Transfer Pricing Forum features Transfer Pricing experts from more than 20 countries and provides unique, country-specific solutions to complex technical Transfer Pricing problems.
Andrew Cousins -Editorial Board Member and Panelist for United Kingdom
Director, Duff & Phelps, London
Andrew Cousins is an international tax practitioner in the Duff & Phelps Transfer Pricing practice, with more than 20 years of cross-border experience in private practice, industry and in government. He brings a comprehensive regulatory, commercial and advisory perspective to the fields of transfer pricing and business restructuring, with a focus on practical implementation. Before joining Duff & Phelps Andrew was Deputy Comptroller of Taxes in the Jersey tax authority, acting as competent authority for all of Jersey's international tax agreements. He also served as Jersey's delegate to the Global Forum on Transparency and Exchange of Information for Tax Purposes, as well as representing Jersey at the OECD's Global Forums for Transfer Pricing and for Tax Treaties. Andrew spent eight years in industry as a global head of transfer pricing, and has led the transfer pricing practice in two FTSE 100 FMCG multinationals.
Andrew is a graduate of Oxford University and is a fellow of the Institute of Chartered Accountants in England and Wales. He qualified as a chartered accountant at Deloitte before focusing on transfer pricing at Ernst & Young, where he was a member of its Tax Effective Supply Chain Management team.
Patrick McColgan - Editorial Board Member and Panelist for United States
Managing Director, Duff & Phelps LLP, Atlanta
Patrick McColgan is a managing director in Duff & Phelps' Atlanta office and part of the transfer pricing team. He has a strong focus on assisting growth companies with their global transfer pricing needs through the design of defensible and pragmatic solutions. Patrick has more than 11 years of transfer pricing experience and has worked across several industries, including automotive, chemical, consumer products, medical products, pharmaceutical, software, internet, and manufacturing.
Mayra Lucas Mas, Editorial Board Member
Advisor, Tax Treaty, Transfer Pricing & Financial Transactions Division, Centre for Tax Policy and Administration, OECD, Paris
Mayra Lucas Mas has been an advisor at the Centre for Tax Policy and Administration Tax Treaty, Transfer Pricing and Financial Transactions Division since June 2008. She is responsible for chairing bilateral and multilateral transfer pricing events in non-OECD countries with her primary focus being the implementation of legislation in the transfer pricing area. In the past she has worked as a senior consultant for the transfer pricing group of a leading accounting firm and in the Taxation and Customs Union unit of the European Commission.
Mayra is a graduate of New York University School of Law (LLM), the University of Barcelona (Ph.D in Tax Law and Law Degree.)
Rahul Mitra - Editorial Board Member and Panelist for India
Partner and Head of Dispute Resolution & Litigation for Transfer Pricing, KPMG India
Rahul K Mitra is currently a partner in the tax & transfer pricing practice of KPMG India; and is the national leader of dispute resolution & litigation in the fields of transfer pricing & international taxation. Prior to joining KPMG India, Rahul was the national leader of PwC India’s transfer pricing practice between 2010 and 2014. Rahul was a partner in the tax & regulatory services practice of PwC India between April 1999 and February 2015.
Rahul has over 22 years of experience in handling taxation & regulatory matters in India. He specializes in transfer pricing, particularly inbound & outbound planning assignments, and advises on profit/cash repatriation planning; value chain transformation or supply chain management projects; profit attribution to permanent establishments, etc. Rahul independently handles litigation for top companies at the level of the Income Tax Tribunals. At least 50 of the cases independently argued by Rahul have been reported in leading tax journals of India. Some of the major wins of Rahul before the Tax Tribunals in transfer pricing matters have set precedents, both in India and globally.
Rahul has been consistently rated as amongst the leading transfer pricing professionals & tax litigators in the world, by Euromoney and International Tax Review, since 2010.
In his personal capacity, Rahul has handled several APAs in India, involving clients from across industries; and also covering complex transactions, e.g. industrial franchise fees/variable royalties under non-integrated principal structures; contract R&D service provider model; distribution models, with related marketing intangible issues; financial transactions; profit split models for royalties; etc.
