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Corneli Espost, Associate Director in the PwC Cape Town Corporate and International Tax Practice

Corneli Espost is a corporate and international tax specialist with over 14 years of experience. She advises large South African and foreign multinational groups in respect of their South African income tax, international tax, exchange control and transfer pricing issues.

Whilst she continues to provide corporate and international tax advice to corporate clients, her main focus is on transfer pricing. She uses her project management skills to assist with the implementation of advice given, where required.

As a transfer pricing specialist, Corneli regularly presents at various PwC seminars and contributes to many PwC and international publications.

Michael Hewson, Director at Graphene Economics

Michael Hewson has over 12 years of experience in transfer pricing in Africa. He founded Graphene Economics™ in 2017 with a vision of creating a specialist economics-focused African transfer pricing firm.

Michael was previously a partner at EY where, under his leadership, the EY South African transfer pricing team grew to the largest professional services transfer pricing team in Africa. The team was awarded the 2016 International Tax Review Award for South African Transfer Pricing Firm of the Year.

He has contributed to two books on transfer pricing and is a guest lecturer at the University of Johannesburg and the University of Pretoria. He initiated the development of a trainee programme for university graduates to specialise in transfer pricing, which is run through SAIT.

Michael is the vice chair of the Transfer Pricing Subcommittee of the South African Institute of Tax Professionals (SAIT).

Nishana Gosai, Tax Director at Baker McKenzie

MCom, HDip Tax, BCom

Nishana Gosai is part of Baker McKenzie's tax practice group in Johannesburg. She has over 15 years of experience in transfer pricing.

Her main areas of specialisation include tax planning, restructurings, policy and documentation design, audits, dispute resolution, risk mitigation and legislative interpretation matters.

Nishana is a member of the United Nations Subcommittee on Transfer Pricing, which is responsible for preparing and updating the United Nations Practical Manual on Transfer Pricing for Developing Countries. She is also a member of the South African Institute at Chartered Accountants.

Karen Miller, Consultant in the Tax Practice at Webber Wentzel

Karen Miller has a wealth of corporate tax experience, which spans over 20 years in both public and private sectors in South Africa, Australia and the United Kingdom.

Prior to joining Webber Wentzel, she was employed as the transfer pricing practice leader for SARS until 2010, director of EY in the role as transfer pricing leader for the Sub-Saharan Africa region until 2014 and as transfer pricing leader for the Western Cape with Deloitte.

Karen has been involved in a number of key speaking events on transfer pricing and was the South African delegate to Working Party 6 at the Organisation for Economic Co-operation and Development between 2007 and 2010. She has also published a number of articles on transfer pricing.

She is a member of the SAIT International Tax Committee and the SAICA Transfer Pricing Subcommittee.

Prof. Deborah Tickle, Technical Advisor (International and Corporate Tax and Transfer Pricing) at KPMG

Deborah Tickle acts as a technical advisor to KPMG, consulting in both international and corporate tax and transfer pricing.

Previously, she was appointed as a partner at the firm, and later as managing partner of the Cape Town Tax Department. After 31 years with the firm, she retired as partner in order to free up some time to pursue other interests, which include lecturing for the Masters in Corporate Tax and Masters in International Tax classes at the University of Cape Town.

Deborah is a full member of the Davis Tax Committee and has served on the southern region and national tax committees of the South Africa Institute of Chartered Accountants.

In addition to the many articles she has written for media and journals over the years, she was published in the 2014 edition of the International Fiscal Association’s Cahiers.

Jan-Paul Borman, Director/Partner at PwC

Jan-Paul "JP" Borman leads PwC South Africa’s Transfer Pricing Team. JP has been with PwC since 2006 and has specialised in transfer pricing for over nine years. Although based mostly in Johannesburg, JP also completed a secondment to London where he managed some of the most complex transfer pricing assignments. JP’s industry experience covers various industries, given the nature of the South African and African economies.

He has also been involved in:

  • Various operating model/value chain transformation assignments
  • TP implementation/technology/ERP-driven work
  • Transfer pricing audits and disputes (negotiation, mediation and litigation) in various territories, including South Africa, the US and Australia
  • Leading numerous Pan-African tax and transfer pricing assignments

JP is an admitted attorney and conveyancer in South Africa.

