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Tuesday, December 18, 2018

PANEL 1. GAARs history, theory and new developments under BEPS

Mr. Enkhjavkhlan Tseyen /Moderator/

Mr.Enkhjavkhlan Tseyen is the Head of Tax Administration and Cooperation Department at the General Department of Taxation of Mongolia. Previously, Mr.Enkhjavkhlan was a managing partner of Taxand LLC and a tax manager at PWC Mongolia. Before working for these business entities, he worked as a tax official at the General Department of Taxation for 10 years. He has been practicing in taxation for almost 20 years. Mr.Enkhjavkhlan holds bachelor’s degree of Business Administration in Accounting, from the Institute of Finance and Economics, Mongolia. Mr.Enkhjavkhlan also holds two masters’ degrees: Master of Economics in International Economics, Public Policy and Taxation from Yokohama National University, Japan and Master of Advanced Studies in International Tax Law, at International Tax Center from Leiden University, Netherlands.




Prof. Rick Krever

Professor Rick Krever is an international taxation law and policy expert based in Australia.  He has been closely involved in modern Australian tax reform initiatives with roles on several key government tax reviews.  In addition, he has been a professor-in-residence at both the Australian Taxation Office and the Australian Treasury, and has twice been seconded to the International Monetary Fund. His international visiting professor positions include appointments at Osgoode Hall Law School, Erasmus University and Harvard Law School. Professor Krever has worked with a variety of international organizations including the United Nations, European Union, Asian Development Bank, and World Bank as a post-conflict and development specialist, providing assistance in tax law design and drafting in regional and other countries including East Timor, Tonga, Solomon Islands, Vietnam, China, Mongolia.  Rick is the author of 75 articles in quality journals, 13 books (several in multiple editions), and 73 book chapters as well as editor of 26 books.



Prof. Minoru Nakazato 

Mr. Minoru Nakazato is Professor of Law at the Graduate School of Law of the University of Tokyo, where he teaches Tax Law, Law & Economics, and International Transactions. He has served, since 2013, as Chairman of the Tax Commission of the Japanese Government, which is an advisory committee on taxation to Prime Minister Shinzo Abe. He has also served as President of the Japan Society for Tax Law since 2012.

Professor Nakazato has previously visited Columbia in February 2017, March-April 2000, and March 2006. He was Visiting Professor at UCLA School of Law in 1989, and Harvard Law School from 2004 until 2005.



Mr. David Smith

David Smith is a Consultant to PwC’s tax practice in Hong Kong and China. He commenced his career with the Australian Taxation Office before joining the tax profession in Hong Kong more than 30 years ago, where he spent most of his subsequent career apart from some time in the Middle East. During his career, David has advised many of the world’s largest corporate groups across all industries on Hong Kong and international tax issues, tax planning, structuring and dispute resolution.  This has provided David with an enviable understanding of the technical and practical aspects of local and international tax issues. In his role as Consultant to the tax practice, David acts as an experienced resource to assist partners and staff in relation to complex technical issues, dispute resolution and litigation support.  As a consequence, he has involvement in a significant number of the firm’s clients’ major transactions as well as domestic and cross-border tax disputes. Through this work he gains a unique insight into trends regarding issues being scrutinized, attitudes of revenue authorities and methods of dispute resolution. David also plays important roles in the practice with regard to thought leadership and international tax policy developments and trends.  This ensures that the firm is well placed to ensure that its services and advice will withstand the stricter rules and practices which they will be measured against, and the greater transparency which they will face, in the years ahead.  In this capacity, David has been heavily involved in understanding, analyzing, commenting and advising on the OECD’s Base Erosion and Profit Shifting (“BEPS”) project over the last five years. David is a regular speaker and author of articles on tax matters in Hong Kong and China.


