Tax Law Dispute Resolutions in Tax Matters

Friday, April 26
Location (Room)
Le météore

Dispute resolution in tax controversies in general, and in particular in cross border matters has become a topic of significant relevance. Beside the possibility to appeal a matter in domestic courts, MAP and arbitration procedures to solve and remedy international double taxation have become important tools. With due regard to the OECD Pillar I and II projects, the importance of international tax litigation will get a further push and a raise of controversy on these new taxes may be expected. The panel will address and assess the efficiency and effectiveness of the existing tools to solve cross border tax controversies and will endeavor to provide an outlook of what may come next.



Thomas Meister

Thomas Meister is the co-founder of the firm’s tax practice and a partner in the tax team. He is working in the fields of domestic and international corporate tax, including tax op-timization, corporate and real estate finance, structured finance, corporate reorganiza-tions, transaction structuring and M&A. Since 2004 he is an adjunct professor for tax law at the University of St. Gall.

Thomas Meister was educated at the Universities of Lausanne and St. Gall (lic. iur. 1989, Dr. iur. 1995), New York University (LL.M. 1998), and graduated as certified tax expert (1996). For his doctoral thesis he received the 1995 Blumenstein Award. Prior to joining the firm he had working experience as a District Court clerk, general secretary at the Zur-ich Revenue Service, tax associate in Zurich, Geneva and Washington D.C. law firms and as a tax partner in a Zurich law firm.

Thomas Meister is fluent in German, English and French. He is registered with the Zurich Bar Registry and also admitted in New York.



Ryosuke Kono

Ryosuke Kono is a partner at Oh-Ebashi LPC & Partners. He represents clients in a number of complex tax litigation and administrative controversies. He also advises on tax matters in various types of domestic and cross-border transactions. His practice covers a wide range of tax issues, including transfer pricing, anti-tax haven rules (CFC rules), withholding rules, depreciation, permanent establishment (PE), customs duties as well as issues relating to cross-border restructuring, mergers and acquisitions and joint venture.

He previously served as a Review Officer (International Examination) for the Review Division (Large Enterprise Examination) of the Osaka Regional Taxation Bureau, where he handled a broad range of complex tax issues.

Education & Professional Experience

  • 2009-2011 Osaka Regional Tax Bureau, as a fixed term officer
  • 2006-2007 Weil, Gotshal & Manges LLP, New York
  • 2006 New York University (LL.M.)
  • 2000 Kyoto University (LL.B.)



Nur Amira Ahmad Azhar

Amira is a partner with the firm’s Tax, SST, and Customs practice. She is heavily involved in tax litigation and advisory with a specific focus on corporate tax, petroleum tax, tax incentives, transfer pricing disputes and the recovery of goods and services tax.

She advises and represents Fortune 500 companies, public listed companies, international and multinational companies as well as SMEs from various industries.

She has appeared before the Special Commissioners of Income Tax, High Court, Court of Appeal, and Federal Court. She is presently involved in one of the largest tax disputes in Malaysia amounting to RM9 billion in claims. She has successfully engaged in various negotiations with the Inland Revenue Board and the Royal Customs of Malaysia.

She regularly contributes to the firm’s publications and has conducted various webinars where she spoke on the current tax issues in Malaysia.

In recognition of her expertise, she has been appointed as a UiTMLaw Industry Reviewer for the tax law syllabus under the UiTM Bachelor of Laws program.


  • LL.B (Hons), Universiti Teknologi MARA (UiTM)
  • Advocate & Solicitor, High Court of Malaya

Practice Areas

  • Tax & Customs
  • Sales Tax & Service Tax
  • Trade Facilitation
  • Tax Incentives



Picharn Sukparangsee

Practice Areas

Mergers & Acquisitions
Corporate & Commercial
Banking and Finance
General services
Litigation & Arbitration


Thai, English


30 March 1961


  • 1992: LLM, Taxation Laws, King’s College London, University of London, England, UK
  • 1990: LLM, Laws on Trade and Investment, University of Warwick, Coventry, England, UK
  • 1986: Barrister-at-Law, Institute of Legal Education, Thai Bar Association
  • 1983: LLB, Thammasat University, Bangkok, Thailand


Mr. Picharn Sukparangsee is a founding partner of Bangkok Global Law.
He is one of leading lawyers in Thailand in respect of corporate & commercial Law, M & A transactions, Securities and taxation laws (specializing particularly in (M & A, securities , taxation law and litigation.
He regularly advises, and represents a wide variety of multinational corporate and clients from a vast array of businesses , including manufacturing, automobile, logistics, technology , service, real estate , cement, energy companies and listed companies.

He plays an important roles as an active member of the Legal Tax Committee and the Tax Committee of the American Chamber of Commerce in Thailand and the Legal and Tax Committee of the British Chamber of Commerce in Thailand.
He contributes to various international publications, including 'Doing Business handbook', published by The World Bank Group.

He is a frequent speaker on Thai laws and regulations at many international , regional and domestic conferences.