He earned a BCom (Law), BCom (Informatics), LLB and an HDip (International Tax) from the University of Johannesburg; as well as an LLM (Tax) from the University of the Witwatersrand.

Caoilfhionn van der Walt, Partner at Regan van Rooy

Caoilfhionn van der Walt is one of the founding partners of Regan van Rooy, a niche tax and specialist corporate services firm, where she provides senior international tax support on an ad hoc in-sourced basis. She also runs specialist coaching and technical skills upliftment programmes.

Caoilfhionn started her career at Arthur Andersen in London and thereafter moved to Deloitte. She relocated to South Africa in 2007 and was the head of international tax for the Sasol group until 2016.

Willemien Viljoen Researcher at Tralac

Willemien Viljoen holds a Master’s degree in Economics and a Bachelor of Laws degree from the Stellenbosch University. Her research interests are in regional integration and international trade policy, and specifically in issues pertaining to non-tariff barriers to trade, trade data analysis and modelling, and trade and climate change.

Nina Keyser, Partner at Webber Wentzel’s Tax Practice

Nina Keyser is the head of the Tax Dispute Resolution and Tax Controversy Management team.She has more than ten years' experience in representing taxpayers on a broad spectrum of tax disputes with SARS.

Nina provides clients with advice in the course of large transactions and prior to the submission of the relevant returns. Where taxpayers have not complied with the relevant tax laws, she assists them to regularise their affairs with SARS. She also provides advice and assistance to clients who are being audited or investigated by SARS.

Prior to joining Webber Wentzel in 2004, she spent eight years working as a legal advisor at SARS resolving disputes between SARS and taxpayers, and providing legal and tax advice to SARS audit teams. Other duties included training, advising on criminal investigations and personal liability, conducting civil litigation between SARS and taxpayers and prosecuting tax evaders.

Marcus Stelloh, Associate Director in Grant Thornton’s Transfer pricing division in Johannesburg

Marcus Stelloh has ten years’ experience in transfer pricing, cross-border structuring and international tax.

His extensive knowledge of transfer pricing includes, but is not limited to the following:

  • Transfer pricing planning: Analysing and resolving international and local transfer pricing issues faced by multinational enterprises within South Africa, Australia and Africa.
  • Transfer pricing compliance: Putting in place appropriate documentation to support client transfer pricing policy documents within South Africa, Australia and Africa.
  • Transfer pricing defence strategies and litigation support: Drafting comparability and detailed financial analyses which involves building financial models that allow for various scenario analyses.
  • Transfer pricing negotiations with SARS

    Marcus’s experience in specific sectors includes: oil and gas (upstream, downstream and seismic operations), mining (coal, base metals, PGMs and gold), financial services (asset management and reinsurance), information technology, manufacturing, distribution, telecommunications, services, shared services and cooperatives.


Craig Bain, Manager at Grant Thornton

Craig Bain has eight years’ experience in tax consulting including VAT, corporate tax, international tax, cross-border structuring and transfer pricing. He has spent four years focusing on transfer pricing in South Africa and the USA.

Craig’s extensive knowledge of transfer pricing includes the following:

  • Transfer pricing planning: Operating model efficiencies, IP modelling, and advising on transfer pricing issues faced by multinational enterprises within the USA, South Africa and Africa.
  • Transfer pricing compliance: Preparation of transfer pricing documentation including policies, master files and local files.
  • Transfer pricing defence strategies and litigation support: Advance pricing agreements, mutual agreement procedures and transfer pricing negotiations with the IRS and SARS.
While living in South Africa and the USA, Craig gained specific sector experience including:
automotive, technology including robotics, information technology, financial services, telecommunications, retail, oil and gas, mining and agriculture.


Victor Adegite, Senior Manager: Tax and Transfer Pricing at KPMG Nigeria

Victor Adegite has more than 11 years’ experience in advising multinational companies on various tax matters such as transfer pricing, tax and regulatory compliance, corporate mergers and acquisitions, and tax dispute resolution. His experience spans across several industries including consumer and industrial markets, manufacturing, energy and natural resources, financial services and IT/ business outsourcing.

Victor is a regular presenter at conferences, training programmes and seminars organised by the Federal Inland Revenue Service and various regulating bodies. He has also published articles in several international journals on tax, transfer pricing and BEPS.

