The 30th International Petroleum Tax Conference

Rikard Gaarder Knutsen was appointed Deputy Minister in the Norwegian Ministry of Petroleum and Energy on 22 January 2019. He is a representative of the Norwegian Progress Party. Knutsen He was previously Deputy Minister in the Norwegian Ministry of Agriculture and Food. Earlier he also served as Political Adviser to the Minister of Agriculture and Food, the Minister for Transport and Communications, and to the Progress Party's parliamentary group. Knutsen is a mechanic by profession and is the group leader of the Progress Party in Røyken municipality. He has held a number of positions in the Progress Party in Buskerud County and in the Progress Party's youth organization.

Hilde Merete Nafstad is the Head of Finance and Control for Development and Production International at Equinor, covering more than 15 countries. She has held a variety of positions within the oil and gas industry since 1988. Before joining Equinor in 2007, she held various management positions in Norsk Hydro, Saga Petroleum, Aker ASA and the Norwegian Ministry of Petroleum and Energy. Hilde Nafstad has several years of international experience, including leadership roles in Houston, Texas, Stamford, Connecticut, and Singapore. She is a director of the boards of a number of Equinor subsidiaries. She also serves on the Board of Directors of Gjensidige Forsikring, a leading Nordic insurance group listed on the Oslo Stock Exchange. Nafstad holds a master in business and economics from the Norwegian School of Management.

Dr Carole Nakhle is the founder and CEO of Crystol Energy, an advisory, research and training firm, awarded Best Independent Energy Consultancy – UK 2018. With a unique breadth of experience, she has worked with oil and gas companies (NOCs and IOCs) at the executive level, governments and policy makers, international organisations, academic institutions and specialized think tanks on a global scale. She is active on the Governing Board of the Natural Resource Governance Institute and Member of its Audit and Finance Committee, and Advisory Board of the Payne Institute at the Colorado School of Mines. She is a program advisor to the Washington based International Tax and Investment Centre, and regular contributor to Geopolitical Intelligence Services and the Executive Sessions on the Political Economy of Extractive Industries at Columbia University in New York. She is also involved in the OECD Policy Dialogue on Natural Resource-based Development, where she contributed to the development of the organization’s Principles for Durable Extractive Contracts.
Dr Nakhle founded the not-for-profit organisation ‘Access for Women in Energy’ in 2007, with the aim of promoting the development of women in the energy sector, globally. She has also supported the development of similar initiatives in Ghana, Tunisia and the UAE, where she sits on ADIPEC’s Advisory Board for Inclusion and Diversity.
She has published two widely acclaimed books: Petroleum Taxation: Sharing the Wealth published in 2008 and re-printed in 2012 and used as primary reference in leading universities and industry training courses; and Out of the Energy Labyrinth (2007), co-authored with Lord David Howell, former Secretary of State for Energy in the UK.
In 2017, she gave evidence to the International Relations Committee at the UK Parliament on oil markets, the transformation of power in the Middle East and implications for the UK policy. In the same year, she received the Honorary Professional Recognition Award from the Tunisian Minister of Energy, Mines & Renewable Energy.

Graham has over 30 years experience as a petroleum economist, specialising in the
modelling and analysis of global petroleum fiscal systems.
He has advised several governments on petroleum fiscal policy, most recently Algeria,
Ireland, Newfoundland & Labrador, PNG, Qatar and South Africa. He has also
advised numerous IOCs and oil industry associations during debates with
governments on appropriate terms (e.g. Alaska, Australia, Nigeria and UK).
Graham oversees Wood Mackenzie’s fiscal information gathering, modelling and
reporting and is the lead author of Wood Mackenzie’s multi client reports comparing
global fiscal systems. He also has wide experience delivering training courses in
petroleum economics and fiscal analysis around the world.
Graham graduated in Economic Science from Aberdeen University and earned a
masters degree (M Litt ) for his thesis on ‘Oil Field Abandonment in the UKCS’. He
previously worked for Petroconsultants, two independent oil exploration companies
and as a Research Fellow in Aberdeen University’s Economics department.
He is a member of the Association of International Petroleum Negotiators (AIPN) and
is a regular speaker at industry conferences.

Global Lead, Tax Policy for Government Services, EY 2017 to present. Built and leading EY’s global team supporting governments’ analysis, design, and implementation tax policy and administration reform. Special emphasis on international tax issues and on supporting Public Financial Management programs. Working closely with global architects of the international tax system, including OECD, EU, and international organizations. Projects to date in EU, Middle East Asia, and Latin America.

