Speakers

General Reporters

Johann Hattingh is Professor in the Department of Commercial Law of the University of Cape Town, South Africa, and an Advocate of the High Court of South Africa. He formerly practiced in the field of international taxation with PwC. Professor Hattingh received his PhD in law from the University of Cambridge for a thesis developing a theory of integrative tax treaty interpretation. He holds two LLM degrees, one from the University of Cape Town and the other from Leiden University. He obtained B.Com (Law) and LL.B degrees from Stellenbosch University.

Since 2003, Professor Hattingh has an association with the International Bureau of Fiscal Documentation (IBFD) in Amsterdam, where in 2019 he took up the Chief Editorship of the Bulletin for International Taxation. He has lectured and tutored at several universities including the International Tax Centre at Leiden University, Stellenbosch University, and the University of Cambridge, has been an academic visitor at the Oxford Institute for European and Comparative Law, and regularly speaks at international conferences. He has acted as senior international consultant for the UN Economic Commission for Africa, participated in the tax work of NEPAD on behalf of the African Union, and is consulted by public and private sector organizations across Africa. He is a member of the International Tax Law Committee of the International Law Association (ILA) and the permanent scientific committee of the International Fiscal Association (IFA).

Professor Hattingh has authored over 70 academic publications including legal reference works, textbooks, edited books, book chapters, journal articles and case notes. His work on tax treaties has been cited by courts, including the Supreme Court of Canada and the Federal Supreme Court of Switzerland.

Peter Hongler is professor for tax law at the University of St. Gallen and a director at the Institute for Law and Economics. Peter was educated at the Universities of Bern (MLaw 2008) and Zurich (Dr. iur. 2011). As assistant to Prof. Dr. Madeleine Simonek he conducted research at the Universities of Zurich and Lucerne. Besides, he was a guest researcher at the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business and a Post Doc Research Fellow at the IBFD in Amsterdam. He is experienced in advising political bodies in tax policy matters. Peter is the editor-in-chief of the Forum for Steuerrecht and he is a member of several national and international tax organizations. He published several books (e.g. Justice in International Tax Law [IBFD 2019] and International Law of Taxation [OUP 2021]) and dozens of articles (for a full list please check the website www.alexandria.unisg.ch/persons/8263)

Chair

Philip Baker KC is a practicing barrister and King’s Counsel, practicing from chambers in Field Court, Gray’s Inn. Additionally, he is Visiting Professor at the Law Faculty of Oxford University and a Senior Visiting Fellow at the Institute of Advanced Legal Studies, University of London.
He specialises in international aspects of taxation, which covers both corporate and private client matters. He has advised and represented several governments on tax matters, and appeared as an expert in cases around the world. He has a particular interest in taxation and the European Convention on Human Rights, is author of a book on Double Taxation Conventions, and editor of the International Tax Law Reports. He was one of the General Reporters on the Practical Protection of Taxpayers’ Rights for the International Fiscal Association Congress in Basel in 2015, and is one of the directors of the Observatory on Protection of Taxpayers’ Rights.

Secretary

Tobias Fleischer is an associate at Setterwalls law firm in Gothenburg, Sweden and branch reporter for Sweden for the 2024 IFA Cape Town congress. Tobias regularly assists Swedish and non-Swedish companies in tax matters such as restructurings, incentive programs, tax disputes and tax advice in conjunction with M&A transactions. Tobias also regularly provides tax advice to individuals moving to or from Sweden.

Tobias graduated from the law programme at the University of Gothenburg in 2021. Prior to graduating, Tobias worked part-time as an associate at Deloitte during law school and worked as a summer legal clerk at a court of appeal in Sweden. Tobias has also studied international finance law at Queen Mary University of London.

Panel Members

Dr Victoria Plekhanova is a practitioner-turned-academic. She left practice in 2013 and moved to New Zealand to write a PhD thesis, “Global Matchmakers: Tax Challenges and Responses in the Digital Economy”, at the Auckland University Law School.

Victoria has over fifteen years of practical experience in commercial and tax law advisory work and litigation in Russia, including several years at Ernst & Young CIS (Moscow) as a barrister and a member of the Moscow Bar Association. Victoria also holds a Master of Private Law degree from the Russian School of Private Law at the Private Law Research Centre at the President of the Russian Federation.

From 2018, Victoria teaches tax courses at undergraduate and postgraduate levels at Massey University (Auckland, New Zealand) and conducts research on international taxation. She has published in leading academic tax and law journals in Australia, Canada, the EU, New Zealand, and the UK. In 2024, Victoria was appointed as a Vice-President of the Australasian Tax Teachers Association.

Andrea has more than 20 years of experience in the tax area, working within both, the private and the public sector. She started her career in 2003 at PWC Uruguay where she worked at the Tax&Legal Services Department during eight years. Afterwards, she was Tax and Accounting Content Manager at Thomson Reuters-La Ley Uruguay and, in 2012 she joined the Uruguayan Tax Administration, within the Ministry of Economic and Finance, as tax advisor to the Directorate-General. Additionally, in 2020 she was appointed Uruguayan delegate at the OECD Task Force on the Digital Economy and since then she has also been coordinating the work of other Uruguayan delegates at different OECD/IF subsidiary bodies.

She is an accountant with an MBA and a master degree in international taxation. She pursued her PhD (cum laude) at the Faculty of Law of the University of Valencia, Spain, where she regularly contributes in the development of academic activities. Besides, she is the Secretary and a member of the board of directors at the Uruguayan Tax Studies Institute (IUET), which is the local IFA branch and member of the Latin-American Tax Law Institute (ILADT). Since 2017 she has also been an external consultant to the Inter-American Development Bank.

She is an active writer and speaker in national and international academic fora. Her field of expertise is international taxation, and during the last years, her research and teaching activities, including at national and foreign universities, have been centered on the implications arising from the globalisation and digitalisation of the economy, with a special interest in Latin America and the Caribbean and developing countries in general. During her PhD studies, she researched on CIT nexus rules and her book “A global solution to corporate income taxation: the revitalisation of source” was published – in Spanish – in 2021.

Prof. Dr. Cedric Ryngaert (PhD Leuven 2007) is Chair of Public International Law at Utrecht University (Netherlands). His research interests include the law of jurisdiction, immunities, sanctions, international security law, international criminal law, non-state actors, the role of international law before domestic courts, international responsibility, and international organizations. Among other publications, he authored Jurisdiction in International Law (OUP 2015, 2^nd ed), Selfless Intervention: The Exercise of Jurisdiction in the Common Interest (OUP 2020), and, with Tom Ruys, Secondary Sanctions (British Yb Int’l 2020). Cedric Ryngaert is the chair of the Dutch Advisory Council on International Law (CAVV). He is also the editor-in-chief of the Netherlands International Law Review and the Utrecht Law Review. Previously, he taught at Leuven University and the Military Academy of Belgium.

Annet Oguttu is a professor of taxation and the Director of the African Tax Institute at the University of Pretoria. She holds a doctorate in tax law and specialises in international tax law.

She is the author of: the ground-breaking book “Base Erosion and Profit Shifting: A Blueprint for Africa’s Response” (IBFD, 2021); the seminal book “International Tax Law: Offshore Tax Avoidance in South Africa” (Juta, 2015); co-author of “Tax Law: An Introduction” (Juta, 2024) and has contributed several book chapters. She has published numerous articles in various accredited journals and presented her findings in many international conferences – often as the Key Note Speaker. She has written commissioned reports for many international bodies.

She is rated as an established researcher by South Africa’s National Research Foundation. She is a Research Fellow of: IBFD Centre for Studies in African Taxation; Abe Green Baum Research Fellowship of the School of Taxation and Business Law at the University of New South Wales; and University of Michigan’s Presidential Scholars Fellowship.