As an active participant in the deliberations relating to the BEPS project, he has facilitated several sessions within KPMG and externally.He is an associate of two professional organisations – the Institute of Chartered Accountants of Nigeria and the Chartered Institute of Taxation of Nigeria.

Tayo Ogungbenro, Partner & Head of the Consumer/Industrial Markets Group in the Tax, Regulatory & People Services division of KPMG Nigeria

Tayo Ogungbenro has garnered over 21 years of experience in providing tax planning, management and regulatory advisory services to clients in diverse sectors of the economy. His in-depth tax management experience includes tax audit and assessment, tax due diligence, the resolution of tax issues, financial and accounting review, tax structuring, the review of business regulatory issues and PAYE tax reviews.

As the head of the transfer pricing group, he has led various transfer pricing engagements and is responsible for the development of policy documents, the review of inter-company transactions, and advising multinational clients on Nigerian taxes and how to manage any potential impacts on Nigerian operations.

Tayo has served as lead engagement partner on various tax advisory projects including tax compliance services, corporate tax planning, IFRS tax implementation, compliance work for local and multinational companies, personal income tax planning, and mergers and acquisitions tax advisory services.

Owen Murphy, Africa Desk Leader at BDO

As the head of BDO’s Africa Desk, Owen Murphy drives the BDO Africa Network objective of providing corporate finance and tax solutions to companies expanding into Africa.

Owen joined BDO in 2016 and has extensive functional experience in international tax, corporate tax, mining tax and transfer pricing which was gained over 15 years while he was the vice president of taxation at AngloGold Ashanti. He also has experience with controversy management and negotiating with governments on stability agreements in many African jurisdictions. Owen’sexperience spans various sectors, including resources, electronics, telecommunications and financial services.Previously, Owen was the group tax manager and group treasurer at the Altron Group and divisional tax adviser at Anglo American.

David Lermer, Partner/Director at PwC & PwC Africa Leader: International Tax and Transfer Pricing Services

David Lermer has over 30 years of professional experience in advising multinational groups in respect of their cross-border investment structures and modus operandi in Africa.

He has worked on numerous re-organisations of multinational groups and mergers and acquisitions, and is heavily involved in representations to Government on tax and exchange control policy and legislative changes.

David is a founder member of the PwC Africa Legislative Change and Development Group, a group dedicated to facilitating legislative change that supports business and economic growth in the country and region.

More recently, he has been one of the main lobbyists of the SA “Gateway into Africa” initiative, including the specific protection from tax for foreign investors in foreign or local investment funds, mainly in the private equity and venture capital space.

Craig Mitchell, Partner, Operating Model Effectiveness across EMEIA at EY Africa

Craig Mitchell leads EY’s Operating Model Effectiveness Team and has extensive experience in designing and implementing new global business models and operating models for large European and multinational groups headquartered in the United States.

Craig is the former CFO of SABMiller’s global procurement organisation, an organisation that he was instrumental in designing, implementing and operating.

His in-house and consulting experience covers the end-to- end supply chain in numerous sectors, most notably consumer products and industrial products.

Christiana Neal, Senior Manager: Assets & Procurement at Boland College

Christiana Neal received her HDip Business from the University of the Orange Free State in 1981. Her work experience includes the following:

  • Business Studies teacher at Central High in Beaufort West and Maitland High in Cape Town
  • Senior Lecturer at the College of Cape Town
  • Vice Principal at Durbanville College
  • Consultant for Coltech Computer Training
  • Manager Procurement at Boland College


Celia Becker, Executive at ENSafrica

Celia Becker is an expert in Africa regulatory and business intelligence, advising multinationals on investing and doing business in Sub-Saharan Africa. Her African expertise covers tax and regulatory requirements, the tax efficient structuring of investments / projects and executing contracts in various jurisdictions.

She has travelled extensively in Africa and has vast experience in liaising with local authorities and advisors. Celia started her career as an international tax advisor at a Big Four accounting firm and spent six years at a multinational construction company as country risk director.

She is a member of the South African Institute of Chartered Accountants and is the author of the Viewpoint Africa column in Business Day’s Business Law & Tax Review, and is a regular contributor of African jurisdictional content to Bloomberg BNA’s Tax Planning International and other publications.



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