Rahul is a Member of the Global Editorial Board of the Magazine, “Transfer Pricing Forum”, published by think and code. He has been a visiting faculty of the National Law School in the subject of transfer pricing & international tax treaties.
Rahul was the country reporter on the topic, “Non Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008. Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.
Dirk van Stappen - Editorial Board Member and Panelist for Belgium
Partner, KPMG, Belgium and member of the EU Joint Transfer Pricing Forum
Dirk Van Stappen is a Partner with KPMG in Belgium. He joined KPMG in 1988 and has over 20 years of experience in advising multinational companies on corporate tax (both domestic and international) and transfer pricing issues. He leads KPMG’s transfer pricing practice in Belgium. Dirk Van Stappen has also been appointed in 2002 (and reappointed in 2007) as one of the 10 (15 as from 2007) European business representatives of the EU Joint Transfer Pricing Forum of the European Commission.
Dirk has been named in International Tax Review’s “World Tax –The comprehensive guide to the world’s leading tax firms”, Euromoney’s (Legal Media Group)“Guide to the World’s Leading Transfer Pricing Advisers” and Euromoney’s “Guide to the World’s Leading Tax Advisers”.
He is a certified tax adviser and member of the Belgian Institute for Accountants and Tax Advisers (IAB) and of the International Fiscal Association (IFA).
Yves de Groote
Partner, KPMG, Antwerp
Yves de Groote has an LL.M from King's College London, MSc. HUB; he joined KPMG in 2004 and has over 10 years of experience in advising multinational organizations on transfer pricing issues. He has been involved in and conducted various tax planning and transfer pricing assignments, ranging from the preparation of European and global transfer pricing documentation (including functional and economic analyses and comparables searches) and domestic and international transfer pricing audit defense to the negotiation of (uni-, bi-, and multilateral) rulings and advance pricing arrangements (APAs).
Cristian Rosso Alba
Mitrani, Caballero, Rosso Alba, Francia, Ojam & Ruiz Moreno Abogados, Buenos Aires
Cristian Rosso Alba has a well recognised experience in Tax Law, with particular emphasis in domestic and international tax planning, restructurings, reorganisations and international business transactions. He leads the Tax Law practice of Mitrani, Caballero, Rosso Alba, Francia, Ojam & Ruiz Moreno Abogados.
Additionally, Mr. Rosso Alba has been a regular lecturer in the United States and speaker in domestic and international tax conferences and is the author of more than eighty articles appearing in specialised publications. Cristian Rosso Alba is a member of the American Bar Association (ABA), Harvard Club of Argentina, the Canadian Tax Foundation and the Advisory Board of the Argentine Chamber of Commerce. Mr. Rosso Alba has been recommended as one of the “Leaders in their Field” (Tax - Argentina) by Chambers Latin America.
Director, Duff & Phelps, Australia
Stean Hainsworth is the Director of Transfer Pricing at Duff & Phelps based in Australia and has over 20 years of legal and tax experience, specializing in transfer pricing. Previously he was a director of an international transfer pricing firm, the transfer pricing leader for Asia at a global advisory firm, and a senior transfer pricing specialist for a Big Four firm in New Zealand, Canada, and Australia.
Global Partner for Asia Pacific, Transfer Pricing Associates, Sydney
Douglas Fone has a long background in Big 4 firms, providing international tax and transfer pricing services since 1987 in London, Hong Kong, Singapore and Sydney. He has been devoted exclusively to Asia Pacific international tax and transfer pricing consultancy since 1991. Doug joined the global independent specialist firm Transfer Pricing Associates (TPA) in 2005 to lead the development of the business in the Asia Pacific region, and is now a partner of the global firm. TPA has grown to become the leading independent specialist transfer pricing firm in Asia, and has coverage in over 30 countries around the world.
