Recent Structures and Trends to Pass Anti-Avoidance Tests
Anti-avoidance mechanisms remain a cornerstone of direct tax policy across jurisdictions. Our session will explore recent structures and emerging trends adopted by taxpayers to navigate these rules, including the use of tax or residency certificates, substance-based arrangements, and certain PE-related structures. We will discuss how these elements are assessed under anti-avoidance frameworks in different jurisdictions.
Presenters
Primary Speakers

Gibran Naushad
Gibran Naushad is the founder and counsel at GN Law, a law firm based in New Delhi with focus on dispute resolution and taxation laws. Gibran is also an ‘Advocate-on-Record’ in the Supreme Court of India, i.e., part of the select group of advocates who can file and initiate proceedings before the Supreme Court of India. Gibran’s focus areas include general commercial litigation and arbitration, tax disputes and advisory along with international and domestic structuring.
Gibran is presently a Senior Standing Counsel (nodal counsel) for taxation for the Government of India in the Delhi High Court. He is also a Senior Panel Counsel for the Government of India in the Supreme Court of India.
Gibran completed B.A. LL.B.(Hons.) [JD Equivalent] from National Law University, Delhi. He is a member of the Bar Council of Delhi and the Delhi High Court Bar Association. Prior to setting up his independent law firm, Gibran worked at S&R Associates, a full-service law firm in New Delhi and thereafter at the Guild – Advocates and Associate Counsel, a boutique litigation setup based in New Delhi.
Gibran has been awarded the IPBA Scholarship in 2020 and the AIJA Scholarship in 2023. He was also awarded Business World’s 30 under 30 Lawyers and Legal Influencers Award (India) for 2021-2022.

Siong Sie Khong
Kuala Lumpur
Siong Sie is a chartered accountant and Malaysian tax lawyer specialising in tax disputes, cross-border tax, international trade, and competition law. He advises local and multinational clients on complex engagements with tax authorities and regulators.
He is recognised for Tax in Malaysia by Chambers Asia-Pacific 2026 and Legal 500 Asia Pacific 2026, and serves as legal counsel to the Malaysia Competition Commission on competition matters. Prior to establishing his current practice, he was Partner and Head of the Tax Practice Group at Skrine.
Earlier in his career, he worked in tax practice, audit, and in-house roles, including at PwC Kuala Lumpur and Tesco Malaysia, giving him a broad commercial and regulatory perspective.
Other Speakers

Tom Kwon
Seoul
Tom is the Head of Lee & Ko’s International Tax Practice. He advises Korean and foreign companies, investment funds and other investors on Korean and cross-border tax matters. He practices primarily in international tax and M&A tax. Tom’s practice also involves advising foreign clients on tax controversies, claims for tax refund as well as other tax disputes.
Tom is recognized as, among others, a “Ranked Lawyer” in 2026 Chambers Asia-Pacific, “Litigation Star” by 2026 Benchmark Litigation Asia-Pacific, as well as “Highly Regarded” in General Corporate Tax in 2026 International Tax Review (ITR)/World Tax rankings.
Prior to joining Lee & Ko in 2016, Tom was a Director in Deloitte’s M&A and International Tax Group.

Brígida Galbete
Barcelona
Brígida joined Cuatrecasas in 2005. She specializes in advising multinational and consolidated business groups on tax matters, particularly in connection with corporate transactions. Her expertise covers a wide range of tax matters, including those related to M&A transactions, tax planning, contract negotiations, and corporate restructurings.
She has been a member of the Cuatrecasas Asian Desk since her assignment to the Shanghai office, where she worked until 2015.

Tin-Lok Shea
Sydney
Tin-Lok is an Australian lawyer practising in commercial, corporate, and taxation law. He has advised on numerous M&A transactions and complex commercial matters, with a particular focus on inbound investment from Asia into Australia. His experience includes acting for Australian subsidiaries of prominent Japanese listed companies, leveraging his Japanese bilingual capability.
Prior to joining H & H Lawyers, Tin-Lok was an Account Director at Deloitte Australia, where he advised on the implications of complex, high-profile transactions involving multinational corporations and government entities.

Sneh Shah
Mumbai
Sneh is a Partner in the Direct Tax Practice at Khaitan & Co, based in the firm’s Mumbai office.
She regularly advises leading multinational corporations and investment funds on complex domestic and cross-border M&A transactions, including both sponsor-led deals and strategic investments/divestments. Her experience spans a variety of deal structures, such as share and business acquisitions, flip structures, as well as global transactions involving an Indian leg.
Sneh also has deep expertise in tax advisory matters, including structuring of inbound and outbound investments, cross-border secondments, joint venture arrangements, franchising models, review of global ESOP policies, EPC contracts, and evaluating residency and taxable presence risks for foreign entities.
She frequently advises on the structuring of domestic and international investment vehicles, including Indian collective investment schemes, REITs, InvITs, and offshore debt instruments.