Job title: Director, Directorate ’lndirect taxation and tax administration‘, DG TAXUD

Organization: European Commission

Maria Elena Scoppio is the Director of the Directorate ”Indirect taxation and tax administration“ in the Directorate-General for Taxation and Customs Union (DG TAXUD) in the European Commission. which aims to develop and implement tax policy across the EU on indirect taxation, and notably on environmental taxation. Before being appointed to this position, she was Member of the Cabinet of Commissioner Gentiloni and was responsible for all issues related to DG TAXUD at the Cabinet level. She was notably coordinating the legislative proposals in the field of direct and indirect taxation and customs. Previously, she was Head of the Unit in DG TAXUD in charge of the elaboration and development of the EU policy in the field of VAT and of digital taxation. Before, from 2004 until 2017, she has served as a Member of Cabinet for the Commissioners Moscovici, Semeta and Kovacs and was supervising taxation issues. Before joining the Commission in 2002, she worked as a tax and legal adviser for Arthur Andersen

General Reporters

Prof Jan de Goede, Senior Principal, Tax Knowledge Management, reporting to the CEO of IBFD, held several positions during his 25 years at IBFD, including Director Knowledge Centre. He performs various academic, teaching and government consultancy activities, is IBFD liaison officer for relations with OECD, UN, ICC. He is Professor of International and European Tax Law at Lodz University in Poland, and visiting professor at Renmin University in Beijing, teaching also at other universities and Institutes, including IBDT in Sao Paulo.

He is member of the Scientific Council of the Polish Tax Law Quarterly, member of IFA who attended its PSC as supervisor IFA researcher and General-Reporter for the 2024 Cape Town Congress, member of EATLP and of the Dutch Association for Tax Science.

He worked 19 years at the Dutch Ministry of Finance, including as Head of the Divisions on Company Tax Legislation during which period important changes in that legislation were realized, and on Bilateral Tax Matters where he was involved in the conclusion of many tax treaties and mutual agreement procedures with various countries.

He holds several (unpaid) positions at charitable organizations, was granted the Medal for Science and Society of Lodz University, the Honorary Membership of IFA, is Knight in the Order of Merit of the Republic of Poland and Officer in the Order of Orange-Nassau of the Kingdom of the Netherlands.

Mr. Maruca has been practicing tax law in Washington DC since 1983, primarily in dispute resolution on behalf of large corporations in the biopharma, information technology, automotive, communications, manufacturing, and entertainment industries. In 2011 Mr Maruca was appointed the first director of transfer pricing operations at the Internal Revenue Service, returning to private practice in 2014. While at the IRS Mr Maruca assumed program responsibility for compliance on large transfer pricing disputes and operations of the US Competent Authority (double tax cases in MAP and the APA program). He also served on the US delegation to Working Party 6 at the OECD. He is now Senior Counsel at Covington & Burling LLP, which he joined as a partner in 2008.

Chair

Marlene is the Deputy Commissioner General- Legal Support Division, Tax Administration Jamaica, Ministry of Finance and the Public Service.She has over 24 years experience in taxation.

She currently serves as the co-chair of the Inclusive Framework on BEPS and previously served on the Steering Group during the period 2017 – 2020. Marlene also serves as co-chair of the OECD’s Advisory Group for Global Dialogue on Tax Matters.
She also served as Jamaica’s chief delegate to the Global Forum on Transparency and Exchange of Tax Information from 2010- 2013.
Marlene is also a past and current member of the United Nations Committee of Experts on International Cooperation in Tax Matters, and during her membership from 2017-2021, served as Coordinator of the Subcommittee on the Tax Treatment of Government-to- Government Aid

She frequently participates in various panel discussions and other fora, giving voice to the issues of developing countries, as they position themselves in the global tax landscape.

Secretary

Craig West is a Principal Associate at IBFD. There he serves as Managing Editor of IBFD’s Global Tax Treaty Commentaries and of the IBFD Doctoral Series. Craig is also an Adjunct Professor in the Commerce Faculty at the University of Cape Town, South Africa, having previously worked at the UCT for a period of 20 years. He is a Chartered Accountant of Australia and New Zealand and a Chartered Tax Advisor (SA) in South Africa. He holds a PhD from the University of Cape Town (2009) as well as a Master of Commerce in Accounting.

He has been a visiting researcher at the IBFD (2016/2017); the Institute for Austrian and International Tax Law (WU, Vienna) (2015) and the Fiscal Institute for Taxation (UvT, Tilburg) (2013). Craig has delivered guest lectures at Tilburg University (2016, 2022, 2024), Netherlands, University of Amsterdam (2021, 2022), Netherlands, Leiden University (2021-2023), Netherlands, and Strathmore University (2018), Kenya. Craig has also provided tax training to corporate entities and government. He is a member of IFA and an Associate Member of the EATLP. Craig has published a number of articles and chapters and regularly presents at conferences and seminars on both international and South African taxation. He has been appointed as a national reporter for South Africa on several occasions.

Panel Members

Part 1:

Rasmi Ranjan Das is a former member of Indian Revenue Service with 34 years of experience in poficy making and implementation of direct tax laws in India. In his last assignment before his voluntary retirement, as Chief Commissioner of Income Tax (International Tax) in India’s Ministry of Finance, he was responsible for managing and guiding a team of senior and middle management level officers in taxation of non-residents including transfer pricing. Before this, he was the Competent Authority of India for tax treaty negotiation, exchange of information and resolution of BAPA and MAP cases for countries in North America and Europe. He represented India in the G-20/BEPS/lnclusive Framework and was Member of its Steering Group. He is also member of current United Nation Committee of Tax Experts. Earlier, as part of the team responsible for Tax Policy and Legislation in India, he was involved in some key policy initiatives in international tax including those relating to Interest limitations, secondary adjustments, and Significant Economic Presence (SEP). Rasmi holds a Post Graduate Degree in Public Policy and Management from Indian Institute of Management, Bangalore, and a Post Graduate degree in International Relations from Jawaharlal Nehru University, Delhi. He has authored papers on subjects like whether value creation is relevant for allocation of taxing rights; on gradual loss of authority of AoA on attribution of profit to Permanent Establishment; and whether QDMTT is right for developing countries. Recently, he co-authored a paper titled “Beyond the Two Pillars-A simplified approach for taxing Multinationals”.

Michael Lennard is Chief of the International Tax Cooperation Section in the UN Financing for Sustainable Development Office and is also Secretary of the UN Tax Committee. His work focuses on ensuring the fairness and workability of international tax norms for all stakeholders, including achieving greater developing country input into those norms, and encouraging cooperation to improve tax systems as a spur to sustained development that benefits all stakeholders in tax systems. In 2011 and 2021/22 he was selected as one of ITR’s Global Tax Top 50, and the UN tax work more generally has been regularly so recognized. In 2023 he was Tax Notes International Person of the Year.

Céline is a French Attorney-at-law. She is Partner at BDO Law Firm and Head of the Transfer Pricing / International Tax department in France.

Her practice focuses on international corporate tax law and transfer pricing for multinational clients, both in an advising role and in the context of disputes. She has developed expertise on tax audits as well as dispute prevention, dispute resolution procedures (advance pricing agreements, mutual agreement procedures, arbitration, etc.) and collaborative approaches. She assists international groups in the securing of their tax and transfer pricing policies. She is also involved in international exchange of information matters such as FATCA and CRS.

Céline is a member of IFA France Women of IFA Network (WIN) Board and the representative of the WIN at IFA France scientific committee. She is also a member of the board of the Institut international des sciences fiscales (2iSF). She regularly publishes contributions on transfer pricing and dispute prevention/resolution matters (recently Dispute Resolution under Tax Treaties and Beyond – French report, IBFD, Chapter 24 France), and she participates as speaker in French and international tax conferences on such matters (recently IFA France and CIOT).