Tax Director, BDO Austria GmbH, Vienna
Alexandra Dolezel is a tax director at BDO Austria GmbH in Vienna, Austria. She has over 22 years of experience and specializes in international taxation and transfer pricing. Her expertise includes the conceptual design of international tax structures and business models, defense in tax audits, litigation, and mutual agreement procedures, as well as the optimization of value chains from a transfer pricing point of view. In addition, she is a lecturer on European Union tax law and comparative tax law at FH Campus Wien, the largest university in Austria. Previously, she was Head of Corporate Taxes for Borealis AG, where she had overall responsibility for group corporate tax, including matters affecting tax risk management, transfer pricing, and international structures. Alexandra received her education at the Vienna University of Economics and Business Administration, and she is also a member of the Austrian Chamber of Accountants.
Jerry Levers de Abreu
Partner, TozziniFreire Advogados, Sao Paul
Jerry Levers de Abreu is a Partner at TozziniFreire Advogados, Sao Paulo. A specialist in tax law, Jerry has over 18 years of experience in tax consulting and administrative litigation. He counsels both domestic and foreign clients, with an emphasis on indirect taxes and taxation in the automotive, information technology, telecommunications, intellectual property, food, and cosmetics sectors. Prior to building his tax practice at TozziniFreire, Jerry worked as a tax manager in global audit and consulting companies. He is recognized as an Indirect Tax Leader by the International Tax Review and recommended by The Legal 500 and Best Lawyers. Jerry's education includes a law degree from Universidade São Francisco and a specialized degree in Tax Law from Pontifícia Universidade Católica de São Paulo. He frequently publishes articles on tax law in major national publications.
Partner, Deloitte LLP, Toronto
Richard Garland is a partner in the Toronto office of Deloitte. He is a Chartered Professional Accountant and has over 25 years of accounting experience focused in the area of corporate international taxation. Richard has assisted clients in all aspects of international taxation, with particular emphasis on tax treaty issues, cross-border financing structures, and transfer pricing. Over the past several years, Richard's work has been focused in the area of transfer pricing, and he has been repeatedly recognized in Euromoney’s guide to leading transfer pricing practitioners.
Partner-in-Charge for China and the Hong Kong SAR, KPMG, Shanghai
Based in Shanghai, Cheng Chi is the partner-in-charge of KPMG’s Global Transfer Pricing Services for China and Hong Kong S.A.R. Mr. Chi has led many transfer pricing and tax efficient supply chain projects in Asia and Europe, involving advance pricing arrangement negotiations, cost contribution arrangements, Pan-Asia documentation, controversy resolution, global procurement structuring, and headquarters services recharges for clients in the industrial market including automobile, chemical, and machinery industries, as well as the consumer market, logistic, communication, electronics and financial services industries.
In addition to lecturing at many national and local training events organised by the Chinese tax authorities, Mr. Chi has provided technical advice on a number of recent transfer pricing legislative initiatives in China. A frequent speaker on transfer pricing and other matters, his analyses are regularly featured in tax and transfer pricing publications around the world （i.e. International Tax Review). Mr. Chi has been recommended as a leading transfer pricing advisor in China by the Legal Media Group.
Mr. Chi started his transfer pricing career in Europe with another leading accounting firm covering many of Europe’s major jurisdictions while based in Amsterdam until returning to China in 2004.
Arne Møllin Ottosen
Partner and Head of Tax Law, Kromann Reumert, Copenhagen
Arne Møllin Ottosen is Head of Kromann Reumert’s tax law group. He specialises in contentious tax including transfer pricing, tax litigation and business taxation advisory work. Arne is the author of numerous Danish and international articles on tax and company law.
Arne is listed in the International Tax Review, European legal 500 and Chambers. He holds a Law degree, Aarhus University (cand.jur. 1993). LL.M., King’s College, University of London (1999).
Attorney, Kromann Reumert, Copenhagen
Casper Jensen is an attorney and a member of Kromann Reumert's tax law group. He specializes in corporate and international tax matters. Casper is the author of numerous articles on international taxation. He holds a law degree from the University of Copenhagen (cand.jur. 2013).
Tax Partner, Delsol Avocats, Paris
Julien Monsenego specializes in international taxation, tax treatment of M&A, and restructurings. He assists French and foreign companies in their international investments, as well as in the course of their tax audits and litigations. He particularly focuses on Life Science and R&D-intensive industries. He has extended the practice of transfer pricing and has intervened for French and non-French groups in setting up intra-group flows, IP companies, and business restructurings.
