Energy · Natural resources · Frontier markets
Senior international tax counsel for energy and natural-resources groups operating in frontier and emerging markets - brought in by in-house tax and finance teams to take on one high-stakes matter they lack the time or specialist expertise to cover, and hand it back resolved.
Where teams bring counsel in
Across energy and natural-resources groups operating in frontier and emerging markets.
When an audit, assessment or dispute with the authority goes beyond what the team can absorb, the mandate is to take the file, build the position and manage the authority-facing response. Experience includes an HMRC inquiry resolved with no penalties, and petroleum-tax assessments contested in Gabon, Equatorial Guinea, Mauritania and Ghana.
When a live transaction needs tax structuring, due diligence or step-planning the team has no bandwidth to run - from a US$4.8bn capital increase into a Brazilian oil & gas business to FPSO and subsea structuring, cross-border reverse mergers and E&P M&A.
When the group is moving into a jurisdiction no one in-house has operated in - fiscal framework, holding and financing structure, and government negotiations. Lead tax negotiator on Production Sharing Contracts across Africa and South America, securing fiscal-stability clauses and exemptions worth millions.
When OECD Pillar 2, a new corporate-tax regime or a transfer-pricing position lands and you need a senior, defensible answer quickly - without hiring a permanent specialist for a one-off question. Includes Pillar 2 readiness and a global transfer-pricing policy built across a 12-country group.
When shareholders or family principals need senior, confidential advice on private asset structuring, wealth preservation and succession - kept separate from the group's in-house function.
An in-house team should not have to carry every specialist problem alone. For one issue at a time, the file is taken on, resolved, and handed back with a defensible record.
Selected experience
Group-level tax leadership
Greenfield corporate tax, VAT and customs implementation across multiple business units; group tax policy, e-invoicing and direct tax-authority engagement.
Regional and group tax ownership
Group tax across 12 countries and a US$1.4bn-turnover group; resolved an HMRC inquiry with no penalties; built a global transfer-pricing policy and Pillar 2 readiness.
International tax and fiscal negotiations
Lead tax negotiator on Production Sharing Contracts with governments, securing fiscal-stability clauses and exemptions worth millions; FPSO and subsea structuring on a Ghana deepwater development; reverse merger of Norwegian entities; managed audits in Gabon, Equatorial Guinea, Mauritania and Ghana.
Cross-border structuring and M&A
Tax structuring for a US$4.8bn capital increase into a Brazilian oil & gas business; FPSO and FLNG structuring across Brazil, the Netherlands and Mozambique; petroleum production taxes and cross-border E&P M&A.
Earlier experience includes tax-law practice and Big Four exposure in Southern Europe, with a published and conference-speaking record in international and upstream oil & gas tax.
Credentials
Postgraduate taxation training with distinction-level performance
Professional credential in cross-border taxation
Law degree and tax-litigation postgraduate training
Examiner and moderator for the upstream oil & gas paper of a professional international tax qualification
Built for confidential, senior-level support where public attribution is less important than a resolved matter and a defensible file.
Working languages - English, Portuguese, Spanish