Before joining BDO, Céline has worked for more than 10 years in the International Tax / Transfer Pricing department of CMS Francis Lefebvre Avocats. Céline graduated from Oxford University (Comparative Law) and Paris II-Assas University (Business and Tax Law). She holds a Master’s degree in Corporate Tax Law from Paris-Dauphine University

Sebastiaan de Buck is Global Head of Tax with Unilever. Since joining Unilever in 2011, Sebastiaan has held a wide range of positions in Unilever, covering Dutch, regional and global tax and transfer pricing matters. Prior to joining Unilever he was with KPMG in the Netherlands in the international tax & transfer pricing practice since 2004. Sebastiaan has specialized in corporate income taxation, international taxation and tax treaties, transfer pricing with key focus on transfer pricing in relation to intangibles, services and financial transactions, as well as has a key interest in tax transparency and tax governance. He studied fiscal economics at the University of Maastricht, and has completed various post-university tax programs at amongst others the Erasmus University in Rotterdam, International Tax Center in Leiden and New York University on European and international taxation. He is a Member of the Board of the Dutch IFA branch, is a Member of the Board of the Dutch Association of Tax Advisors where he represents the in-house tax community, and is a Member of the Dutch Association of Tax Advisors’ Committee on Tax Law Proposals. He is a permanent contributor to the international tax documentation of SDU Uitgevers where he writes on subjects in relation to the OECD Model Tax Convention and the topic of Residence. He is a frequent speaker at conferences and seminars where he primarily presents on the perspectives of a multinational company in the areas of tax and development, the tax policy and design considerations of international (e.g. OECD or EU) tax, and on the subject of tax transparency. He also teaches a course on the aspects of tax transparency and dispute prevention and resolution as part of the Advanced Master in International Tax Law of the University of Amsterdam.

Trésor-Gauthier M. Kalonji is an Associate Professor at the Université Pédagogique Nationale and Visiting Professor in several universities and colleges in the DR Congo (Ecole Nationale des Finances, Université Catholique de Bukavu, Leadership Academia University, Université Protestante de Lubumbashi) and abroad (Aix-Marseille University/France) where he teaches tax law, public finance law, business law and economic law. Researcher and author of several legal books and articles, his research and expertise focus on tax law (transfer pricing, tax optimization, tax structuring of companies, tax treaties, etc.), public finance law (public budgets and financing, public procurement, etc.), business law (OHADA, investments, insurance, financial markets, banking), and economic law (state interventions in the economy).
He is also a Senior Tax Advisor at DALDEWOLF DRC since May 2023, after ten years as civil servant (senior manager) at the Ministry of Finance of the DRC.
He holds the following degrees Ph. D in Tax Law from the University of Neuchâtel/Switzerland (summa cum laude); LLM/Master of Advanced Studies in European and International Governance from the University of Geneva/Switzerland; University Diploma of Specialization in Economic, Social and Cultural Rights, awarded jointly by the Collège Universitaire Henry Dunant of Geneva/Switzerland and the University of La Rioja/Spain; Master 2 in Public Law – Public Services and Policies of the University of Rouen-Normandie/France; and Maîtrise/Licence in Economic and Social Law of the University of Lubumbashi/R. D. Congo.
He works in French, English, Lingala and Swahili.

Prof Thabo Legwaila holds the following qualifications: B Iuris (Venda); LLB (Wits); LLM (Wits); Postgraduate Diploma in Tax Law (UCT); LLM (UCT) and LLD (Pretoria). Prof Legwaila was a Senior Lecturer at the University of Stellenbosch. He was later invited to Harvard University where he spent time as a Research Fellow in the Harvard University International Tax Program in 2002. He subsequently moved into tax consultancy working for KPMG and later Ernst & Young. In 2006 Prof Legwaila joined the South African National Treasury as a Director for Business Tax where his role was to develop the South African business tax policy as well as manage general tax legislative amendments and specific business law amendments. In 2011 he joined Citibank as Head of Tax for the Africa division. Prof Legwaila was a Professor of Tax Law at the University of Johannesburg from 2014 to 2023. He was appointed as a member of the Davis Tax Committee (DTC) in 2015. Prof Legwaila is the Chief Executive Officer of the Office of the Tax Ombud and Professor of Tax Law at the University of the Witwatersrand.

Panel Members

Part 2:

Degrees: Business Law, University Paris 2 ; Institute of Political Science, Paris ; National School of Administration, Paris

Member of the French Conseil d’Etat (Supreme Administrative Court) from 1981 to 2022

President of the National Tax Commission (since 2021)

President of the French IFA Branch

Vice-president of the International Association of Tax Judges (IATJ)

As a partner and head of the tax controversy practice at Osler, Al Meghji is widely regarded as Canada’s preeminent tax litigation counsel, holding an outstanding record of success in complex tax litigation matters in various courts. Al is supported by Osler’s tax group, which is consistently ranked as one of Canada’s largest and most sophisticated tax practices.

Al has been lead counsel in many of Canada’s most important and high-profile tax cases. He has appeared in the Supreme Court of Canada more frequently than any other Canadian tax litigator and has successfully argued a number of landmark tax cases in that court, including Shell Canada (widely regarded as the leading authority on economic substance and tax avoidance); Canada Trustco (that defined the scope of the Canadian GAAR); and GlaxoSmithKline (the first and only transfer pricing case heard by the Supreme Court of Canada).

Al has been widely recognised as a leading Canadian tax litigation practitioner by third-party and peer review legal ranking directories, including Chambers Canada, Best Lawyers in Canada, Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada and the Tax Directors Handbook. He is the only tax litigator in Canada to receive the coveted “Star Individual” rating by Chambers Global and Chambers Canada. Al was also recognised by Best Lawyers as “Tax Lawyer of the Year” and by Best of the Best 2018: Expert Guides as “One of the World’s Top 30 Tax Practitioners”.

Al is a CPA, a graduate of Harvard Law School (LLM) and a member of the Bars in Alberta and Ontario.

I am a qualified Chartered accountant with inter alia a Masters degree in Taxation and a Higher Diploma in International Taxation. I have a passion and heart for Africa and have dedicated my tax career to try and play some role in unlocking the continent’s potential. After starting my career at the South African Revenue Authority, I garnered significant international tax expertise through leading the international tax function at a large telecommunications company for a decade. Transitioning into an Africa tax group lead role for the last 7 years required me to expand my focus to all levels of taxation and to support our operations on all their tax and related matters in Africa’s evolving tax landscape. It is well established that manufacturing is regarded as a key driver for economic growth, a source of resilience to economic shocks and an important contributor to GDP which is one of our continued focus areas as we refresh Africa every day.

Nicole Welch is the director of the Treaty and Transfer Pricing Operations practice area in the IRS Large Business and International division, where she is responsible for responsible for planning, developing, directing, and monitoring the administration of U.S. tax treaties and related competent authority programs and the IRS’s transfer pricing examination work across the country. She previously served as director of the Advance Pricing and Mutual Agreement program (APMA), where she oversaw the negotiation and resolution of all mutual agreement procedure and advance pricing agreement cases arising under U.S. tax treaties. Nicole has served as a delegate to several OECD working groups, including the Forum on Tax Administration MAP Forum. Before joining the IRS in 2012, Nicole handled international tax planning and controversy matters at a law firm in Washington, DC. She received her bachelor’s degree from Georgetown University and her J.D. from The University of Chicago Law School.

Chair

Stephen Shay is the Paulus Endowment Senior Tax Fellow and Adjunct Professor at Boston College Law School. He is the IBFD Visiting Global Scholar for 2024.

Mr. Shay has served as Deputy Assistant Secretary for International Tax Affairs in the United States Department of the Treasury and is a retired partner of Ropes & Gray LLP where he practiced international tax law for over two decades. He has been a Professor of Practice at Harvard Law School and a Lecturer at Yale Law School, Oxford University (MSc. in Taxation) and the Leiden International Tax Institute.

Mr. Shay consults for international organizations and private parties and has testified as an expert before judicial and arbitral tribunals on behalf of governments and private litigants. He has testified in his personal capacity numerous times on international tax issues before the U.S. Congress. He has served as an expert consultant to the International Monetary Fund on tax policy missions and he regularly provides pro bono technical assistance to governments of low-income countries through the auspices of the International Senior Lawyers Project.

Mr. Shay serves on the Executive Committee of the New York State Bar Association Tax Section, the Leadership Council of the Harvard Law School Wilmer Hale Legal Services Center, and the Amicus Committee of the American College of Tax Counsel. He is a 1972 graduate of Wesleyan University and earned his J.D. and his M.B.A. from Columbia University in 1976. He is admitted to practice in New York and Massachusetts.

