UK

Lower Mosley Street

Manchester, M2 3PW

UK

Tel: +44 (0)161 245 2990

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

Website: pwc.com/taxcontroversy

David Anderson leads the indirect tax team at PwC Legal in the UK. He is listed as an "Up and Coming" individual in Chambers and Partners 2013. He previously spent a period with HM Customs & Excise (now HMRC) 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, Colingrove Limited [2013] UKFTT 116 (TC), Colingrove Limited [2013] UKFTT 312 (TC) and WM Morrisons Supermarket PLC [2012] UKFTT 366 (TC).

David is a regular speaker at tax conferences and seminars and a frequent contributor to the Tax Journal and De Voil's Indirect Tax Intelligence.

David joined PwC Legal in September 2011.

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 (0) 121 695 5011

Mobile: +44 (0) 7775 807510

Email: saustin@deloitte.co.uk

Shaun Austin is a Deloitte UK partner. He has 11 years of experience as a partner, and more than 18 years of experience in transfer pricing.

Since 2007, Shaun has been the partner responsible for the UK regional transfer pricing practice and he has been the leader of the UK national transfer pricing practice since 2009.

Shaun advises a range of clients, particularly focusing on the consumer business and manufacturing sectors. He assists clients relative to all areas of transfer pricing including planning, documentation, controversy, HMRC defence and mutual agreement procedure, and debt pricing.

Shaun is a graduate of Cambridge University and is a member of the Institute of Chartered Accountants in England & Wales (ACA).

PricewaterhouseCoopers Legal LLP

Hays Galleria

1 Hays Lane

London SE1 2RD

UK

Office: +44 (0)20 7804 4059

Mobile: +44 (0)7764 235 336

Email: giovanni.bracco@uk.pwc.com

Website: pwc.com/taxcontroversy

Having worked for HM Revenue and Customs in the UK for 14 years, Giovanni Bracco joined PwC in 2001.

Giovanni specialises in helping PwC's largest corporate clients in resolving disputes and managing their relationships with tax authorities around the world. Giovanni has in recent years focussed on leading the UK's largest dispute resolution projects, cases involving complex finance and treasury, international structuring and transfer pricing issues, with tax at stake in the hundreds of millions of pounds. In the course of his work, Giovanni has built strong relationships with senior officers within HMRC, and has been asked to speak at a number of internal HMRC meetings.

Giovanni strongly believes that when looking at the lifecycle of a dispute (prevention, management, resolution), helping clients in the preventative space is key to assisting clients manage their tax risks and exposures. It is for this reason that Giovanni has recently taken over the leadership of PwC's Tax Risk Assurance network in the UK. The network focuses on helping clients increase their awareness and improve their management of tax risks.

Giovanni is an active member of PwC's Tax Controversy & Dispute Resolution Network (TCDR), and has regularly presented on the subject of global dispute management.

30 Crown Place

Earl Street

London EC2A 4ES

UK

Tel: +44 (0)207 054 2726

Email: james.bullock@pinsentmasons.com

Website: www.pinsentmasons.com

James Bullock is one of the UK's leading tax practitioners and has 21 years of experience advising in relation to negotiations between taxpayers and HMRC with a view to resolving and avoiding disputes. He has considerable experience in particular in relation to large and complex investigations by the UK tax authorities and of handling tax litigation at all levels from the First-tier Tribunal to the Supreme Court. A particular expertise is in successfully resolving disputes where avoidance has been alleged by HMRC. He has been recognised as one of the leading authorities on the new GAAR. James advises extensively in relation to the powers of HMRC and the application of those powers in enquiries and investigations and has advised FTSE companies, professional advisory firms and professional bodies in relation to the exercise of such powers. James also advises in relation to investigations with a view to criminal prosecution both at the investigatory stage and once matters have been passed to the CPS.

Notable cases include: HMRC v Weald Leasing Limited (ECJ, Court of Appeal and High Court); HMRC v Mayes (Court of Appeal, High Court and Special Commissioners); The Queen on the application of Christopher Lunn And Company v Commissioners For Her Majesty's Revenue And Customs (Administrative Court) and Helena Housing Limited v HMRC (Court of Appeal, Upper Tribunal and First-tier Tribunal).

James is recognised as one of the leading tax practitioners in the leading legal directories and has been consistently ranked in band one for many years. He is a regular speaker at conferences and seminars and has written extensively for professional journals. He is a member of the editorial board of Tax Journal, a member of the development board of the Law Faculty at the University of Oxford and former chapter chairman and a member of council of the VAT Practitioners' Group.

1 Embankment Place

London WC2N 6RH

UK

Direct: +44 (0)20 7212 3142

Mobile: +44 (0)7710 737703

Email: stephen.camm@uk.pwc.com

Website: pwc.com/taxcontroversy

Alternative contact: Whitney Foot

Direct: +44 (0)20 7212 5069

Email: whitney.foot@uk.pwc.com

Stephen Camm is a partner at PwC in the UK and leads the firm's tax disclosure and tax transparency team. He is acknowledged as one of the UK's leading experts on information exchange developments and the handling of tax disclosure cases.