Prof. Nii Ayi Aryeetey

NII AYI ARYEETEY is an accomplished Chartered Tax Practitioner with extensive involvement in tax administration. His areas of expertise include general tax policy analysis and revenue forecasting, development of tax legislation, VAT design and administration, integration of revenue administration, tax office management, tax training and capacity building, public tax education and international relations in tax policy. He retired from the public service of the Republic of Ghana in January 2015 as the Deputy Commissioner (Policy and Programmes) of the Domestic Tax Revenue Division (DTRD) of the Ghana Revenue Authority (GRA) and thereafter served as a Technical Advisor at the Tax Policy Unit of the Ministry of Finance on a two-year contract which ended in February, 2017. He is currently engaged in private practice as a Chartered Tax Practitioner. He is a product of Adisadel College and the University of Cape Coast both in Ghana. He has undertaken a number of post graduation training courses in management and tax administration, notably courses in “Tax Analysis and Revenue Forecasting” at Duke University, Durham NC, USA, “International Taxation (Senior Course)” at the National Tax College, Tokyo, Japan, World Trade Organisation Accession and Compliance at the International Law Institute (ILI), Washington DC, USA and “International Petroleum Management Certificate Program”, IHRDC, Boston MA, USA. He is a Fellow and current President of the Chartered Institute of Taxation (Ghana). He is also the President and Chairman of Council of the West Africa Union of Tax Institutes (WAUTI). He was adjudged the “Tax Personality of the Year” at the 2016 Ghana CFO Awards ceremony held in Accra in November, 2016. The Annual Ghana CFO Awards recognizes Chief Finance Officers and Finance Executives and Teams across all industry sectors in Ghana, whose outstanding leadership practices have raised the standards of accountability in their professions and promoted growth in their institutions or organisations in support of national economic growth.Nii Ayi Aryeetey has presented technical papers on various aspects of taxation at several local and international seminars and workshops. He also served as a Resource Person at the first three Meetings of the OECD Global Forum on VAT held in November 2012 (Paris, France), April 2014 (Tokyo, Japan) and November 2015 (Paris, France). Between 2012 and 2014 he was involved in activities of the African Tax Administration Forum (ATAF) as the Chair of the Indirect Taxes Working Group of the Forum.

PANEL 2. GAARs: different aspects for resident and source countries

Mr. Thomas Lee

Mr.Thomas Lee started his career and spent many years working in the Inland Revenue Department of Hong Kong Government, specializing in tax disputes resolution, tax litigations, tax investigations and prosecutions of offences under the Inland Revenue Ordinance (IRO), last position as senior assessor (1976 to 1993).  He was Partner and Head of Tax, Trust and Corporate Advisory Services of a Hong Kong CPA firm belonging to a second tier international accountancy network (1998 – 2002).  Since 2003 Mr.Thomas Lee served as Chairman and Managing Director of a professional consulting group comprising of international tax and trust advisory, corporate services, consulting and accounting firms, with over 50 professional and supporting staff, and offices in Hong Kong, Macau and Shenzhen, China.   He worked as a specialist in international and cross border taxation, wealth succession planning, civil tax litigations, pre-IPO and corporate finance related structuring and advisory work involving China, Hong Kong and overseas operations, and served as independent tax advisor and provided tax opinions on Hong Kong and China tax issues regularly for companies having submitted applications to the Hong Kong Stock Exchange for public listing of shares. He is a former president of the Taxation Institute of Hong Kong (www.tihk.org.hk) (1999 to 2002) and a representative of Taxation Institute of Hong Kong at Joint Liaison Committee of Taxation of Hong Kong, a committee which the Hong Kong Government consults to on tax policies and practices. He served as an Executive Committee member of Hong Kong Branch of Society of Trust & Estate Practitioners (UK). Mr.Thomas Lee is immediate past president and honorary advisor of Asia-Oceania Tax Consultants’ Association (www.aotca.org), an umbrella association of tax professionals practicing in 16 tax jurisdictions in Asia and Oceania. He is a Founding member and Steering Committee member of International Tax Specialists Group (www.itsgnetwork.com). Mr.Lee served as Chief Executive Officer, Executive Director, Non-Executive Director, Independent Non-Executive Director and Chairman of Audit Committee of several companies listed on Hong Kong Stock Exchange.  He speaks regularly on issues relating to tax and public finance in professional and international conferences.   

Academic Background

Mr. Thomas Lee holds higher education diploma in Accountancy from Hong Kong Polytechnic University and Bachelor of Laws from University of London, UK. He also received his Master of Law degree from University of London, UK.  