Julien Monsenego previously worked at Gowling WLG, Olswang, Arthur Andersen International, Ernst & Young, Coudert Brothers, and Dechert LLP. He is a member of the Paris Bar.
Principal (Transfer Pricing), NERA Economic Consulting, Paris
Guillaume Madelpuech holds an MBA from the ESSEC Business School and an MSc in Economics from the Paris Dauphine University. He is a principal within NERA Economic Consulting in Paris. He is an economist with 10 years of experience in transfer pricing, including in particular intangible valuation, business restructuring, transfer pricing policy design, and litigation. Guillaume has conducted a number of transfer pricing projects for multinationals in a wide range of industries, including high-tech, consumer goods, automotive, luxury goods, financial services, health care, real estate, media and entertainment, and energy. He is a regular contributor to the OECD and a frequent contributor to journals and trade publications. Prior to joining NERA, Guillaume was an economist with EY in both Paris and in New York City in the transfer pricing and valuation groups.
Chairman, NERA Economic Consulting, Frankfurt
During more than 25 years advising international corporations and leading law firms on transfer pricing issues, Alexander Voegele has specialised in the development of innovative economic structures for transfer pricing strategies and for the defense of major international transfer pricing cases. He has led hundreds of large transfer pricing projects and defense cases for a variety of clients in a range of industries. Prior to joining NERA, Dr Voegele was a partner with PriceWaterhouse and KPMG, where he was in charge of their German transfer pricing practice.
He holds a doctorate in economics and a Master of tax and business administration from the University of Mannheim. He is a certified German auditor and tax adviser and is a French Commissaire aux Comptes.
He has received numerous awards as a transfer pricing adviser and has frequently been ranked as a leading tax and transfer pricing professional.
Philip de Homont
Senior Consultant/Principal, NERA Economic Consulting, Frankfurt
Philip de Homont specializes in complicated transfer pricing audits and the valuation of intellectual property for international corporations and law firms. He has defended major transfer pricing cases throughout Europe and the Americas in a wide range of industries from consumer goods to financial services.
He holds a MSc in Economics from the University of Warwick and a Masters-equivalent in Physics from the Technische Universität München.
Philip de Homont is the co-author of dozens of articles and two books on transfer pricing and intellectual property valuation. He has participated in various transfer pricing conferences.
Director, KPMG Global Transfer Pricing Services, Hong Kong
Irene Lee has practiced tax for 11 years, the last 7 specializing in transfer pricing matters involving the financial services sector. She joined KPMG in Hong Kong in 2013 and advises banking, asset management, and insurance clients on transfer pricing policies, documentation, and risk management in the Asia region. She earned a Bachelor of Business Administration (B.B.A.) degree from the Chinese University of Hong Kong and has studied at the University of North Carolina (Chapel Hill).
Senior Manager, KPMG Global Transfer Pricing Services, Hong Kong
Jeffrey Wong is a senior manager of Global Transfer Pricing Services at KPMG in Hong Kong. He is an experienced financial services transfer pricing advisor and works with clients from the banking, insurance, and asset management sectors. Jeffrey joined KPMG in Hong Kong in 2014 and has been based in Hong Kong for over seven years. He also worked as a transfer pricing specialist in New York for over two years. He holds a Bachelor of Science in Finance and International Business (Magna Cum Laude) from the NYU Stern School of Business.
Partner, Matheson, Dublin
Catherine O'Meara is a partner in the tax department at Matheson. Catherine has over ten years' experience advising multinational corporations doing business in Ireland on Irish corporate tax. Catherine has a particular interest in transfer pricing, competent authority matters, and business restructurings and also has extensive experience in structuring inward investment projects, mergers and acquisitions, and corporate reorganizations. Catherine's clients include many of the leading multinational corporations established in Ireland, primarily in the pharmaceutical, healthcare, ICT, and consumer brand sectors. Catherine has published articles in leading tax journals. She is a co-author on the Ireland section of the think and code Transfer Pricing Forum and a co-author of the Ireland chapter of the International Fiscal Association Cahiers on Cross Border Business Restructuring.
Catherine is a Chartered Tax Advisor and a member of the Law Society of Ireland.