Secretary

João Félix Pinto Nogueira, PhD in Tax Law, is Professor at the Portuguese Catholic University (“Universidade Católica Portuguesa”). He is Deputy Academic Chairman at IBFD and team manager of IBFD Academic. He is honorary associate professor at the University of Cape Town, South Africa and regular visiting lecturer at several universities. He is Deputy Editor-in-Chief of the World Tax Journal, of the Global Tax Treaty Commentaries, of the Doctoral Series and of the International Tax Studies. He is a member of the list of independent persons of standing of the European Commission and, as such, authorised to serve as arbitrator for the purposes of the EU tax dispute resolution directive. He was a lawyer at one of Portugal’s most reputed tax law firms.
His areas of expertise are international and European tax law, fields in which he has published a dissertation and several articles and book chapters. Dr Nogueira has more than twenty years of experience in teaching at both the graduate and post- graduate levels and is currently overseeing several master’s courses on EU and international tax law, taught in different languages.

He is a member of the EATLP, IFA, IFA Portugal (Associação Fiscal Portuguesa) and IBDT. He is the Vice-President of the AFP / IFA Portugal. He is a member of the Permanent Scientific Committee of IFA Central. He is a member (and the scientific secretary) of the ECJ Task Force of the Confédération Fiscale Européenne. He is also a member of the Executive Board of the ILADT (Directorio). He is one of members of the LOC (Local Organizing Committee) in charge of organizing the 2025 Annual Congress of the International Fiscal Association, which will be held in Lisbon. He is a member of the editorial board and council of several periodicals on international taxation and frequently acts as an external peer reviewer.

Panel Members

As the Head of Tax at Agoda, one of the world’s fastest growing online travel booking platforms and part of Booking Holdings Group, Giammarco leads a team of 20+ professionals who advise the business on all tax matters affecting its global operations. He has more than 20 years of experience in the tax field, spanning international organizations, governments, private sector, and in-house roles. Giammarco’s core competencies include direct and indirect tax structuring, corporate law and transfer pricing. Giammarco has extensive experience in tax policy and government relations, having represented Italy in the OECD’s BEPS project and worked as a Director of Global Tax Policy at Netflix, as well as international taxation and transfer pricing, having acted as a partner in charge of those issues in a premiere Italian tax boutique firm. He holds a JD and PhD from LUISS Guido Carli and an LL.M in European and International Taxation from Tilburg University. He is fluent in Italian, English, French and Spanish.

Peter Hongler is professor for tax law at the University of St. Gallen and a director at the Institute for Law and Economics. Peter was educated at the Universities of Bern (MLaw 2008) and Zurich (Dr. iur. 2011). As assistant to Prof. Dr. Madeleine Simonek he conducted research at the Universities of Zurich and Lucerne. Besides, he was a guest researcher at the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business and a Post Doc Research Fellow at the IBFD in Amsterdam. He is experienced in advising political bodies in tax policy matters. Peter is the editor-in-chief of the Forum for Steuerrecht and he is a member of several national and international tax organizations. He published several books (e.g. Justice in International Tax Law [IBFD 2019] and International Law of Taxation [OUP 2021]) and dozens of articles (for a full list please check the website www.alexandria.unisg.ch/persons/8263)

Afton Titus is an Associate Professor of tax law of the University of Cape Town (UCT). Afton’s research focuses on African regionalism and its international tax implications; tax governance; and corporate income tax policy. Afton analyses how African countries may best use international tax developments to forward their developmental goals. She also proposes an international tax governance structure within the African Union, incorporating Africa’s regional economic communities and the African Tax Administration Forum.

Afton obtained her Bachelor of Commerce and Bachelor of Laws degrees from UCT before also completing a Master of Commerce degree in Taxation there. She worked as a tax advisor for a few years before joining UCT. In 2020, she defended her PhD thesis entitled, ‘The Design of a Corporate Income Tax System and How to Protect it for the East African Federation,’ which was awarded by the Amsterdam Centre for Tax Law at the University of Amsterdam. Currently, she is part of the core team at the UCT Tax Unit for Fiscal Research, in partnership with the International Bureau for Financial Documentation (IBFD).
Featured work:
– Titus, A. ‘Africa Rising: A Proposal for a Continental Tax Governance Structure’ ICTD Blog, 5 June 2023.
– Titus, A. ‘Global Minimum Corporate Tax: A Death Knell for African Country Tax Policies?’ (2022) 50(5) Intertax 414 – 423.
– Titus, A. ‘Pillar Two and African Countries: What Should Their Response Be? The Case for a Regional One’ (2022) 50(10) Intertax 711 – 720.
– Titus, A. The Promise of Non-arm’s Length Practices: Is the Destination-Based Cash Flow Tax or Unitary Taxation the Panacea of Which Developing Countries Are in Search?. In Mosquera Valderrama, I.J., Lesage, D., Lips, W. (eds), Taxation, International Cooperation and the 2030 Sustainable Development Agenda (2021). Springer. 29-46.

Rebecca Millar is a part-time Professor at the University of Sydney Law School, where she specialises in GST and comparative VAT law. She has been a Guest Professor at the Institute for Austrian and International Tax Law at WU, where she co-taught the course Global Trends in Value Added Tax between 2016 and 2023, and has also taught classes on GST and/or comparative VAT in the Professional LLM at Osgoode Hall Law School (2015), Xiamen University (2023), and the IBFD in Amsterdam (2017, 2018).
She has been a pro-bono academic advisor to OECD Working Party 9 on Consumption Taxes since 2007, and is a member of the UN VAT Subcommittee. Her contributions to comparative tax law research on the ‘international tax’ aspects of VAT (the ‘place of taxation’ rules that allocate taxing rights over transactions with a cross-border element) were recognised by the Women in IFA Network when she was included in their 2019 publication Recognising 100 Years Of Women In Tax. That publication also recognised her work assisting countries with the design, drafting, and implementation of indirect tax laws through her work with the IMF, World Bank, and ATAF.
In Australia, she was a member of the panels of experts for the Board of Taxation’s Review of the Legal Framework for the Administration of the GST (2009) and its Review of the Application of GST to Cross-Border Transactions (2010), and was a member of the ATO GST Rulings Panel (2003-2008) and GST Advisory Group (2013-2014) before moving to Washington D.C., where she now lives during that part of the year that she is not working at the University of Sydney.
Before becoming an academic, she worked as a tax practitioner for 10 years, including two years with Ernst & Young Australia during the introduction of Australia’s GST.

Chair

James heads up the Africa Tax and Legal Services practice at PwC, leading a community of solvers who seek to provide sustained outcomes to clients across Africa. James specialises in providing tailored advice and compliance solutions to high net worth individuals and families based in South Africa and elsewhere, particularly in situations where there are cross border complexities, drawing upon the extensive PwC network. Recent times have seen significant movements of individuals to and from Africa as well as an increasing priority of global asset and wealth diversification and James and his team advises his clients in navigating the associated tax and exchange control complexities both in South Africa and in other jurisdictions. In addition to providing holistic advice, taking into account different countries’ rules, regulations and practice, James and his team work with his client base to support them fulfilling their tax compliance obligations in those jurisdictions. James moved to South Africa in 2001 with the introduction of residence based taxation and capital gains tax, and has been involved in changes to the tax legislation as it has evolved over the last 20 plus years. Prior to moving to South Africa, he worked in the UK and the USA, predominantly advising multinational companies on the tax treatment of their international mobility and share based reward programmes across the world. He is a member of the Chartered Institute of Tax in the UK and the South African Institute of Tax.

James is married and has two grown up children and when he is not advising his clients he can be found swimming in the cold water oceans of Cape Town or hiking on Table Mountain.

Secretary

Tracy Johnson is the Head of the Taxation Section (postgraduate studies) in the Department of Finance and Tax at the University of Cape Town. She also plays a role at the South African Institute of Taxation where she leads the Assessment Development Group and serves on the Assessment Committee, Education Committee, and Chartered Tax Advisor (CTA) Committee. Before entering academia,

Tracy gained practical experience in corporate tax while working at PwC and provides independent tax consulting services to various firms in South Africa. Tracy is the South African representative of the Women of IFA Network (WIN) and is part of the Local Organising Committee for the IFA Congress in Cape Town.