Professional Memberships

  • FCPA (practicing), Hong Kong Institute of Certified Public Accountants
  • Fellow, Association of Chartered Certified Accountants (UK)
  • Member, Chartered Institute of Secretaries and Administrators (UK)
  • Member, The Hong Kong Institute of Chartered Secretaries
  • Fellow, Taxation Institute of Hong Kong
  • Fellow, The Hong Kong Institute of Directors
  • Barrister, Lincoln’s Inn, UK
  • Member, STEP (UK)
  • Member, Macao Society of Certified Practicing Accountants
  • Certified Tax Adviser, Hong Kong


Prof. Piergiorgio Valente

Professor Piergiorgio Valente has acquired extensive and specialized experience (almost 30 years) within the various areas of international tax, tax litigation, tax strategy and tax control. Some of his executive roles included being Partner and Director of the International Tax Planning Department as well as National Director of the BU Large Enterprises with one of the Big 4s; he was also Head of the Tax Department of the largest Italian Oil company.

Professor Valente teaches EU and International Tax and Transfer Pricing related courses at Rome’s Link Campus University, EU and Supranational Taxation at the Advanced Course for the Tax Police of the Revenue Guard Corps (Guardia di Finanza), and Taxation of Multinational Enterprises Lecturer at the “Jean Monnet” School of the Second University of Studies in Naples. He also regularly advises Governments on national and international tax issues. He is the President of CFE Tax Advisers Europe, Chairman of the International Tax Committee of the International Association of Financial Executives Institutes (IAFEI), and Vice Chairman of the Taxation and Fiscal Policy Committee of the BIAC (Business and Industry Advisory Committee to the OECD).


Ms. Wendy Guo

Ms.Wendy Guo is a tax partner of PwC China firm. She has about 30 years Chinese tax and international tax experience. She mainly assists multinational companies with structuring investment into and out of China, M&A, and other Chinese tax related matters. Prior to joining PwC China, Wendy was a tax Partner / Principal in another Big Four international accounting firm between 1998 and 2006 both in United States and China.  She worked on numerous cross border transactions including procurement, manufacturing, financing, cross border supply chain issues and transfer pricing.  She assisted many multinational companies to develop tax strategies for their operations in China and was also a member of her firm’s global Supply Chain team.

Between 1988–1996, Wendy was a Principal Supervising Agent, State Administration of Taxation, People’s Republic of China and was mainly responsible for tax policies related to foreign investment and foreign expatriates working in China.  She participated as part of the negotiating team in income tax treaty negotiations with various countries, drafted transfer pricing regulations, and Income Tax Regulations for the Income Tax Law for Foreign Invested Enterprises that have been effective since 1991.

Wendy has published many articles on Chinese tax issues, including Chinese tax developments overview (BNA Daily Tax Report, 2006), Chinese holding companies (International Tax Review. 2004), M&A developments and strategies in China (US / International Tax Strategies, 2003), Corporate income tax reform in China (Practical Asian Tax Strategies, 2003) and Seconded employees and permanent establishments (Tax Notes International, 2016).  She is a frequent speaker at lecturers for international tax meetings.

Wendy received a Master in Taxation from the University of Denver, USA in 1997, a Master of Arts in Economics from Georgia State University, USA in 1994, a Master in Public Finance from the Fiscal Science Research Institute (Beijing) in 1988, and a Bachelor with a major in Economics from Nankai University in 1985. She is certified tax agent in China.


Mr. Telmuun Byambaragchaa

Mr. Telmuun is Head of Fiscal Revenue Division of the Ministry of Finance of Mongolia. He has been working on modernizing Mongolia’s tax system over the last 7 years. Currently, he is in the leading role on revising Mongolia’s General Tax Law, Corporate Income Tax Law and Personal Income Tax Law, which are under the Parliament discussion currently. Mr. Telmuun is also primary official in charge of introducing BEPS actions and exchange of information standards into the Mongolian tax system.

He holds MPA degree from Cornell University and two other bachelor’s degree in finance and economics. Mr. Telmuun also got his MA in International Law from National University of Mongolia with the thesis on comparative analysis on Mongolia’s tax treaty network and model conventions.





Mr. Ruston Tambunan

Mr. Ruston Tambunan is Managing Partner at CITASCO – Registered Tax Consultants, Jakarta. He holds Master of International Taxation, University of Sydney (Usyd), Australia, Master of Tax Administration and Policy, University of Indonesia (UI), Jakarta,

Graduate Diploma in Accounting, State College of Accountancy (STAN), Jakarta Professional Qualification. He is a Registered Tax Attorney, Registered Tax Consultant and Chartered Accountant.