Head of Transfer Pricing at Lion Orlitzky & Co. – Moore Stephens Israel
Yariv Ben-Dov is Head of Transfer Pricing at Lion Orlitzky & Co. – Moore Stephens Israel. Prior to that, he was Head of the Transfer Pricing and Valuations Department at Herzog, Fox & Neeman. He is an expert in drafting and defending transfer pricing studies and intercompany agreements, with over 15 years of experience. Yariv counsels both multinational conglomerates and small start-ups on their transfer pricing matters, including multinationals which have no activity in Israel. Before working at HFN, Yariv was a co-founder of Bar-Zvi & Ben-Dov, a boutique law firm specializing in transfer pricing and high-tech and, before that, Yariv served as the Head of the Transfer Pricing Unit at Teva Pharmaceuticals. Yariv has published articles on the subject of transfer pricing and has been asked to keynote as an expert in transfer pricing at several conventions in Israel, Europe, and the U.S. Yariv is a member of Transfer Pricing Associates, the world's largest network of independent transfer pricing experts; the Israeli Bar Tax Committee; and the Board of the Israeli-LATAM Chamber of Commerce. Yariv is also a Board member of the Arthur Rubinstein Music Society and the head of the Society's NYC branch. Yariv provides counsel (pro bono) to the Israeli Navy Association. Yariv speaks Hebrew, English, French, and Italian and has often advised global clients in their local language.
Partner, Maisto e Associati, Milan
Aurelio Massimiano is a partner at Maisto e Associati, where he has practiced since 2005, after having worked for the International Tax Office of the Italian Revenue Agency and, prior to that, for a Big 4 accounting firm. His areas of expertise are international taxation and transfer pricing. He is the permanent assistant of Professor Guglielmo Maisto at the EU Joint Transfer Pricing Forum. A member of the Association of Chartered Accountants, he holds degrees from Luiss Guido Carli University in Rome and an LL.M. in International Tax Law from the University of Leiden in the Netherlands.
Partner, Maisto e Associati, Milan
Marco Valdonio was admitted to the Association of Chartered Accountants in 2002. He joined Maisto e Associati in 2000 after working for another tax law firm. He headed the London office from 2002 to 2004 and has been a partner in the firm since 2011. Marco's areas of expertise include transfer pricing, tax controversies and settlements, mergers and acquisitions, financial instruments, and international taxation.
Associate, Maisto e Associati, Milan
Mirko Severi joined Maisto e Associati in 2011 after obtaining a Master Diploma in Tax Law at IPSOA. He graduated (cum laude) in Economics from the University of Parma in 2010. His areas of expertise include corporate taxation and group taxation.
Cosmos International Management Co., Ltd
Takuma Mimura is Managing Director of Cosmos-International Management, a transfer pricing boutique consulting firm in Japan. He has more than 14 years of transfer pricing experience, including 6 years at Deloitte Touche Tohmatsu (both Tokyo and New York), and international banking experience prior to transfer pricing. He has worked extensively with transfer pricing issues worldwide and is especially experienced in Japan, U.S. and China TP matters. He has also worked with a broad range of clients in manufacturing, financial services and telecommunications and has assisted many taxpayers in negotiations with the Japanese tax authorities on transfer pricing audit examinations.
Takuma has authored articles for professional journals including think and code Transfer Pricing Report and Monthly International Taxation of Japan, and is a frequent speaker on transfer pricing topics.
Moises Curiel Garcia
Principal-Director of the Latin American Transfer Pricing Practice, Baker & McKenzie, Mexico City
Moisés Curiel is a member of the Firm’s Transfer Pricing Practice Group. He is recognised by International Tax Review as one of Mexico’s top tax advisers, and has served as the Transfer Pricing Audits and Resolutions administrator of Mexico’s Ministry of Finance and Public Credit for seven years. Mr. Curiel helped prepare and implement various tax transfer pricing rules in Mexico, including the Income Tax Law, the Omnibus Tax Ruling and the Federal Tax Code. He also led the Advance Pricing Agreements Program in Mexico, where he negotiated over 300 unilateral agreements and 34 bilateral agreements. His impressive track record also includes proposing amendments to legislation on various matters for Latin American countries, and representing Mexico before the OECD for the transfer pricing party (WP6).