Panel Members

Oktavia Weidmann is a barrister in England and Wales and teaches at the Dickson Poon School of Law of King’s College London in the International Financial & Commercial Law and International Tax Law LLM programmes.
Oktavia co-wrote the General Report on investment funds for the 2019 IFA London Congress and is the author of the Wolters Kluwer book Taxation of Derivatives and Cryptoassets, 2nd edition, 2024.
Oktavia has written extensively on the taxation of derivatives, investment funds and cryptoassets. She frequently speaks at domestic and international tax conferences on topics relevant to globally acting multinationals and HNW individuals. Her expertise spans across a wide range of international tax topics, such as the application of Pillar Two to multinationals and the tax treatment of transactions involving derivatives, cryptoassets or investment funds. Oktavia has a special interest in taxation issues that are of concern in the developing world.

Shaun Cartoon is a creative and commercially focused tax lawyer. He is a partner of Australian commercial law firm Arnold Bloch Leibler, recently recognised by Best Lawyers as the 2024 ‘Law firm of the year’ for tax.

Shaun advises a range of clients, including ASX and foreign listed companies, high-net-worth individuals and family offices. He practices in corporate, international and employment taxes, with particular expertise in mergers and acquisitions, corporate restructures and employee share schemes. He also assists clients to navigate complex tax disputes with the Australian Taxation Office and has litigated significant cases through the Australian courts.

Shaun’s clients describe him as having “an uncommon combination of deep technical expertise (he is particularly peerless in the area of employee share schemes) and excellent interpersonal skills’.

Shaun has been ranked in the Legal 500 Asia Pacific as a Band 1 Next Generation Partner in Tax and is also listed by Doyle’s Guide and Best Lawyers as a leading tax lawyer.  In 2023, Shaun was recognised as a ‘star’ advisor in employee share schemes by the Global Equity Organization and was selected to join its inaugural class of Fellows.

Shreya (TEP) runs a boutique Indian law firm which specialises in complex tax and private client matters, with international tax as a strong area of focus. Her clients include some of the most well-known Indian and Indian origin families, some of whom also retain her in an external general counsel capacity. Prior to setting up independently, Shreya was a tax partner with, and led market leading private client teams at, two full service Indian law firms. She has been recognized for her tax as well as private client work by leading directories. Chambers HNW rates her Band 1, whereas Asian Legal Business ranked her one of Asia’s Top 15 Private Wealth Lawyers in 2022. Legal 500 (Tax) observes her ability to handle “the most difficult, emotional and intellectually challenging issues with grace and apparent ease”, whereas Chambers (Tax) notes that “she impresses everyone in terms of her knowledge and clear, crisp communication of issues”. Shreya is also academically active, having taught core and elective courses on tax as an adjunct professor at various Indian law schools since 2009. In a deeper commitment to tax research, she is pursuing a PhD in tax law (part time) at the University of Oxford, where she also convenes the Tax Law and Policy Discussion Group. She is an IBA Taxation Section scholar and obtained her LLM in 2009, from the Harvard Law School.

Esiri is a Partner with PwC Nigeria and previously worked in PwC New York. She heads the People and Organisation Unit in Tax responsible for compensation design and structuring, immigration and personal compliance services to companies in various industries. She also leads the Private Wealth Client Services team which provides specialised services to high net-worth families and entrepreneurs, and serves as the Family Business Leader for PwC Africa.

Esiri is a specialist in Family Business and Private Wealth Advisory, International Tax Planning and Structuring, ESG, and Compensation Design and Structuring. Her advisory and tax structuring experience spans multiple sectors including the oil and gas, telecommunications, power and utilities, manufacturing and FMCG.

Esiri’s expertise in private wealth management and family governance is exemplified through her extensive track record of advising multigenerational family businesses and ultra-high-net worth individuals. Her work extends to designing robust family governance structures and holding company setups, and ensuring optimal structuring for wealth transfer and preservation. She has advised a Nigerian investment bank on structuring its family office services division, supporting strategy development, target operating model design, and recruitment of the C-Suite team.

Esiri holds a BSc (Hons) in Microbiology from the University of Ibadan. She is also a Fellow of the Association of Chartered Certified Accountants (ACCA), Chartered Institute of Taxation of Nigeria (CITN) and the Institute of Chartered Accountants of Nigeria (ICAN). She has professional certifications in the Private Equity Master Class from London Business School, Sustainability Strategies and Circular Economy from the Cambridge Judge Business School and International Tax from the New York University. Esiri serves as a Non Executive director on the board of several companies. She mentors, writes articles and speaks regularly at conferences. She has won several awards for her leadership roles and contribution to the Nigerian economy.

Chair

Liselott Kana is a law graduate from Stockholm University and a Master of Laws graduate from London School of Economics. She worked in London for Arthur Andersen & Co and since 1990 she has been involved as a public official with international issues in Chile. In 1997, she was appointed Head of international taxation in charge of negotiating taxation treaties at the Revenue agency. She was a member of the permanent scientific committee of IFA until 2008 and a founder and president of the IFA branch of Chile in 2004. She has also been a president of IFA Latin America and she is actually Co-Chair of the United Nations Committee of tax experts. She teaches international tax at the Catholic University in Santiago and at the Vienna Akademie der Wirtschaftstreuhänder in Austria.

Secretary

Ricardo García Antón is an Assistant Professor in International Tax Law and European Tax Law at Tilburg University. From 2015 to 2018, he was a Research Associate and postdoctoral research fellow at IBFD Academic (Amsterdam, The Netherlands). He was educated at the University of Seville, where he graduated in Law in 2002. He holds a Master’s degree in Taxation from the Instituto de Estudios Fiscales/University of Seville (Spain) and an advanced Master’s degree in Comparative, European and International Law from the European University Institute (EUI). He received his Ph.D. from the EUI in 2015 with a thesis on the preliminary ruling procedure and direct taxation, which was awarded the prize for the best doctoral thesis by the European Association of Professors of Tax Law. Before joining the EUI in 2010, he worked for seven years as a tax practitioner, concentrating on tax due diligence and audits, real estate taxation, mergers and acquisitions, and litigation. He has more than 40 publications (articles and chapters in books) covering areas like tax abuse, transfer pricing, multilateralism, investment law and dispute resolution.

Panel Members

Prof. Dr. Stef van Weeghel is professor of international tax law at the University of Amsterdam and chair of the Board of Trustees at IBFD. He recently retired from PwC on 1 July 2023, where he was a tax partner since 2009 and Global Tax Policy Leader from 2014 up to his retirement, Before he joined PwC in 2009 he was partner at law firms Stibbe and Linklaters, where he practiced in Amsterdam and New York.
His focus is on tax policy and tax controversy, with research covering tax treaties and investment treaties. He regularly acts as expert-witness or co-counsel in tax disputes and in investment treaty and commercial arbitration. He is consulted by the private sector and governments, chaired a government-appointed Dutch tax reform committee, appeared before both chambers of the Dutch Parliament and the TAXE and PANA Committees of the European Parliament. He is immediate past chair of the PSC of IFA, an honorary member, has acted as IFA branch and general reporter, as chair of the IFA-OECD Seminar, and as secretary and chair of the Dutch branch of IFA. He authored and co-authored several books and numerous articles on Dutch and international taxation and has lectured extensively. He received his law degree from the University of Leiden (1983), was admitted to the Amsterdam Bar (1987), obtained an LL.M. in Taxation from NYU (1990) and received a doctorate in law from the University of Amsterdam (1997).

Claudia Annacker is an independent arbitrator and counsel, specializing in international arbitration and public international law. She has more than 25 years of experience in international dispute settlement. Prior to January 2024, she was a partner at Dechert and prior thereto a partner at Cleary Gottlieb.

Claudia has represented sovereign and private parties in more than 50 investment arbitrations, in inter-State and commercial arbitrations and before the European Court of Human Rights. Claudia has also served as an arbitrator in investment treaty and commercial arbitrations. She is a member of the ICSID Panel of Arbitrators and serves on the SIAC Court of Arbitration and VIAC’s Board.

Claudia holds a Ph.D. and venia legendi et docendi (habilitation) in public international law from the University of Vienna. She is an adjunct professor at the University of Vienna where she teaches advanced research seminars in public international law and supervises PhD theses. She also regularly lectures at other leading universities.