For many years Stephen has helped people and businesses, large and small, manage their relationship with HM Revenue & Customs (HMRC). He spent 15 years at HMRC, including spells in the Special Compliance Office and the Large Business Office, before joining PwC.

An expert in negotiation and direct tax enquiry matters with a first class record of helping clients, Stephen has been listed as one of the UK's leading tax controversy experts by International Tax Review several times.

30 Crown Place

Earl Street

London EC2A 4ES

UK

Tel: +44 (0)207 054 2727

Email: jason.collins@pinsentmasons.com

Website: www.pinsentmasons.com

Jason Collins is head of the tax group at Pinsent Masons. As one of the leading contentious tax practitioners in the UK, Jason specialises in the resolution of disputes with HMRC in all aspects of direct tax and VAT. His practice ranges from the resolution of tax technical disputes arising in routine enquiries, through to cases where he represents clients in complex and high value civil investigations by HMRC. He handles litigation from the Tax Tribunal all the way through to the ECJ, and has a particular expertise in managing group litigation.

Jason also advises clients in cases where HMRC uses its criminal investigation powers, including compulsory interviews and dawn raids. He has a particular specialism in the use by HMRC of its information gathering powers, and the sharing of information with foreign authorities, whether under criminal investigation mutual assistance procedures, double tax treaties or tax information exchange agreements. Jason also advises on the implications of the anti-money laundering and corruption legislation, with a particular focus on its impact on tax compliance.

Notable cases include: The Foreign Income Dividends group litigation order; The Compound Interest Project (John Wilkins Limited and others) and Secret Hotels 2 Limited (formerly Med Hotels Limited) v HM Revenue & Customs.

Jason is a committee member of the Chartered Institute of Taxation and the Quoted Companies Alliance. He is consistently top-ranked in Legal 500, PLC Which lawyer? and Chambers, and is described as a "fantastic name in the market".

Hays Galleria

1 Hays Lane

London SE1 2RD

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 (ACA, A.T.I.I, MA (Cantab) Hons) is an international corporate tax partner 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 leads PwC's EU direct tax group, which covers EU law related tax developments. He is also a client tax partner, with a wide range of internationally based corporate clients.

His areas of expertise include tax treaties, OECD developments, EU law, state aid, sovereign immunity, real estate, joint ventures and international tax structuring generally.

Peter's previous experience includes acting as instructing accountant in the advance corporation tax class 2 and 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 cross-border loss relief case (High Court, Court of Appeal, European Court of Justice, First-Tier Tribunal, Upper Tier Tribunal, Court of Appeal and Supreme Court).

Peter chairs the large business and international committee of the Tax Faculty of the Institute of Chartered Accountants in England and Wales (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 and vice chair of the CIOT EU and HR committee.

Peter is the only Big 4 partner 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. Peter is also on the editorial board of the Tax Journal and is a guest lecturer at Queen Mary, University of London and the Institute of Advanced Legal Studies.

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.

2 New Street Square

London EC4A 3BZ

UK

Tel: +44 020 7007 0688

Email: akhan@deloitte.co.uk

Website: www.deloitte.com

Anbreen Khan is the head of the indirect tax dispute resolution team for Deloitte UK. Anbreen is a partner in the London office with 13 years of experience in dealing with contentious indirect tax issues.

Anbreen is a qualified lawyer and advises a number of FTSE 250 clients working across a number of industry sectors. In addition, she has advised on a number of successful landmark VAT cases at the European Court of Justice (ECJ), including the Marks & Spencer VAT litigation, the Association of Investment Companies litigation, and The Rank Group's £100m ($151.9 million) challenge in respect to unlawful taxation of gaming machines based on the EU principle of fiscal neutrality.

Anbreen won The Rising Star award 2008 at the UK Tax Journal indirect tax awards.

Anbreen is a regular speaker and regularly contributes to debate on a number of significant tax disputes. She is a qualified barrister in England and Wales and an affiliate member of the Institute of Chartered Accountants England and Wales.

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, Managing Corporate Risks Programme and collaborative dispute resolution processes and governance frameworks.

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, requested information from taxpayers and made external referrals across all aspects of industry.

As Tom's main focus is advising clients on dealings and interactions with HMRC, his experience of working on both the side of the inspector and of the client is invaluable in providing practical commercial strategies. At the moment 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 favourable 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 the UK and other jurisdictions under tax information exchange agreements.

Hill House

1 Little New Street

London EC4A 3TR

UK

Tel: +44 20 7007 0761

Email: gmsalmond@deloitte.co.uk

Giles Salmond heads the alternative dispute resolution (ADR) tax practice of Deloitte UK and is a Centre for Effective Dispute Resolution (CEDR) accredited mediator.