He has professional membership from the following organizations:

  • Head of International Relation & Globalization at Indonesian Tax Consultants Association (ITCA)
  • Member of the International Tax Planning Association (ITPA)
  • Member of International Fiscal Association (IFA) – Indonesia Chapter


Mr. Phan Vu Hoang

Mr. Phan Vu Hoang is Tax Partner in Deloitte Vietnam. He has 22 years of experiences in providing tax planning, tax controversy, international tax advisory, tax restructuring and tax compliance services to meet the needs of multinational enterprises operating in Vietnam in a wide variety of industries such as banking and financial services, trading, real estate, manufacturing, FMCG etc.
Hoang has been nominated to be one of the Tax Controversy Leaders in Vietnam by International Tax Review for three consecutive years from 2016 – 2018. Hoang is the regular speakers in various tax seminars for Professional Associations, including ACCA, Vietnamese Tax Consultants Association, Vietnamese CPA, Vietnamese CFO Club etc. In his role Hoang also regularly speaks at Tax Dialogue events with representatives from the Ministry of Finance, General Tax Department in Vietnam and regularly contribute to the development of the tax policies and practice in Vietnam.
Hoang is the President of the ACCA Members Committee in Vietnam, and is an ACA (ICAEW – UK), a member of CPA (Australia), ADIT (UK) and Vietnamese CPA.

PANEL 3. GAARs and taxpayers’ right


Mrs. Munkhsoyol Baatarjav /Moderator/

Mrs. Munkhsoyol is the CEO of Institute for National Strategy, a non-government organization and a commentator on economy for Mongol TV.

Mrs. Munkhsoyol worked as a senior consultant on Public Finance Management for the Energy Efficiency Project of the German International Cooperation Agency (GIZ) and as an expert for the Governance and Public Finances Management Sector Review of the EU. Prior to join INS and GIZ, she worked at the Open Society Forum Foundation as an Economic Policy Program Manager. She has over sixteen years of experience of conducting and supervising economic and business development researches, policy analysis, projects and programs.

Mrs.Munkhsoyol also worked as a senior professional on a number of development projects including projects of USAID, UNDP/SIDA and Ministry of Social Welfare and Labour. She was a lecturer at the Mongolian University of Science and Technology. She ran for a Parliament seat in 2016 and came in third out of eight candidates.

Mrs. Munkhsoyol’s background is in economics, business administration and international finance and she holds a MBA from the Asian Institute of Technology in Thailand and an MSc from SKEMA Business School in France. She completed her Hubert Humphrey Fellowship Program at the Michigan State University in 2011.


Ph.D. Jiri Nekovar

Ph.D. Jiri Nekovar is named arbitrator for the Czech Republic, according to Article 9 of the Transfer Pricing Convention, as a member of the Advisory Commission of the Arbitration Convention on the Elimination of Double Taxation in Connection with the Adjustment of Profits of Associated Enterprises. He is the adjudicator at the Arbitration Court attached to the Economic Chamber of the Czech Republic and Agricultural Chamber of the Czech Republic. Nekovar is a judicial expert for business appraisal. He is the member of the Presidium of the Public Audit Oversight Board of the Czech Republic, and he is the Chair of the tax expert team of the Confederation of the Industry of the Czech Republic. He is the member of the Legislative advisory board of the Government of the Czech Republic, in the Commission of Regulatory Impact Assessment. He is Vice-Chair of the Board of Trustees of the University of Economics in Prague and the member of  Board  of Trustees of the Brno University of Technology. He is a member of the Academic Advisory Board of the Faculty of Finance and Accounting of the University of Economics in Prague, as well as a member of the Academic Advisory Board of the study branch of Financial Law and Financial Science at the Faculty of Law of Charles University.

Jiri Nekovar studied at the University of Economics in Prague. He received his Ph.D. at the Faculty of Law at the Charles University in Prague.

Since 1994, he has been active in the activities of the CFE. For fifteen years, Nekovar has been President of the Chamber of Tax Advisors of the Czech Republic. In 2006 he was elected Vice-President of the CFE, in the years 2013-2014 he was President. In 2015 he was voted in as an Advisor of AOTCA. Nekovar is the founding Chair of the Global Tax Advisory Cooperation Forum.