Annet Oguttu is a professor of taxation and the Director of the African Tax Institute at the University of Pretoria. She holds a doctorate in tax law and specialises in international tax law.

She is the author of: the ground-breaking book “Base Erosion and Profit Shifting: A Blueprint for Africa’s Response” (IBFD, 2021); the seminal book “International Tax Law: Offshore Tax Avoidance in South Africa” (Juta, 2015); co-author of “Tax Law: An Introduction” (Juta, 2024) and has contributed several book chapters. She has published numerous articles in various accredited journals and presented her findings in many international conferences – often as the Key Note Speaker. She has written commissioned reports for many international bodies.

She is rated as an established researcher by South Africa’s National Research Foundation. She is a Research Fellow of: IBFD Centre for Studies in African Taxation; Abe Green Baum Research Fellowship of the School of Taxation and Business Law at the University of New South Wales; and University of Michigan’s Presidential Scholars Fellowship.

Rasmi Ranjan Das is a former member of Indian Revenue Service with 34 years of experience in poficy making and implementation of direct tax laws in India. In his last assignment before his voluntary retirement, as Chief Commissioner of Income Tax (International Tax) in India’s Ministry of Finance, he was responsible for managing and guiding a team of senior and middle management level officers in taxation of non-residents including transfer pricing. Before this, he was the Competent Authority of India for tax treaty negotiation, exchange of information and resolution of BAPA and MAP cases for countries in North America and Europe. He represented India in the G-20/BEPS/lnclusive Framework and was Member of its Steering Group. He is also member of current United Nation Committee of Tax Experts. Earlier, as part of the team responsible for Tax Policy and Legislation in India, he was involved in some key policy initiatives in international tax including those relating to Interest limitations, secondary adjustments, and Significant Economic Presence (SEP). Rasmi holds a Post Graduate Degree in Public Policy and Management from Indian Institute of Management, Bangalore, and a Post Graduate degree in International Relations from Jawaharlal Nehru University, Delhi. He has authored papers on subjects like whether value creation is relevant for allocation of taxing rights; on gradual loss of authority of AoA on attribution of profit to Permanent Establishment; and whether QDMTT is right for developing countries. Recently, he co-authored a paper titled “Beyond the Two Pillars-A simplified approach for taxing Multinationals”.

Chair

Stig Sollund has his Master of Laws degree from the University of Oslo (1975). After serving as deputy judge at Lyngdal district court he has practiced tax law in the public and private sector for more than 40 years, most of the time at the Norwegian Ministry of Finance. He retired from his most recent position as director for international tax in 2022. At the MoF he has held various leading positions i.a. responsible for petroleum and other energy tax legislation, transfer pricing, negotiation of tax treaties and MAP/APA for petroleum companies. Over a period of 40 years he has been a delegate to the OECD Committee on Fiscal Affairs and working parties for transfer pricing, tax treaties, BEPS and the digital economy. He was a member of the UN Committee of Tax Experts from 2005 to 2017 i.a. co-ordinating the work on the UN Practical Transfer Pricing Manual, and is currently member of the subcommittees on Extractive Industries taxation and on Transfer Pricing. As member of IFA he has served as Chair for the Norwegian IFA Branch, been member of the Finance Committee and national reporter several times. He has been a regular participant at the congresses since 1986 and occational panelist at seminars. He was the chair of the panel on «Energy taxation» at the 2002 IFA Congress in Oslo.

Secretary

Panel Members

Monique has been working as transfer pricing controversy specialist for over 30 years. She has led Global Transfer Pricing and EMEA tax controversy teams, worked for the US Internal Revenue Service (IRS) in their APA team and served as adviser to the US competent authority when with the IRS’ Associate Chief Counsel International.

She handles tax and transfer pricing audit settlements, APAs and MAP requests. Monique advises the United Nations Tax Committee since 2010. She assists the United Nations’ Financing for Development Office with training materials for tax authorities in developing countries and has trained tax inspectors for organisations such as the Inter-American Centre of Tax administrations (CIAT) and the African Tax Authorities Forum (ATAF). She contributed materially to the UN TP Manual’s Methods, Intragroup Financial Transactions, Dispute Avoidance and Resolution chapter and the guidance on transfer pricing and carbon credits.

She is regularly recognized as tax disputes lawyer or as Highly Regarded transfer pricing practitioner, most recently for 2025 by ITR. Monique uses her expertise to educate the next generation of lawyers, and has been teaching transfer pricing at leading universities for the vast majority of her career.

She frequently authors thought leadership materials and has published and contributed to 195 professional publications

Jim Robertson is a non-executive director in the Scottish Government, former chair of its Audit & Assurance Committee and member of its Global Climate Emergency Board. He is a Senior Fellow of the International Tax & Investment Center, an education foundation based in Washington DC. In that role he delivers capacity-building programs to tax officials in developing countries together with the IMF, World Bank, OECD and UN. He is a member of the UN Subcommittee on Extractive Industries Taxation, the UN Subcommittee on Environmental Taxation and co-chair of its Energy Transition workstream. Jim chairs the academic board of the Advanced Diploma in International Tax of the UK Chartered Institute of Taxation. He sits on the governing Council of the Institute of Chartered Accountants of Scotland.

Jim qualified with PwC in 1981 and then joined Shell. He had nine different tax and finance roles in Shell and lived in London, The Hague, Kuala Lumpur, Aberdeen and Houston. He was a founder member of Shell’s Finance Social Investment Network which connected staff to voluntary organizations in need of finance skills and experience, personally acting as mentor/coach to the owner of a cooking stoves business in Ethiopia. In Shell Finance he had global responsibility for promoting professional qualifications and for communications on diversity & inclusion. He was global head of oil & gas tax in Shell for 11 years.

Michael Hewson is the founder and Director of Graphene Economics, a specialist TP advisory firm. He has over 19 years of experience in TP in Africa. Graphene Economics was named as the 2024 African TP Firm of the Year by the International Tax Review.

Michael is a member of Transfer Pricing Economists for Development, a Paris-based non-profit organisation focused on providing input in the area of TP in developing countries. Previously, he was a partner at one of the Big 4 in South Africa where he was responsible for supporting the transfer pricing teams across Africa.

He has an MCom in Financial Economics, Honours in Econometrics as well as a Higher Diploma in Tax (Law). Michael has been a guest lecturer on the topic of TP at the University of Johannesburg, the University of Pretoria and the University of Fort Hare and has contributed to three books and several articles on transfer pricing. He has also given training in DRC, Ghana, Kenya, Mozambique, Tanzania, UAE and Zimbabwe. His clients include large listed multinational enterprises operating in various different industries.

Christopher Rice has over 25 years of experience in Global Tax. He is responsible for all Tax and Corporate Structuring across the globe. His tax teams work closely with the various businesses to manage all tax affairs for Shell, including Policy/Advocacy; Advice/Structuring; Filling and Reporting; and Dispute Resolution.

Christopher is Executive Vice President Taxation & Corporate Structure for Shell. Shell is a global group of energy companies with operations in more than 80 countries. Shell uses advanced technologies and takes an innovative approach to help build a sustainable energy future. Shell is a customer-focused organisation, serving more than 1 million commercial and industrial customers, and around 32 million customers at 46,000+ retail service stations daily.

During his career at Shell, Christopher worked across various businesses including Marketing, Retail, Manufacturing, Refining, Trading, Exploration and Production, Chemicals, and New Business Development. He previously served as Tax Counsel for Exploration and Production and Americas New Business Development; Regional Tax Manager for Latin America; Head of Tax for the USA Tax Organization; Vice President Tax Global Downstream Businesses; Vice President Tax – Americas; and Vice President Tax Global Upstream/Projects and Technology.

Christopher currently serves on several boards. He is a Board Member and Company Representative for the Extractive Industries Transparency Initiative organization; The Shell Transport and Trading Company Limited; and The Shell Petroleum Company Limited. Christopher has previously served as Board Member and Executive Committee Member for the Global Business Alliance organisation. He also previously served as a Trustee of the Shell Pension Plan and Shell Provident Fund. He was Vice Chairman of the Trustees for part of that period and served as a member of the Investment Committee of the Shell Pension Plan and the Shell Provident Fund.

