes is a senior corporate tax partner of Deloitte Australia with more than 32 years of experience in income tax.

Greg has achieved national prominence as an adviser in relation to complex tax controversy matters. He has specialised in tax controversy for more than ten years at Deloitte where he has successfully acted for a range of multinational clients in respect of Australian Taxation Office (ATO) audit activity and formal tax disputes.

Before joining Deloitte, Greg held numerous key leadership roles within the ATO 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.

Deloitte Touche Tohmatsu

550 Bourke

Melbourne 3000

Australia

Tel: +61 3 9671 7538

Email: asking@deloitte.com.au

Ashley King is the lead tax controversy partner with Deloitte Australia. He has more than 25 years of tax experience including 20 years with the Australian Taxation Office (ATO).

Ashley has advised more than 200 clients on their rights, obligations and strategies for responding to ATO reviews and audits and provides strategic advice on complex tax law, administration and tax litigation matters. He has also helped many clients obtain ATO rulings and favourable settlement outcomes following risk reviews and audits.

Before joining Deloitte, Ashley held senior leadership roles within the ATO including several years as senior assistant commissioner in the ATO's Large Business and International Tax Division. He had responsibility for providing rulings and conducting examinations and audits of Australian and foreign-owned multinational companies. He was involved in cross-jurisdiction projects on tax avoidance arrangements and negotiated several large audit and dispute settlements.

Ashley also spent several years in the ATO's International Tax Division and High Wealth Individuals Taskforce and represented the ATO at the OECD, Federal Parliament, Australian tribunals and courts, cross-jurisdiction revenue authority meetings and conferences.

Ashley specialises in advising large corporates, SMEs and high wealth individuals on the management of ATO information notices, risk reviews, audits and disputes, particularly when they are grappling with complex or potentially significant tax issues. Ashley has a deep knowledge of ATO operational policies and decision making processes – including access powers, settlements, rulings, audits, assessment powers and the general anti-avoidance rule panel – and has excellent relationships with many senior ATO officers.

Ashley is regularly quoted in the Australian media and regularly delivers technical papers at Australian tax conferences. He is also a registered tax agent, a chartered tax adviser, an associate of the Institute of Chartered Accountants of Australia and a member of the ATO's dispute resolution consultative committee.

Level 25 & 26

Riverside Centre

Brisbane 4000

Australia

Tel: +61 416 061 816

Email: dlewis@deloitte.com.au

Dave Lewis joined Deloitte in November 2002 after a career in the Australian Taxation Office (ATO) spanning 38 years.

Dave is best known for his work on transfer pricing. In 1994 he was appointed ATO assistant commissioner for international compliance and strategy. The key task of this position was as Australia's competent authority where he had responsibility for international relationships, exchange of information and the mutual agreement procedures (MAP).

Dave led Australia's delegation in key international meetings such as the Pacific Association of Tax Administrators (PATA), the OECD's Working Party 8 on Tax Avoidance and Evasion and the OECD Forum on Harmful Tax Practices.

Dave also had responsibility for the ATO's transfer pricing programme. He chaired the national tax liaison group (transfer pricing sub-committee). This forum allowed transfer pricing practitioners to have input into ATO policy and practice.

He introduced changes in procedure that have made the advance pricing agreement (APA) programme more user-friendly. These changes and his personal promotion of the APA programme led to a substantial increase in the number of companies seeking and successfully concluding APAs. He also introduced quality control measures on proposed audit adjustments and APAs to ensure that they aligned with the ATO's published view. The transfer pricing compliance strategy he introduced still forms a key component of the current ATO approach.

In respect of MAPs, Dave personally led many of the negotiations with other tax authorities on double tax cases, especially those with the US and Japan. He achieved considerable success in alleviating double taxation and settling bilateral APAs.

Dave was also instrumental in considerably reducing the time frame to achieve consensus. He changed ATO practice to ensure that taxpayers were kept informed and as far as possible involved in the progress of their MAP and bilateral APA cases. His leadership fostered confidence in the ATO's capacity to achieve fair outcomes in these settlements.

Since joining Deloitte Dave has played a key role in resolving audit and APA cases. His understanding of the approach of the ATO and other tax administrations to significant transfer pricing issues has been invaluable in achieving the best outcome for our clients. The knowledge he has transferred to Deloitte personnel has improved the capability of our practice to deliver quality advice to clients and to successfully advocate our clients' position in MAP and APA applications

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 the Australian Tax Office (ATO) NTLG Dispute Resolution Subcommittee, as well as being a chartered tax adviser and on the roll of High Court Legal Practitioners.

She is a leading tax lawyer and litigator in Australia. She joined PwC in January 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 clients through tax reviews, audits, negotiations and litigation. She has run or worked on seminal Australian tax cases in the Administrative Appeals Tribunal, Federal Court and High Court: on anti-avoidance rules (Consolidated Press, CPH Property, RCI); GST (Travelex, Sterling Guardian) and other income tax matters (McNeil, BHP Billiton, Consolidated Media). 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

152-158 St Georges Terrace

GPO Box A46

Perth 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. He has led 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 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 Expert 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, forums and a contributor to various tax and industry publications.