Tax Partner and Head of the Transfer Pricing Team, Loyens & Loeff, Luxembourg
Peter Moons is a partner in the tax practice of Loyens & Loeff Luxembourg since 2004, with a focus on corporate tax advice for multinationals and funds and, in particular, private equity funds, their initiators, and their investors. Before joining the Luxembourg office in 2004, he practiced in the Rotterdam and Frankfurt offices of Loyens & Loeff, specializing in real estate funds and cross-border tax structuring. Peter is also active in the Loyens & Loeff German and Eastern European desks and heads the Luxembourg transfer pricing team. Peter is a member of the Luxembourg Bar, the International Fiscal Association (IFA), and the tax committee of the Luxembourg Private Equity and Venture Capital Association. Peter is the author of the Tax Management Portfolio, Business Operations in Luxembourg, published by Tax. He received a Business economics and tax law degree from Erasmus University in Rotterdam in 1996 and a Tax law degree from University of Cologne in 1997.
Gaspar Lopes Dias
Tax Advisor and Transfer Pricing Specialist, Loyens & Loeff, Luxembourg
Gaspar Lopes Dias is an associate in the tax practice group of Loyens & Loeff Luxembourg. He specializes in international taxation and transfer pricing, Gaspar advises on financial transactions (e.g., cash pool, debt pricing) and intragroup services. Prior to joining Loyens & Loeff Luxembourg, Gaspar worked at a big 4 company in Belgium, having gained experience in several industries and in a broad range of transfer pricing matters, including TP documentation, IP structuring and arm's length license fees, relocation of functions, MAP/EU Arbitration Convention, and EU State Aid rules on transfer pricing. He received a degree in Advanced Transfer Pricing from ITC Leiden, an Advanced LL.M. in European and International Taxation from Tilburg University, and a law degree from Nova University of Lisbon.
Partner, Ernst & Young Belastingadviseurs LLP, Amsterdam, Netherlands
Danny Oosterhoff is a partner at Ernst & Young Belastingadviseurs LLP. He has specialized in transfer pricing services since 1996 and has worked both in the Netherlands and the United States. He has worked with many multinational enterprises in the broader field of transfer pricing planning, including risk and controversy management. His experience covers a wide range of industries, including the chemicals, pharmaceutical, high-tech and technology, consumer products, media, and telecommunication sectors. He has been involved in a significant number of advance pricing agreements, both on a unilateral and multilateral level and has been involved in many mutual agreement procedures with many different countries across the European, Asian, and American continents. He has also effectively used APAs and rollback mechanisms to resolve transfer pricing disputes.
He works with many companies on transfer pricing risk management to assist in defining the overall transfer pricing policy, the corporate transfer pricing function, and associated processes for ensuring sustainable and manageable transfer pricing models. Danny has also worked with many international companies on the transfer pricing aspects of acquisitions and divestures. For many multinational enterprises, he has assisted in the field of due diligence and post-merger integration of transfer pricing policies, establishing arm's length financing conditions, and integration of operating models.
Danny regularly speaks at forums and events about transfer pricing, business restructuring, and international developments in taxation, including BEPS and state aid. He holds a degree in tax law from the University of Tilburg.
Managing director, TP EQuilibrium | AustralAsia LP (“TPEQ”)
Leslie Prescott-Haar is the managing director of TP EQuilibrium | AustralAsia LP (”TPEQ”) (formerly, Ceteris New Zealand). TPEQ provides transfer pricing services in Australia and New Zealand across an extensive range of industries, transactions, and engagements, including APAs; independent second opinions and expert advice; tax authority reviews, investigations, and audit defense; global, regional, and country-specific documentation. Leslie has over 22 years of specialized transfer pricing experience based in the APac Region (Sydney and Auckland) and an additional 10 years of corporate taxation experience in Big Four accounting firm practices, specializing in mergers, acquisitions, bankruptcies, and reorganizations based in the United States (New York City and Chicago). Prior to forming TPEQ, Leslie commenced the transfer pricing practice of Ernst & Young New Zealand, where she served as the National Leader for a number of years. Leslie frequently provides “thought leadership” contributions to various international publications and associations.