Christopher is also the co-founder of a small foundation supporting children with dyslexia in at risk communities – Reaching Individuals and Communities Everywhere Foundation.

Fernando Zuzunaga is the Founding and Leading Partner of Zuzunaga & Assereto Abogados (Z&A), a firm renowned for its sophisticated Tax Law services. For 15 years, Z&A has been ranked as a Band 1 Leading Firm by Chambers & Partners.

Fernando is highly regarded in the local tax landscape for promoting critical debate. Since 2014, he has directed the Latin American Institute of Tax Law (ILADT). Additionally, he has chaired the Tax Affairs Committee at the Sociedad Nacional de Minería, Petróleo y Energía (SNMPE) since 2013. In 2023, he expanded his influence internationally as the Peruvian Representative for tax matters at the OECD’s Business and Industry Advisory Committee (BIAC).

For over two decades, Fernando has been a lecturer at the Pontificia Universidad Católica del Perú (PUCP), the Universidad Peruana de Ciencias Aplicadas (UPC), and the Universidad EAFIT in Colombia. His teaching focuses on international tax management.

In practice, Fernando has been a key advocate in major administrative and judicial cases involving mining tax issues. He also serves as an expert witness in high-stakes proceedings before the International Commercial Arbitration (Ontario) and the ICSID of the World Bank.

Fernando’s institutional work includes leading the firm’s “Conflict in Figures Z&A” project for seven years, analyzing tax proceeding trends at various stages. He has provided expert advice to Parliamentary Commissions on key tax reforms and legislative proposals, and this year particularly regarding mining taxes.

Fernando holds a law degree and a Master’s Degree in Legal Research from PUCP. He has specialized courses in International Taxation at IBFD, OECD, Universidad Austral, and Leiden University.

With over 30 years of experience in tax and corporate matters, especially within the extractive industries, Fernando received numerous accolades, including “Band 1” by Chambers & Partners for 15 years, “Leading Individuals” by The Legal 500, and “Global Elite Thought Leader” by Who’s Who Legal

Viola Tarus is a Policy Advisor, Tax and Extractives focused on the IGF’s taxation and financial benefit optimization work. She is trained as an economist, specializing in extractives, and worked with Oxfam and the National Oil Corporation of Kenya before joining the IGF. Viola is based in Nairobi, Kenya.

Chair

Armando has more than 25 years of experience related with aspects of international tax policy, including the development and review of proposals for Mexican tax reform, the promulgation of regulations and administrative guidance regarding the Mexican taxation of cross-border income, and the negotiation of tax treaties.

He advises clients on Mexican international tax matters, including tax planning with respect to their structures, operations, and transactions. In particular, he has extensive experience advising on issues relating to international tax policy, tax treaties, the source of income rules, CFC rules and foreign tax credits.

He was chairman of the UN Tax Committee from 2009 to 2017, Chairman of the OECD Working Party 10 on Exchange of Information and Tax Compliance from 2010 to 2016, and Vice-chair of the OECD Committee on Fiscal Affairs from 2014 to 2015.

He has been an international tax consultant at the World Bank Group, United Nations, Inter American Center of Tax Administrations and International Monetary Fund.

Secretary

Roberto, with more than 20 years of experience, is a renowned lawyer and accountant, who has focused his professional practice on tax consulting, specialized in finance, real estate, M&A, and international taxation. He is characterized by offering his clients a comprehensive and accurate advice.

He joined Chevez Ruiz Zamarripa in 2004 and was admitted as Partner in 2017. He is an active member of the Equity, Diversity and Inclusion Committee of the Firm.

Roberto teaches several tax courses at Instituto Tecnologico Autonomo de Mexico (ITAM) and Universidad Iberoamericana (UIA), in undergraduate and graduate programs. Moreover, he has authored articles on tax matters published by important international publishing houses.

He is a frequent speaker at national and international tax conferences.

Panel Members

Manal Corwin is the Director of the Centre for Tax Policy and Administration at the OECD. She took up her duties on 3 April 2023.

Prior to her role at the OECD, Manal was principal-in-charge of KPMG’s Washington National Tax Practice and America’s Regional Tax Policy Leader; a member of the KPMG Board of Directors and Lead Director. Earlier roles at KPMG included national service line leader for International Tax and leader of KPMG’s Global BEPS Network. Prior to this, during her time at the U.S. Treasury Department, Manal served as International Tax Counsel in the Office of Tax Policy and as the Deputy Assistant Secretary for International Tax Affairs. Manal shaped the development and implementation of FATCA and was head of the delegations responsible for negotiating income tax treaties with several countries. Before this, Manal practised as an attorney specialising in interational taxation and served as editor-in-chief of the Boston University Law Review. Manal has also served as the United States delegate and Vice Chair to the OECD’s Committee on Fiscal Affairs and was actively engaged in the origination and development of the OECD Base Erosion and Profit Shifting (BEPS) initiative. She also served as the U.S. delegate to the Global Forum on Transparency and Exchange of Information for Tax Purposes.

An American national, Manal has a Bachelor of Arts (cum laude) from Harvard University and a Juris Doctor (magna cum laude) from Boston University School of Law. She is fluent in English and Arabic and conversant in French.

Dr. Achim Pross is Deputy Director within the OECD’s Centre for Tax Policy and Administration (CTPA). In this role, he has overall responsibility for a number of key outputs including the Standard for Automatic Exchange of Financial Account Information in Tax Matters (Common Reporting Standard or CRS), the OECD’s work to address the tax challenges arising from the digitalisation of the economy, many of the BEPS actions, as well as the work on tax administration and tax certainty and on countering tax crimes and other financial crimes. He joined the OECD in 2001.

Prior to joining the OECD, he worked in the tax department of a large US law firm working from offices in Washington D.C., Paris and London. Previously he was an assistant at Munich University’s Research Centre for Foreign and International Tax and Financial Law.

Dr. Pross is a lawyer by background. He received his legal training at the University of Munich, the London School of Economics and Georgetown Law Centre, Washington D.C. He holds a PhD (Summa cum laude) in international taxation and was the winner of the International Fiscal Association’s Mitchell B. Carroll Prize in 1997.

Prof Dr Englisch holds a chair for public law and tax law at Münster University. His research focuses on International and European tax law covering both, direct and indirect taxation. Dr Englisch serves as an advisor in expert groups of the OECD and of the EU Commission since 15 years, and he has given advice also to national governments, NGOs and MPs. He is also a visiting professor in several LL.M. programs. Dr Englisch has published several books as well as approx. 200 scholarly articles, and he has given approx. 150 invited presentations.

Tim Power is Director for Business and International Tax at HM Treasury.

His teams have responsibility for International Tax and Corporation Tax including tax base design, base protection measures, transfer pricing, tax treaties, and tax transparency.

Tim was elected Chair of the CFA in December 2023.As Chair of the CFA he also serves as Co-Chair of the OECD-G20 Inclusive Framework on BEPS alongside…

Tim has significant experience representing the United Kingdom in multilateral discussions within the OECD, starting with the origins of the Base Erosion and Profit Shifting (BEPS) project in 2013. He has had long-standing involvement in the Steering Group of the OECD/G20 Inclusive Framework on BEPS and since 2022 has served as Co-Chair of the Task Force for the Digital Economy that was tasked with developing a Multilateral Convention (MLC) to implement Amount A of Pillar One.

Phil West is widely regarded as one of the premier international tax lawyers in the United States. Formerly Steptoe’s global chairman, he is a trusted adviser to major multinationals, high-net-worth individuals, and governments on international tax issues, and often achieves exceptional results for clients in complex and high-profile tax controversies; legislative, regulatory, ruling, and competent authority proceedings; transactions; and other matters. He advises clients on both technical questions and issues of broad policy significance, and has served as an expert witness in major tax controversies involving taxpayers around the world. Drawing on four decades of private sector and public service experience, including in the Treasury Department, as the U.S. government’s most senior international tax law and policy official, he is regularly called on to advise clients and government officials alike with respect to sensitive and complex tax matters, and often assumes responsibility for defusing, and then resolving, matters with taxing authorities that have become needlessly adversarial. Mr. West has testified before Congress several times on international tax matters.

