International tax dispute resolution: deciding on a strategy and a choice of forum

Sandy Bhogal is a partner in the London office of Gibson, Dunn & Crutcher and a Co-Chair of the firm’s Tax Practice Group. Mr. Bhogal experience ranges from general corporate tax advice to transactional advice on matters involving M&A, corporate finance & capital markets, investment funds, structured and asset finance, insurance and real estate. He also has significant experience with corporate tax planning and transfer pricing, as well as with advising on the development of domestic and cross border tax efficient structures. He also assists clients with tax authority enquiries, wider tax risk management and multi-lateral tax controversies. Mr. Bhogal is listed as a leading tax adviser in Chambers and Legal 500. He is also listed in the World Tax Leaders Guides for Tax Controversy and ranked in the Who’s Who Legal editions of Thought Leaders in Corporate Tax.

Wiebe specialises in international and Dutch tax law, focusing on corporate transactions, investment funds and tax controversy. Since joining De Brauw, Wiebe has advised numerous multinationals and funds on complex cross-border M&A transactions, investment structures and tax disputes. Wiebe is actively involved in the tax expert group of the Dutch association of asset managers (DUFAS), the committee on legislative proposals of the Dutch association of tax advisors (NOB) and frequently lectures on international tax law, including at IBA conferences and at the universities of Amsterdam and Groningen. He is recognised by Chambers and Legal 500 with Chambers describing him as “very accessible, sharp, responsive and to the point” and Legal 500 referring to him as a “top-notch tax professional”. Wiebe’s recent work includes advising: a multinational on a high-profile state aid investigation into its Dutch tax rulings NXP on the aborted USD 47 billion acquisition by Qualcomm and two multi-billion dollar divestments Pfizer on the USD 48 billion combination of its Upjohn business with Mylan GrandVision on the EUR 7 billion takeover by EssilorLuxottica Elastic NV on its NYSE listing valued at USD 2.2 billion ABN AMRO on the spin-out of its private equity business APG on the EUR 450 million sale of Loyalis to ASR Port of Rotterdam on the impact of the introduction of its corporate income tax liability further to the European Commission’s state aid ruling a major Dutch banking and insurance group on setting up and restructuring its investment fund range

Head of Tax and Customs (Americas) at Nissan North America