Ask-An-Expert Series #2: Toolkit on the Taxation of Offshore Indirect Transfer of Assets

WEBINAR PROGRAM & SPEAKER BIOS

Biographies:

Panelists:

Mr. Daniel Atwere Nuer is currently Head of the Tax Policy Unit (TPU) at the Ministry of Finance – Ghana. He is a career public servant with a little over 32 years of experience in tax administration and tax policy. Over the period he has worked with several different teams in providing policy inputs for national budgets and monitoring the implementation of those policies; preparation of supporting legislation for tax policies and participated in the review of Ghana’s tax laws as part of the integration and modernisation of the Revenue Agencies. He has also worked as a tax expert on several IT projects in both Ghana and internationally. He holds an M.Phil. in Taxation, is a Fellow of the Chartered Institute of Taxation (Ghana) and a Tax Administration Diagnostic Assessment Tool (TADAT) Trained Assessor.

Mr. Daniel Prates is the Head of International Tax at the Federal Revenue of Brazil.

Mr. Martin L. Tsalwa is the Manager International Tax Office, Extractives Sector (Large Taxpayers Office (LTO). Prior to this, Martin was the Manager Extractives sector Compliance (Large Taxpayers Office) which handles compliance management in the Extractives sector. He has worked with the Medium Taxpayers Office as a Relationship manager Services. He has worked in different tax offices within the authority in his 20 years working experience. Martin was in charge of the capacity building of the new office for the Extractives in LTO. He was the project manager to work in collaboration with a consultant to develop the office procedures manual and training curriculum. He has undertaken various short and long training courses in the oil and gas sector that have been run by the IMF, PETRAD, IBFD, Sydney University. Martin is a certified QMS lead auditor. He holds a degree from Egerton University and a Fellowship from the Sydney University.

Ms. Patricia Sepúlveda Garcés is a Mining Sector Tax Auditor at the Internal Revenue Service of Chile. She has more than 17 years of experience in the Internal Revenue Service in the oversight of multinational mining, metallic, and non-metallic companies. She has more than 11 years of experience as a lecturer in tax matters at numerous universities in Chile. At present, she teaches a postgraduate Mining Taxation course at the Universidad de Santiago de Chile and undergraduate courses at the Universidad Católica Raúl Silva Henríquez. She has participated as a speaker in numerous seminars and international events of tax administrations, particularly in international mining taxation, and has written articles on tax issues.

Mr. Thomas Lassourd is a Senior Policy Advisor, Tax and Extractives with the IGF Secretariat, working on its project to address tax base erosion and profit shifting (BEPS) in mining. His areas of specialization include public finance and fiscal reforms with a strong focus on tax policy in extractive industries. Thomas has more than 12 years of experience analyzing, designing, and implementing economic reforms in developing countries. His past experience includes acting as a senior economic analyst at the Natural Resource Governance Institute in New York, where he delivered high-level technical assistance, capacity building, and applied research in fiscal policy for resource-rich developing countries. Thomas speaks French, English, Portuguese, and Spanish and is based in New York, USA.

PCT Experts:

Mr. Cory Hillier (IMF) is a tax lawyer and is currently appointed as Senior Counsel in the Legal Department of the IMF. Cory is involved in providing legal advice in relation to taxation in the context of the IMF’s capacity development, surveillance, and financial assistance programs. He has experience providing legal advice on, and drafting legal instruments in, all major areas of tax law, including corporate and personal income tax, general consumption taxes, taxation of the financial sector and capital markets, tax administration and procedures, and international taxation. He is also extensively involved in the IMF’s legal and international tax policy work, including at the G7 and G20 level. Prior to joining the IMF, Cory worked in private practice and was consistently listed as a leading tax practitioner in the Chambers: Asia Pacific Client Guide (2012-2015).

Ms. Emily Muyaa (moderator - UNDESA) is the Chief of the Capacity Development Unit for the Financing for Sustainable Development Office of the United Nations since 2022. In her role, she is responsible for planning strategies and determining the capacity or capability development within tax administrations or with private practitioners for developing countries. Among other duties, Emily provides tax consultations and training to tax officials in countries in need of expertise. She formerly worked for the International Bureau of Fiscal Documentation between 2014 and 2022, where she rose from an associate to a senior associate, managing principal and project manager for CSAT. She also served as a freelance tax researcher in New York from 2013 to 2014, as a working student in Amsterdam for EY in 2013, and a revenue officer in Nairobi for the Kenya Revenue Authority for its transfer-pricing unit. She has also served as a visiting lecturer at the University of Cape Town in South Africa since 2017 and worked in the same capacity at the University of Amsterdam. Supporting various civic interests, Emily spent four years as a member of the Transfer Pricing Subcommittee for the United Nations between 2018 and 2022. She has continued to serve as a founding member of the Transfer Pricing Economists for Development (TPED), a nonprofit organization that is based in Paris, since 2018. Emily earned a bachelor's degree in law at the University of Nairobi School of Law in Kenya in 2006. She subsequently received a postgraduate diploma in law at the Kenya School of Law in 2007, followed by a Master of Laws in advanced studies in international tax law at Leiden University in the Netherlands in 2013. Additionally, she received an advanced diploma in accounting and business through the Association of Chartered Certified Accountants. Emily was also recognized as one of the Leading Women in Tax by the Kenya Revenue Authority in 2021 and 2022.

Mr. Norbert Roller (WB) teaches international tax law at FH Campus Wien University and regularly works for the World Bank Group as a Consultant for International Tax Law and Tax Policy. Before, Norbert worked for more than ten years for the Austrian Federal Ministry of Finance, where he held various positions including Austrian delegate to the OECD.

Mr. Tomas Balco (OECD) serves as Senior Adviser in BEPS Capacity Building Team of Global Relations and Development Division at OECD Center for Tax Policy and Administration. In this role he is assisting both the OECD member and non-member countries in the process of implementing various BEPS recommendations into their legal and administrative framework. He is also leading the joint project on Transfer Pricing between OECD and Brazil’s Receita Federal (RFB). Prior to his current role he was serving as Head of Transfer Pricing Unit in the Tax Treaty, Transfer Pricing and Financial Transactions division at OECD, where he was overseeing the finalization of the BEPS follow up work on transfer pricing. He has more than 20 years of combined practical experience both in private and public sectors as well as in academia. His experience in international tax policy includes the work done for the Ministries of Finance and Tax Authorities of Slovakia, Czech Republic, Chile as well as European Council and EU Commission and also working as consultant for other international organizations such as International Financial Corporation, World Bank Group, United Nations and development agencies such as USAID, JICA and others. Tomas has previously represented Slovakia on several working groups of OECD during the BEPS project and was also involved in the process of implementation of BEPS measures both at the EU level – negotiation of the ATAD Directives and also their implementation in the national tax law. Next to transfer pricing, his expertise includes the EU Tax Law, Tax Treaties and special tax regimes – e.g. financial sector taxation, extractive industry taxation and others. He has both legal (graduate of LL.M. in International Tax at WU, Vienna and PHD from Masaryk University, Brno) and accounting training (Chartered Certified Accountant- member of ACCA, UK professional body).