Launch Webinar | How to Implement Effective Transfer Pricing Documentation Requirements: A Practical Toolkit to Support Developing Countries

Ms. Melinda Brown is a senior advisor at the OECD’s Centre for Tax Policy and Administration (CTPA) with almost 20 years’ experience in all aspects of transfer pricing practice, policy and law design.  She was heavily involved in the development of transfer pricing guidance under the BEPS Action Plan; and as a member of the UN subcommittee, is also responsible for drafting key parts of the UN Practical Manual on Transfer Pricing. 

As the head of a team assisting developing countries to effectively participate in the OECD’s Inclusive Framework, Melinda’s current focus includes supporting lower capacity countries in the work aimed at finding consensus solutions to the digitalisation of the economy. She also has a leadership role in the development of Toolkits on international tax for low-income countries by the Platform for Collaboration on Tax, a joint initiative of the OECD, IMF, World Bank Group and UN. 

Before joining the OECD, Melinda was a competent authority for Australia and a senior transfer pricing specialist at the Australian Taxation Office and the Australian Treasury.

Mr. Colin Clavey is a senior international tax consultant at the World Bank Group. He has over 25 years’ experience of working in the international taxation area: in the UK’s tax administration, EY and OECD.  Since retiring from OECD in 2015, Colin has worked as a consultant to the World Bank and on TIWB and similar country projects. He has extensive experience of practical auditing as well as on policy issues.

Ms. Wanda Montero Cuello is a Tax Policy Advisor at the Transfer Pricing Unit of the OECD’s Center for Tax Policy and Administration. She is responsible for the development of Toolkits related to transfer pricing matters. Within the OECD Ms. Montero also worked at the Global Forum for Transparency and Exchange of Tax Information. Before joining the OECD, she was the Head of the Transfer Pricing Department at the General Directorate of Internal Taxes in the Dominican Republic. Ms. Montero has also been a consultant for the Inter-American Center of Tax Administrations (CIAT) on various projects related to international taxation.

Ms. Montero is an Economist from the Pontificia Universidad Católica Madre in Santo Domingo and holds a master’s degree in Economic Policy from the University of Illinois at Urbana-Champaign and a master’s degree in Economic Development from the Catholic University of Santo Domingo.

Mr. Michael C. Durst is a Senior Fellow at the International Centre for Tax and Development (ICTD) and has been a long-time US tax practitioner, an author on international taxation and developing countries, a government official and a law professor.

He has practiced extensively in the field of international taxation, both in the private sector and in the US government, as Director of the IRS Advance Pricing Agreement Program. Michael has published many articles, in both academic and professional journals, on issues of international taxation, particularly as they affect developing countries.  His book, Taxing Multinational Business in Lower-Income Countries: Economics, Politics and Social Responsibility, was published in February 2019 under the auspices of ICTD and is available to access free online.

Mr. Alex Evans is a Senior International Auditor with the Canada Revenue Agency.  Alex has specialized in transfer pricing for the past 10 years including reviewing transfer pricing documentation prepared by taxpayers in his current role, as well as preparing transfer pricing documentation for taxpayers before joining the CRA.

Mr. Moses K. Yidana is the Head of Transfer Pricing at the Ghana Revenue Authority. Prior to joining GRA, he worked with Deloitte in Ghana leading its transfer pricing team and business tax.  

Mr. Yidana is a Chartered Accountant (Member ICA Ghana), Chartered Tax Practitioner (Member CIT Ghana) and holds MBA in Finance and Bachelor of Laws (LLB).

Mr. Kamlesh C. Varshney is the Joint Secretary (Tax Policy and Legislation) at the Ministry of Finance of India. He is 1990 batch Indian Revenue Service (IRS) Officer. He has an MBA from Indian Institute of Management Lucknow and has also obtained his degree in Law. As an IRS officer he has worked in various capacity in tax administration. He was involved in successful rolling out APA program in India and was its first Commissioner. He has also worked as Commissioner of Income Tax in Delhi in the area of international taxation and transfer pricing. He has worked in Indian Finance Ministry for more than 10 years in the areas of tax policy and foreign tax. Previously, he was advisor to task force which drafted the new income tax law and submitted the report to the Finance Minister. He also worked for five years with tax administration of Papua New Guinea upgrading their tax skills in domestic resource mobilization. He is also a visiting professor at many prestigious Indian institutes and academies.

Mr. Fernando Becerra O’Phelan is the International Taxation and Transfer Pricing Manager at The National Superintendency of Tax Administration (SUNAT), Peru.

With almost 20 years advising in transfer pricing issues to both the private and the public sector, Mr. Becerra joined SUNAT in 2013 after twelve years practitioner as a Senior Manager at PwC and Senior Consultant at Deloitte.

Since 2015, he is the Peruvian delegate at the OECD´s Working Party N^o6 – Taxation of Multinational Entities.

In his career, Mr. Becerra has participated as lecturer and been trained in specialized forums in the US, France, Argentina, Colombia, Chile, among others. He holds a bachelor’s degree in economics from the Ricardo Palma University (Peru) and an MBA from EUCIM Business School (Spain), and completed postgraduate studies on Corporate Finance, Assets Valuation and International Taxation at ESAN and Pacifico Business School (Peru).

Since 2013, Ms. Rocío Bermúdez is the Head of Transfer Pricing at Repsol, responsible for monitoring the transfer pricing policy across the Group, technical support in tax audits, international tax policy, tax closing and participation in international fora (ICC, BIAC, UN…)

Ms. Bermúdez has been a Non-Governmental Member of the EU Joint Transfer Pricing Forum representing Repsol (Mandate 2015-2019) and she is currently Vice-chair of the Taxation Commission of the International Chamber of Commerce.

Prior to joining Repsol, Ms. Bermúdez worked for Deloitte, both in Madrid and Deloitte Rotterdam offices for more than 7 years, in the Transfer Pricing and International Tax department, dealing with Transfer Pricing assessment, APAs negotiations and different tax planning projects. She has a degree in Business Administration and Law and a Master’s in Corporate Taxation.

Mr. David Ernick is a Principal in the Transfer Pricing Practice of PricewaterhouseCoopers’ (PwC) Washington National Tax Services office.  David has extensive experience in the preparation and negotiation of advance pricing agreements (APAs) and ruling requests, and in the management of competent authority matters and transfer pricing disputes.  His practice also includes transfer pricing planning and documentation, cost sharing, IP transfers, and tax valuation services.

Prior to joining PwC in 2013, David was Associate International Tax Counsel at the U.S. Treasury Department.  While at Treasury from 2004-2013, his responsibilities included negotiating tax treaties and trade agreements, drafting regulatory guidance, and advising on legislative matters.  David was the principal staff attorney for transfer pricing matters at Treasury and advised on every significant guidance project in this area released by Treasury and the OECD during his tenure.  He was a member of the drafting team and intimately involved with the development of the temporary and final regulations under Section 482 for intercompany services and cost sharing arrangements.  He also represented the United States as a delegate to the Organization for Economic Cooperation and Development (OECD) Working Party No. 6 on Transfer Pricing.   

David has also clerked at the U.S. Tax Court and the U.S. Court of Appeals for the Eleventh Circuit.  He currently serves as an adjunct professor and teaches a course on transfer pricing in the Graduate Tax Program at Georgetown University Law Center.  He is also a co-author of the Practising Law Institute's (PLI) Transfer Pricing Answer Book and a member of both the Bloomberg BNA Transfer Pricing Advisory Board and the Tax Management International Journal’s Panel of Leading International Tax Practitioners.