In 2011, he initiated the first tax mediation and since then has acted as a mediator in many VAT and direct tax disputes. Deloitte now has eight CEDR accredited mediators in the UK which mirrors HM Revenue & Customs' desire to use ADR to solve a wide range of tax disputes.

Giles is a qualified barrister and solicitor-advocate and has many years of experience in tax litigation. He has advised a wide range of UK corporates and multinationals in taking complex tax litigation through the UK court system from the First-tier Tribunal to the UK Supreme Court and to the European Court of Justice.

201 Bishopsgate

London EC2M 3AF

UK

Tel: +44 20 3130 3811

Fax: +44 20 3130 8951

Email: psteiner@mayerbrown.com

Website: www.mayerbrown.com

Peter Steiner is an experienced tax adviser who represents clients across a broad range of transactions, including real estate transactions, company and business sales and acquisitions, corporate reorganisations, and joint ventures, as well as international finance transactions involving cross-border tax planning. Peter's practice extends to the tax implications of projects generally, including global funds, and he advises clients on numerous questions regarding VAT.

Peter has significant experience in negotiating and litigating tax disputes, including transfer pricing inquiries. He has acted in landmark cases, such as EMI Group Electronics Limited v Coldicott, concerning the tax treatment of termination payments to employees; and the challenge by major UK electrical retailers, rental companies, and insurance companies concerning the legality of the higher rate of insurance premium tax on domestic electrical appliance (warranty) insurance.

Following a successful career as an economist in the pharmaceuticals industry, Peter retrained as a lawyer and joined Mayer Brown International in 1986.

Regularly listed as a leading individual by the legal directories, Peter "is very practical and has a very sharp mind with a keen eye for tax planning," according to clients (Chambers UK 2012). He is "very innovative" (Legal 500 2011); a "talented operator" (Chambers UK 2011); "well regarded by clients and peers alike" (Legal 500, 2010). Peter is "always looking for the best and quickest solution to a problem." Described as a "safe pair of hands" he is especially strong on property taxation notes Chambers UK 2010. Peter has again been ranked as a leading individual by Chambers & Partners UK Directory 2009, he earns plaudits for providing "excellent advice, thanks to his keen sense of judgement and ability to find the quickest way through difficult deals."

2 New Street Square

London

UK

Tel: +44 20 7007 4397

Email: fwalkinshaw@deloitte.co.uk

Website: www.deloitte.com

Fiona Walkinshaw is a litigation specialist with more than 20 years of experience in 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 methods such as mediation and expert determination.

6 Hay's Lane

London SE1 2HB

UK

Tel: +44 (0) 20 7804 1455

Email: m.whitehouse@pwclegal.co.uk

Website: pwc.com/taxcontroversy

Mark Whitehouse heads the tax litigation team at PwC Legal. He is one of the UK's leading specialists in contentious tax, having been in practice for more than 20 years. He is listed as a Band 1 leading individual (one of nine in the UK) in Chambers and Partners 2013.

He has particular expertise in the interaction of EU law with UK tax principles, tax planning challenges and judicial reviews. He was also involved in taking the only substantive transfer pricing case that has been litigated in the UK to date.

A large part of his practice is working with clients and HM Revenue & Customs (HMRC) to settle tax disputes before they reach court and in this context, he has been involved in a number of very high-value negotiations settling some billion pound plus disputes.

Reported cases include Lansdowne v HMRC [2011] EWCA Civ 1578, DSG Retail Ltd v HMRC [2009] UKFTT 31 (TC), the Stamp Taxes GLO, R (The Minister for Economic Development of the States of Jersey) v HMRC [2012] EWHC 718 (Admin) and Vocalspruce Ltd v Revenue & Customs [2012] UKFTT 36 (TC).

Mark is a Centre for Effective Dispute Resolution accredited mediator and has experience of alternative dispute resolution.

Mark trained and qualified with Allen & Overy and he spent a period with HMRC Solicitor's Office where he conducted cases on behalf of HMRC. He joined PwC Legal in 2009.

7 More London Riverside

London SE1 2RT

UK

Tel: +44 20 (0) 7804 1938

Fax: +44 20 (0) 7804 4447

Email: simon.wilks@uk.pwc.com

Website: pwc.com/taxcontroversy

Simon Wilks is the leader of PwC's tax dispute resolution network in the UK.

Simon spent 11 years as an Inland Revenue inspector where, amongst other jobs, he was an investigator in the Inland Revenue Special Compliance Office (now Special Civil investigations) where he specialised in the investigation of tax avoidance.

Simon joined PwC in 1999 and became a partner in 2005. Simon spends most of his client time working with large corporates, mainly helping them deal with and resolve difficult enquiries.

He has led a number of significant and successful negotiations with HM Revenue & Customs (HMRC) as part of the High Risk Corporates Programme. Simon has also acted as a mediator on several difficult mediations with HMRC's alternative dispute resolution (ADR) process.

Simon has also led PwC's response to the Senior Accounting Officer rules and has helped many large corporates deal with the HMRC risk process.