  • Thai Bar Association from 1986 to present
  • Lawyers Council of Thailand from 1989 to present
  • International Bar Association (“IBA”) from 2009 to present
  • International Fiscal Association (“IFA”) from 1995 to present
  • Inter-Pacific Bar Association (“IPBA”) from 2010 to present
  • The American Chamber of Commerce in Thailand (AMCHAM) from 2008 to present
  • The British Chamber of Commerce in Thailand (BCCT) from 2008 to present
  • Thai Chamber of Commerce (TCC) from 2008 to present



Rogerio M. Fernandes Ferreira

Rogério Fernandes Ferreira is the founder (2012) and managing partner of RFF Lawyers. Previously, he was tax practice area coordinator (2004-2012) and equity partner at PLMJ and Secretary of State for Tax Affairs of the XIV Portuguese Government (2001-2002).

Currently, he is the President of AFP, the Portuguese branch of the International Fiscal Association (IFA) and Latin American Institute of Tax Law (ILADT). Specialist in tax and business law, he holds membership in both Portuguese Bar Association and Brazilian Bar Association.

Since 2011, Rogério Fernandes Ferreira has served as a tax arbitrator at the Arbitration Centre for Administrative and Fiscal Affairs. Early in his career, he participated in committees, such as the Tax Offences Committee (1991-1992) and the Legislation Committee in the Portuguese Bar Association (1995). Additionally, he played a significant role in several Committees and working groups in the Ministry of Finance, serving as the Coordinator of the working group on procedures, processes, and the relationship between Tax Administration and the taxpayer. Rogério was a member of the Working Group for Taxation Competitiveness Studies (2008-2009), President of the Commission for the Reform of Public Real Estate Assets (2005-2006), and a member of the Committee Studying the Taxation of Financial Institutions and Products (1998-1999). He also participated in the working group for the Reform of the State Budget Legal Framework (1997-1998).

Rogério Fernandes Ferreira's academic journey began with a Law degree in 1987, followed by a Post-Graduate Program in European Law in 1990, and a Master of Laws (LLM) in Tax Law in 1991. Having initiated a PhD in law in 1997, he is lecturing in the advanced program in taxation at the Universidade Católica Portuguesa (PAFISC) and teaching at the Economic, Financial, and Taxation Law Institute of the Universidade Clássica of Lisbon (IDEFF).

Professional associations and networks

  • STEP - TEP
  • IFA
  • IBA
  • IPBA


  • Chambers & Partners - Band 1 Tax and Private Wealth Tax
  • Who's Who Legal - Corporate Tax Advisory and Controversy, Thoughleaders global elite Tax Controversy (2% of Global Ranking) and Thoughtleader Private Clients
  • International Tax Review - Tier 1, Tax Controversy
  • Legal 500 – Hall of fame
  • Private Clients Global Elite - first Portuguese invited
  • Best Lawyers – Litigation and Tax Law
  • Leaders League – Best tax firm in Portugal



Jaekyoung Han

As a distinguished member of the Tax Practice Group at Lee & Ko, Ms. Jaekyoung Han is renowned for her expertise in a wide spectrum of tax-related matters, encompassing international tax issues, tax planning, and general tax consulting. Her practice is specifically tailored to provide comprehensive advice and representation to both domestic and international clients, focusing on cross-border transactions and investments.

Ms. Han's proficiency extends to aiding global corporations in navigating the complexities of Korean markets, as well as devising strategic tax solutions for Korean businesses seeking international expansion. Her acumen in addressing intricate tax issues and disputes across various international jurisdictions has established her as a reliable advisor in the field.

In her recent endeavors, Ms. Han has played a pivotal role in guiding Korean brokerage houses through the intricacies of compliance with Qualified Intermediary obligations under U.S. federal tax laws. Furthermore, she has been actively involved in representing multinational companies in various tax disputes within Korea, particularly concerning withholding tax on Korean-source income.

Beyond her direct practice, Ms. Han's insights and expertise are highly sought after in the broader legal community. She is a respected speaker, having shared her knowledge at workshops and seminars hosted by prestigious organizations, including the British Chamber of Commerce.


  • 2018 Georgetown University Law Center ‒ LL.M in Taxation
  • 2017 Georgetown University Law Center ‒ J.D.
  • 2014 Seoul National University ‒ Social Studies Education

Work Experience

  • 2018-Present Lee & Ko

Areas of Practice

  • General Tax Consulting and Strategic Advisory Services
  • International Tax
  • Finance Tax
  • Foreign Investments
  • Outbound Investment


  • Admitted to bar, District of Columbia (2018)


  • Korean and English



Mark Gao

Rufeng Mark Gao is an equity partner at Zhong Lun Law Firm’s tax and wealth planning practice group. Mark has over 15 years’ experience of providing tax services to companies and individuals.

Mark is well-versed in tax dispute resolution, including serving as a tax expert for cross-border dispute cases, representing various Chinese central State-owned enterprises and private businesses in tax administrative appeals and litigations, and furnishing effective tax dispute resolution strategies for companies. Mark has successfully advocated for numerous clients in negotiations with both national and sub-national PRC tax authorities. He has implemented feasible tax planning strategies, proactively addressed tax inspections, and adeptly managed tax-related conflicts.

Mark's consistent recognition by esteemed sources like Chambers and The Legal 500 spans multiple years. He was recognized as one of the leading Individuals in the private wealth practice area by The Legal 500 in 2023. He stands as one of the select legal professionals to receive premier endorsements in both the realms of taxation and wealth planning.