Managing Partner, Deloitte, Warsaw
Iwona Georgijew is a managing partner of Deloitte’s Transfer Pricing National Practice in Poland and Deloitte’s regional Transfer Pricing Group for Central and Eastern Europe. She supervises projects on structuring, documenting, auditing and defending intercompany transactions for both local and international clients. In the Guide to the World’s Leading Transfer Pricing Advisors (by Euromoney Magazine) she was appointed a leading Polish transfer pricing advisor in 2006/2007 and 2008/2009.
Associate Partner at Deloitte & Associados SROC, S.A., Lisbon
Patrícia Matos is currently Associate Partner in Deloitte’s Lisbon office in the transfer pricing department.
Patrícia has a business degree and is a chartered accountant. She started her professional career in Arthur Andersen (Arthur Andersen, S.A., presently Deloitte & Touche as result of an effective association of both firms since April 2002) in 1997 and was promoted to Associate Partner in 2008.
Patrícia has extensive experience in tax planning, due diligence and tax compliance for Portuguese and Multinational companies. In 2002, she began working exclusively in transfer pricing. She advises clients in several aspects of transfer pricing, ranging from tax audits to comprehensive transfer pricing planning, structuring of intercompany transactions and defensive documentation.
Her experience spans a wide range of industries including communications, technology, media, financial services, automotive, consumer goods, tourism and pharmaceuticals.
Patrícia has been a speaker at several seminars and conferences on tax, economic and transfer pricing issues.
Dr. Tae-Hyung Kim
Transfer Pricing, Korea
Dr. Tae Hyung Kim is a former senior partner and national leader of the Global Transfer Pricing Group at Deloitte Korea. Over more than 14 years, Dr. Kim has represented multinational corporations in various industries in transfer pricing audit defense, advance pricing agreement negotiations, mutual agreement procedures, and planning and documentation studies.
Prior to his previous position, Dr. Kim headed the national transfer pricing practice at other Big Four firm in Korea and the Law and Economics Consulting Group in Korea. Before specializing in transfer pricing, Dr. Kim was a research fellow for the Korea Institute for International Economic Policy (KIEP). During his tenure at the KIEP, he advised the Ministry of Finance and Economy, the Ministry of Commerce, Industry, and Energy and the Ministry of Foreign Affairs in the area of international trade and investment policies.
Dr. Kim's recent publications appear in IBFD's International Transfer Pricing Journal, Tax's Transfer Pricing Reports, and Euromoney's Transfer Pricing Reviews. His economics publications also appear in Canadian Journal of Economics and Review of International Economics.
He holds a Ph.D. in economics from the University of Washington and is a graduate of Advanced Management Programs of both Harvard Business School and Seoul National University.
Seong Kwon Song
Head of Transfer Pricing Group, Deloitte Korea
Mr. Seong Kwon Song, former Assistant Commissioner for International Tax Investigation and Head of the Competent Authority at the Korean National Tax Services (KNTS), leads the Deloitte transfer pricing group in Seoul, Korea. The group has over 40 specialists, including ex-KNTS officers and economists with global backgrounds.
Ernst & Young, Moscow
Evgenia joined the firm as a partner in March 2011. Before that she worked for more than 15 years with another Big Four company where she obtained extensive experience in providing advisory services to Russian and international companies on various areas of taxation and conducting business in Russia, structuring investments, and coordinating approaches to tax planning. Since 2007 Evgenia has been focusing on transfer pricing. She has led transfer pricing planning and documentation projects for multinational and Russian clients in various industry sectors, including structuring of entry/exit strategies of clients from the transfer pricing perspective, adaptation of global transfer pricing policies to Russian requirements, business restructuring, development of sustainable transfer pricing methodologies, etc. Evgenia specialises on serving companies working in retail, consumer products and life science industries. She is currently a Partner in the Transfer Pricing Group for Ernst & Young in Moscow.