At the Treasury Department, Mr. West played a central role in virtually every policy, legislative, and regulatory development in the international tax area. He led tax treaty negotiations, discussions, and ratification efforts involving countries throughout the world, and led the U.S. tax work at the OECD. He has practical experience with many foreign tax systems and good relationships with tax officials and private practitioners around the world. Chambers, The Legal 500, and other rankings consistently place him in the top tier of international tax practitioners.

Leon is a corporate tax director with over 25 years’ experience. He is a Chartered Accountant and holds a Masters Degree in Tax law and currently heads the Group Tax function of the FirstRand Group, a large listed financial services group listed on the JSE. Leon is also the deputy chair of the Direct Tax Committee of the Banking Association of South Africa and an executive committee member of the South African branch of IFA.

Chair

Belema R. Obuoforibo, CTA ATT (Fellow) is Director of the IBFD Knowledge Centre, Member of IBFD’s Executive Board, and Chair of the Centre for Studies in African Taxation (CSAT).

Belema is also Extraordinary Lecturer in the Department of Economics, University of Pretoria, where she lectures on international taxation. She is also a member of the UN Subcommittee on Wealth and Solidarity Taxes.

Before joining IBFD, Belema worked in London for many years as a UK-qualified Chartered Tax Adviser.

Belema is an authoritative speaker, lecturer, and presenter on international tax issues. She has lectured and presented extensively in Europe, Africa, Asia, and the Caribbean. She is the Director of the annual Africa Tax Symposium, the leading global conference on African taxation.

Belema is a noted writer and editor in the field of international taxation. She is widely published, including as an author of the esteemed publication, Global Tax Treaty Commentaries, for which she writes the chapter on Treaty Residence. She also serves on the editorial boards of leading international tax publications, including the Bulletin for International Taxation and the European Taxation journal.

Belema also serves in an advisory capacity for various African governments, particularly on matters relating to tax policy, tax treaties and effective domestic tax legislation.

Secretary

Aisha Aize Isa is a seasoned tax practitioner who specializes in international taxation and IBFD’s Manager for the Centre for Studies in African Taxation (CSAT), and Managing Principal for Africa and the Middle East Department, within the IBFD Knowledge Centre in Amsterdam. There she oversees the identification of tax policy issues pertinent to Africa, provides authoritative research and insights on these issues; develops practical framework for policy solutions on such issues and is involved in capacity development within the region.

She is an expert in international taxation and specializes in tax treaties and taxation of the digitalized economy of which she has been extensively involved in providing trainings in these areas. She was also a facilitator for the African Tax Administration Forum (ATAF) technical assistance to governments on tax treaty negotiations and double taxation agreements.

Prior to joining IBFD, she served as a Manager at the International Tax Policy Division of the Federal Inland Revenue Service (FIRS), Nigeria, where she was a tax treaty negotiator and involved in policy and legislation development on international & domestic tax issues.

Her work primarily focused on developing domestic policies on taxation of cross-border transactions, developing the implementation framework for international tax rules and standards, as well as serve as a focal officer on policies on international tax in general of which she represented Nigeria in several international committees and working groups including the OECD’s Tax Force on the Digital Economy (TFDE), Working Party 1, Working Party 11, Forum for Harmful Tax Practices, as well as, in the UN subcommittee on Tax Treaty Manual. She also served in the secretariat of the National BEPS Implementation Committee of Nigeria where she was saddled with the responsibility for developing policies to implement BEPS outcomes.

She has a bachelor’s degree in International Relations and has Master degrees in Public Policy and Taxation.

Panel Members

Des Kruger was previously a Partner, and now Consultant, in the Tax Practice at Webber Wentze Attorneys. He has studied law and tax at the universities of KwaZulu Natal and Wits in South Africa, and Harvard in the United States of America. Des has specialised in all aspects of taxation, including international tax, corporate tax and value-added tax, for more than 42 years.

During that time he spent 12 years in total at Inland Revenue/South African Revenue Service, where he was a Deputy Director (Legal Drafting) and then subsequentely a Specialist in the then Legal and Policy Division.

He has co-authored Value-Added Tax in South Africa and Broomberg on Tax Strategy and is currently co-editor of Business Tax and Company Law Quarterly.

Des’ expertise has been recognised by various international research organisations including Chambers Global and the prestigious International Tax Review. He has also been named as one of the top tax consultants in South Africa by the International Tax Review and was named as Lawyer of the Year: Tax, 2010 by Best Lawyers.

Des has Advised both Margo and Katz Tax Commissions of Enquiry into the Tax System of South Africa, and was a member of the VAT Ad-hoc Committee of the Davies Tax Committee.

He is presently an Executive Member of IFA; South Africa Branch.

Ms. Mercy Mbithi is currently an international tax technical Advisor with the African Tax Administration Forum (ATAF). ATAF’s mandate within this space offers technical assistance to member states in areas of international tax including: drafting and implementation of the legal regulatory framework and conduct of Transfer Pricing tax audits. ATAF is firmly involved in standard setting in international taxation through development of products for use by member countries that address live tax risks around cross border economic in the African continent. As part of its service to member States, ATAF holds the critical role of amplifying the African voice in global standard setting Fora.

Prior to this role, Ms. Mbithi worked in the International Tax Office within the Kenya Revenue Authority (KRA) for 15 years; actively conducting transfer Pricing tax audits and operationalization of international tax policy. Further, she served as the Chairperson to the Cross Border Taxation (CBT) Technical Committee within ATAF.

She has extensive experience in international tax Policy having represented Kenya on international tax standard setting as both the Vice Co-Chair of Working party 6 and the Principal Kenyan Delegate to the Task force on taxing the Digital Economy housed within the OECD- Inclusive framework.

Her passion lies in ensuring the Global South has the capacity and resources it needs to ensure sustainability of its development goals.

Emily Muyaa is Chief of the Capacity Development Unit in the Financing for Sustainable Development Office of the UN Department of Economic and Social Affairs. Muyaa leads the development of a coherent strategy for capacity development programmes and activities at national, regional, and global levels in financing for sustainable development, including supporting an integrated approach to policy and capacity development work in the area of international tax cooperation and domestic resource mobilization. Ms. Muyaa is the UN focal point for the Technical Working Group of the Platform for Collaboration on Tax (PCT), a joint initiative of the Secretariats of the IMF, OECD, UN and World Bank.

She is the focal point for the UN Tax Committee’s Subcommittee on Environmental Taxation.

Previously, she led IBFD’s Sub-Saharan Africa region and was manager of the IBFD Centre for Studies in African Taxation (CSAT). In 2021, she led a prestigious research project that resulted in the first-ever IBFD comprehensive publication on African taxation, the book Base Erosion and Profit Shifting: A Blueprint for Africa’s Response authored by Professor Annet Wanyana Oguttu.

Ms. Muyaa has also worked in the Transfer Pricing Division at Kenya Revenue Authority and served on the UN Transfer Pricing Subcommittee.

Ms. Muyaa is a founding member of Transfer Pricing Economists for Development (TPED), a think tank promoting business economics in transfer pricing for emerging economies. She is a visiting lecturer at the University of Cape Town.

Her academic qualifications include a law degree from the University of Nairobi, a postgraduate diploma in law, and an LLM in international taxation from Leiden University. She is a member of ACCA. She is an advocate of the High Court of Kenya and a member of the Law Society of Kenya. She has widely published on international taxation, with a focus on transfer pricing.

Troopti is the Head of Tax for MTN. MTN is Africa’s largest mobile network operator providing voice, data, fintech, digital, enterprise, wholesale and API services in 19 markets. She joined from PwC where she was a partner in the Corporate Tax department. She was previously employed as the Head of Tax: Sub Saharan Africa for General Electric.

Troopti is an admitted Attorney and has experience in Corporate Tax, Mergers and Acquisitions and Tax Incentives. She also has experience in the areas of Tax policy and Revenue Authority engagement and has worked extensively across Africa on tax related matters.