Dr. Stefan Huang

Dr. Stefan Huang is currently Consultant of Tax-Accountancy Association Union, Taiwan

Professor of Department of Tax Administration, National Taipei University of Business.

Experience: Dean of Department of Tax Administration, National Taipei University of Business, Tax Attorney at PwC Taiwan, Lecturer of Taiwan Judge Academy, Visiting Scholar of German DAAD Association and Max Planck Institute.





Mr. Chow Chee Yen

Mr. Chow Chee Yen is currently the Executive Director of Advent MS Tax Consultants Sdn Bhd. He has more than 27 years of tax experience and was involved in tax engagements concerning cross border transactions, tax due diligence review, restructuring schemes, corporate tax planning, group tax review and inbound investments.

Mr. Chow Chee Yen’s expertise is in high demand and he is a prolific trainer/facilitator/speaker for tax workshops, seminars and National Tax Conference organised by ACCA, CCH, CPA Australia, CTIM, MIA, MAICSA, MICPA and the STAR newspaper as well as in-house training for both professional firms and corporations.

He is a Council Member of the Chartered Tax Institute of Malaysia (FCTIM), a Fellow Member of The Association of Chartered Certified Accountants (FCCA) and a Chartered Accountant of the Malaysian Institute of Accountants (CA). He is also a graduate of the Malaysian Institute of Certified Public Accountants (MICPA) Examinations.



Mr. Tony Greco

Mr.Tony Greco is currently General Manager of Technical Policy for Institute Public Accountants.

Tony held the position of senior tax consultant with Taxpayers Australia for 8 years prior to becoming its former CEO. Tony commenced his professional career in Chartered Accounting before venturing into the commercial world, working for several large multi-national companies in diversified range of senior management positions. More recently has worked for Tax training organization as tax trainer and consultant .Tony is well known in the industry as a tax trainer, presenter and commentator on tax matters. Tony Greco joined the Institute of Public Accountants’ (IPA) as the senior tax adviser in 2009 and is the Institutes representative on a number of peak body forums with Treasury, ATO and Tax Practitioner Board. Tony has participated in numerous Parliamentary inquiries into tax administration and has assisted the Board of Tax as a member of one of their expert working committees. Tony is currently a member of the advisory panel for the Board of Tax.


PANEL 4. Tax anti-avoidance cases and GAARs development


Mr. Khishignemekh Regzedmaa /Moderator/

Khishignemekh (Nicky) Regzedmaa is a Senior Manager at EY in Mongolia being part of EY’s International Tax Services practice in Asia Pacific assisting clients in various areas of inbound investments into Mongolia. Nicky’s experience also extends to transfer pricing aspects including policy design and implementation.

Nicky majored in accounting and holds a MBA degree in business administration. Nicky also holds a bachelor degree in Law from Mongolian National University of Mongolia. Nicky has completed EY’s International Tax Academy and Transfer Pricing Academy.

Nicky is a Co-Chair of Tax Working Group at Business Council of Mongolia which is one of the most active business associations in Mongolia. He also chairs the Professional Service Committee of Mongolian Association of Certified Tax Consultants (MACTC).

Nicky has been awarded as ‘The Advisor of the Year – 2017’ by MACTC.



Mr. Anthony Tam

 Mr.Anthony Tam – Executive Director of Mazars Hong Kong, Formerly Chairman of Tax Faculty of Hong Kong Institute of Certified Public Accountants.  Mr.Anthony Tam has more than 30 years of professional experience in international taxation with proven track record in international taxation as well as Hong Kong and China tax, with a specialization in IPO, M&A and transfer pricing. He also leads the field audit / tax investigation team in Hong Kong and China offices of Mazars.  He currently is the leader of Mazars Asia transfer pricing practice. He had supervised an Unilateral Advanced Pricing Agreement (“APA”) in Australia.

Prior to joining Mazars, Anthony was the Deputy Tax Managing Partner of one of the Big 4’s Southern China tax practice. He has an extensive experience in IPO projects in the Asian Pacific region (including listing in Hong Kong and Singapore) as well as in transfer pricing in China (he was the advisor to two Bilateral Advance Pricing Agreements (“BAPA”)).