Director of Economics (Transfer Pricing), Baker & McKenzie Wong & Leow, Singapore
An economist with 16 years of experience in transfer pricing consulting and academia, Michael Nixon's experience includes transfer pricing and business restructuring projects in the U.K., Germany, the Netherlands and Singapore, where he has been based for the last six years. He has advised multinationals across various industries throughout the planning, compliance, and audit cycle. His practice is focused on transfer pricing controversy, intellectual property valuations, and business restructuring. He is a member of the Singapore transfer pricing consultation group with the Inland Revenue Authority of Singapore (IRAS) and has undertaken training for the IRAS Tax Academy. He also consults with Singaporean academic institutions on transfer pricing and business restructuring matters. Mr. Nixon has a Bachelor of Arts Economics degree from Nottingham Trent University and a Master of Science Economics (with distinction) from the University of London. He is a member of the Chartered Institute of Taxation in the U.K. and the Society of Financial Advisors in the U.K.
Partner in the Tax Department of Webber Wentzel Attorneys
Michael Honiball is a Partner in the Tax Department of Webber Wentzel Attorneys, which is the leading law firm in South Africa.
Michael has substantial transfer pricing and tax advisory experience and has specialised in South African domestic and international corporate tax issues for over 20 years, advising many multinational corporations on a wide range of tax compliance, structuring and financing matters. Michael advises on a broad spectrum of transfer-pricing issues, from documentation and planning to dispute resolution, taking into account the unique circumstances of various African jurisdictions.
Michael is a visiting professor at the University of Johannesburg and is a regular speaker at professional conferences. He is also a co-author of the book International Tax: a South African Perspective 2008 (now in its fourth edition), together with Professor Lynette Olivier of the University of Pretoria, which contains a chapter on transfer pricing.
Michael is a well-known tax adviser in South Africa, being listed in The Guide to the World's Leading Tax Advisers and Who's Who of Southern Africa 2005.
Global Transfer Pricing Services, Partner, Tax Department, KPMG Abogados, Barcelona
Ms. Trapé joined KPMG in 2007 and has worked on numerous transfer pricing projects including transfer pricing policy design, documentation work, APA negotiations as well as audit defence and recourse in transfer pricing cases and international taxation. Her work has spanned the financial, consumer products, energy and pharmaceutical sectors.
Prior to joining KPMG, Montserrat Trapé worked at the Spanish Revenue Service. As Co-Director of International taxation she was responsible for negotiating several multilateral and bilateral APAs, judicial defence of TP assessments as well as actively participating in the new transfer pricing legislation. Ms Trapé was also Vice-Chair of the European Union Joint Transfer Pricing Forum for four years. During this period, the JTPF worked on recommendations for the effective implementation of the Arbitration Convention, on a transfer pricing model documentation to simplify documentation compliance requirements and on a report on best practices for APA within Europe.
Montserrat Trapé is also a Visiting Professor at ESADE Instituto de Estudios Fiscales, where she has conducted several training courses for Spanish & Latin American Tax Authorities in Madrid. She is a frequent public speaker and contributor to articles and books on transfer pricing, dispute resolution mechanisms and international taxation issues.
Ms Trapé has been included in the list of 2009 and 2010 "Best lawyers" in Spain.
Transfer Pricing Partner, PricewaterhouseCoopers, Zurich
Benjamin Koch is a transfer pricing partner in the tax and legal services practice of PricewaterhouseCoopers Switzerland. His experience includes advising multinational companies on the structuring of global manufacturing and distribution structures, migration of intangible property, establishing global trademark royalty schemes and the development of intra group service fee concepts. Furthermore, he has substantial experience assisting companies in preventing tax audits and managing international tax controversies through the use of advance pricing arrangements (APAs), tax rulings and mutual agreement procedures (MAPs).
Jeffrey S. Korenblatt
Partner, Reed Smith LLP, Washington, D.C.
Jeffrey S. Korenblatt is a tax attorney with more than 15 years of experience. He has a broad-based transactional tax practice and focuses on international tax planning and transfer pricing. Jeff delivers tax solutions to clients in multiple industries, including, but not limited to, manufacturers, retailers, franchisors, web-based providers of goods and services, and taxpayers in life-sciences industries.
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