Presentations

Who are the Winners in Tax Litigation: Tax Authority, Taxpayer, or Tax Lawyer? A Brief Review of the Current Trends Around the Globe

Who are the winners in tax litigation – tax authority, taxpayer, or tax lawyer? A brief review of the current trends around the globe.

Presenters

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Andre Carvalho

Partner, Veirano Advogados

Rio De Janeiro

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Jay Shim

Partner, Yoon & Yang

Seoul

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Rogério Fernandes Ferreira

Sócio | Managing Partner, RFF Lawyers

Lisbon

Rogério Fernandes Ferreira is the founder and the managing partner of RFF Lawyers – the first and largest Portuguese full-service tax & business law firm. He is a professor of tax litigation at the University of Lisbon (IDEFF) and of international taxation at the Catholic University of Portugal (PAFISC), the president of the Portuguese branch of the International Fiscal Association (IFA) and of the Instituto Latinoamericano de Derecho Tributario (ILADT), and the chair of IFA Congress 2025 in Lisbon. Rogério is also a former Secretary of State for Fiscal Affairs of the Portuguese Government and has been invited – by Minister of Finance – to chair the Portuguese tax reform on litigation matters in 2025.

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Riccardo Cajola

Managing Partner, Cajola & Associati

Milan

Riccardo G. Cajola is managing partner at Cajola & Associati, a law firm based in Milan. Riccardo served as Chief Technology Officer of the IPBA until 2024 and he is currently President of the Tax Commission at the Union International des Avocats. His practice is focused on transactional, tax and commercial work, in the area of distributorships, as well as M&A, private equity investments, corporate restructurings, and a variety of other general corporate transactions.
He currently serves as member of the supervisory boards and of the statutory auditor boards of several domestic corporations, mostly belonging to multinational groups.
Riccardo Cajola is editor and co-author of several legal publications and he is a frequent speaker at national and international conferences.
He graduated at Università degli Studi di Milano and as LL.M. in International legal Studies in Washington D.C. at American University, Washington College of Law.

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Fabienne Limacher

Partner, Walder Wyss AG

Zürich

Fabienne Limacher is a partner in the Tax Team. She advises companies and private clients in national and international tax matters. Fabienne Limacher has extensive experience in corporate taxation, in particular in the area of national and international reorganisations, real estate transactions, cross-border relocations as well as M&A and private equity transactions. She is also an expert in tax issues relating to financial and insurance products, structured financing as well as CRS and FATCA. A further focus of her practice is advising managers, companies and start-ups on tax and social security issues regarding employee incentive plans and cross-border employee transfers.

Born in 1986, Fabienne Limacher was educated at the University of Bern (MLaw 2010) and the University of Sydney (LL.M. 2018), was admitted to the Bar in 2012 and graduated as certified tax expert in 2016. She worked as a research assistant for the Institute of Tax Law at the University of Bern and as a trainee with Walder Wyss. In addition, she gained working experience as a trainee at the cantonal court and the public prosecutor’s office of Canton Nidwalden. Fabienne Limacher regularly publishes and lectures on relevant tax topics.

Fabienne Limacher’s professional languages are German and English. She also speaks French. She is registered with the Zurich Bar Registry and admitted to practise in all of Switzerland.

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Monchai Varatthan

Partner, TMI Associates (Thailand) Co.,Ltd.

Bangkok

Reena Khair

Reena Khair

Senior Partner, Kochhar & Co.

New Delhi

Reena is a Senior Partner and heads the International Trade & Indirect Taxation Practice at the Firm.
She is a lawyer of eminence with more than 25 years of work experience and specialisation in the areas of international tradeand indirect taxation. She represents clients regularly before the Customs, Excise, and Service Tax Appellate Tribunal, as wellas before various High Courts and the Supreme Court of India. She has extensive court room experience with more than 300reported cases argued by her.
In the domain of international trade, Reena has represented clients comprising domestic and foreign industries, as well as userindustries in India before the Designated Authority, Directorate General of Trade Remedies, and higher forums. She has alsosuccessfully argued the highest number of anti-dumping and anti-subsidy cases before the Tribunal. She has also assistedclients in trade remedial investigations in foreign jurisdictions.
She has been regularly providing advisory services and has been involved in dispute resolution for high-profile matters relatingto customs, excise, service tax, FEMA, and GST. Critical issues handled by her include classification under the HarmonizedSystem Nomenclature, valuation, export promotion schemes, drawback, EOUs, SEZs, inverted duty structure, admissibility ofcredits, transitional issues in GST, export refunds. She regularly assists clients in the transition to the GST regime.
She has also conducted Internal Management audits for optimization of tax liability, identifying issues/risks for potentialdisputes with departmental authorities and restructuring of transactions undertaken for various clients including some ofIndia’s major conglomerates and multinational corporations in the oil & gas, specialty materials and chemicals, steel andmanufacturing sector.

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Theophilus Emuwa

Partner, Aelex

Lagos