While he was a tax partner of the Canadian practice of the Big 4 firm, he taught part-time in taxation at University of Toronto. He is one of the three course directors of the Advanced Diploma in Taxation offered by the Hong Kong Institute of Certified Public Accountants, (“HKICPA”), which covers Hong Kong, China as well as international taxation. He is a facilitator in the China tax course offered by the Tax Academy of Singapore for the last ten years.


Mrs. Chung-Sim Siew Moon

Mrs. Chung-Sim Siew Moon is a Board Member of the Singapore Institute of Accredited Tax Professionals (SIATP). She is Accredited Tax Advisor (Income Tax & GST).

With over 30 years of experience and as Asia-Pacific Tax Policy and Controversy (TPC) Leader, and Partner in Ernst & Young Solutions LLP (EY), Siew Moon serves multinationals and local clients and works with various government authorities and regulators on tax matters.

As EY TPC Leader, Siew Moon works across all tax services, particularly with the EY specialist network of TPC professionals across the Asia-Pacific and globally. In working with the global tax controversy network, she helps clients to prevent, manage and resolve their tax controversies. She also works with the EY global tax policy network to help develop and implement policy initiatives – both as external and internal advisors to governments and companies.

Siew Moon is a frequent speaker at seminars and contributes articles to EY and external publications regularly. Besides possessing a Bachelor of Accountancy (First Class Honours) degree from the National University of Singapore, Siew Moon also holds professional designations as a Fellow Chartered Accountant of the Institute of Singapore Chartered Accountants, and a Fellow CPA of CPA Australia.


Mrs. Tungalagmaa Khuajin

Associate professor Tungalagmaa Khuajin (CPTA, CPA, and MCMC) is a founder of Mongoltax TMZ LLC, which is one of the first tax consulting and accounting outsourcing companies in Mongolia. Mongoltax TMZ LLC currently has 4 branches in Mongolia and provides tax and accounting consulting services.

Tungalagmaa has more than 40 years’ experience in tax education, accounting, consulting and tax advocacy. She is the core author of 13 tax research articles in international and domestic journals, 24 research works in the area of taxpayers’ social responsibilities and continuous tax education in Mongolia. During the last 10 years, she has provided tax education trainings for around 40,000 people from preschool to businesspersons.


  • Head of the Training and Research Management Committee, Mongolian Association of Certified Tax Consultants.
  • Head of the Bayangol branch at Mongolian Institute of Certified Public Accountants.
  • Founder and Member of the Mongolian Management Consulting Institute.
  • Member of One Asia: Asian CPA & CPTA Firm’s Network



Ms. Euney Marie J.Mata-Perez

Ms.Euney Marie J. Mata-Perez is the managing and founding partner of Mata-Perez, Tamayo & Francisco, a firm with strong corporate, tax and customs practice.  She is a certified public accountant and a member of the Philippine bar. She has been ranked by Chambers & Partners as one who “really knows tax law and is a magnificent lawyer.” Euney brings to the practice not only a rich 26-year experience in tax, transactions, corporate reorganizations and other corporate matters, but also a keen business insight as a certified public accountant, enabling her to identify and help resolve the issues that shape business needs. She has been invited to explain the complexities of tax laws and speak at local and international forums—such as conferences sponsored by the International Tax Review, Asia-Oceana Tax Consultants Association, Inc. (AOTCA), and TAXAND—as well as contributing to several foreign and local publications, including CCH Doing Business in Asia, the Ateneo Law Journal, and the TMAP Technical Journal.  She is an author at The Manila Times, one of the country’s leading national newspaper, in the weekly column entitled “More to Follow” at the Business Section of the newspaper. Euney was the President the Tax Management Association of the Philippines—the country’s leading association of tax practitioners and professionals—in 2013. She is the current Deputy President of AOTCA. She is an active member of Financial Executives Institute of the Philippines Inc. and the Management Association of the Philippines. Euney earned her degree of Juris Doctor and graduated salutatorian of her class at the Ateneo de Manila University School of Law, where she was the Associate Editor of the Ateneo Law Journal. She graduated summa cum laude in her undergraduate course of Bachelor of Science in Commerce, major in accounting, from the University of San Carlos, Cebu City.