Lead Tax Specialist, Global Tax Team, World Bank Group. 2015-2017.
Global lead, International Tax at the World Bank Group. Program focuses on implementation of transfer pricing instruments, tax treaty policy, and implementation of the G20 Base Erosion and Profit Shifting program. Operational work in Africa, Asia, ECA, MENA, and Latin America. Sector specific work on extractive industries and agriculture. Lead WBG work on tax transparency and in G20 analytical work. Co-author of WBG Offshore Financial Center Policy. Manage program budget of $20 million.

Global Program Lead, Business Taxation Program, World Bank Group, July 2007-2015
Designed and implemented Business Taxation Program; managed global and regional teams 2007-2013, then lead technical expert 2013-2015. Program focused on all taxpayer groups, including multinationals and SMEs; international and domestic tax instruments and administration. TA Program budget $15 million and in charge of fund raising/donor relations.

Academic Experience
Senior Lecturer, Vienna University, Tax and Law Faculty. 2013 to present. Courses for PhD candidates and Masters students on tax and development
Assistant Professor, University of California, Los Angeles, Department of Economics, 1994 to 1996.
Courses include seminars in international economics and intermediate macroeconomics.

Education
Ph D, University of California, Berkeley, Department of Economics, 1992.
Thesis title: Monetary and Financial Aspects of Economic Reform in Transition Economies
Fields of concentration: international economics, pubic finance, and macroeconomics.

Aengus is a transfer pricing partner, sitting within Deloitte’s UK firm. He joined Deloitte 16 years ago and since that time has spent a significant portion of his career assisting clients in the energy and resources industry. He has particular experience in complex energy pricing projects within the oil & gas sector, such as using risk pricing techniques to support the margins retained by marketing entities to leading one of our most difficult diversionary LNG cargo pricing assignments.
Aengus has experience delivering a broad range of transfer pricing services, from documentation and compliance reports to IP planning exercises and debt pricing projects. He has worked on a number of APAs and also has experience of wider international tax issues through participation in several tax structuring projects.
Aengus holds both bachelors and masters degrees in Economics and is a CFA Charterholder.

Extensive experience on E&P taxation on the NCS from:
- The Directorate of Taxes
- The and Ministry of Finance
- The Oil Taxation Board
- Partner and Head of Energy Taxation in PwC Norway
- Attorney and Partner in the Law Firm Harboe & Co
- Assisting numerous E&P companies with tax issues on the NCS (close to) full time during the last 20 years

Education:
- Master’s degree in Law, University of Oslo
- MBA, University of Bradford
- Business Economics, Norwegian School of Management (BI), Oslo

Ove Lykke Hindhede is partner in the Oil & Gas – Shipping practice in PwC Copenhagen. He is cand.jur, Ll.M master of laws with Copenhagen and San Diego Universities.

Ove has worked with tax issues for oil and gas clients for almost three decades, and his department in Denmark serves a majority of domestic and foreign oil and gas clients doing business in Denmark. The work includes advice / planning / consulting services, compliance work, negotiating with authorities, Tax Courts, etc.

Alfred Grannas has been a member of the German Foreign Office since 1990. His past postings include Lima, New York and Oslo, among others. He also worked for the United Nations in Kosovo and for the EU-Delegation in Afghanistan. Furthermore, he served as Deputy Director General for Infrastructure and Security in the Federal Foreign Office in Berlin. Since August of 2018, he is Ambassador of the Federal Republic of Germany to Norway. Alfred Grannas is married and has one son.

Anna Theeuwes is currently Global Tax Policy Manager at Shell International BV. She has over 20 years of experience in advising on international tax matters, first with PriceWaterhouseCoopers in Brussels, Belgium and subsequently within the Royal Dutch Shell group out of The Hague, Netherlands. She held regional roles in Upstream tax, covering Europe and Africa, and at present is the focal point for energy transition related tax policy matters for the group.
She is a frequent contributor to UN and OECD tax debates on international tax and climate change related tax matters. She participates in business organisation discussions towards the European Commission on climate change and energy transition related tax issues and chairs Dutch and Europe focused tax committees on Energy Tax and Green Taxation.
She studied law at Leuven University (KUL), Universite de Poitiers and Heidelberg’s Karl-Ruprecht University and tax law at Erasmus University in Rotterdam.

Mark Robinson is the Executive Director of the Extractive Industries Transparency Initiative (EITI), a global multi-stakeholder initiative on extractives governance that brings together governments, companies, and civil society organizations. He is an accomplished senior leader with over 30 years' experience in governance, extractives, climate and international development, and a career spanning the worlds of policy, operations, research and philanthropy. Mark joined the EITI in November 2018 from the World Resources Institute in Washington D.C., where he served as Global Director for Governance, leading an ambitious climate and environmental governance strategy focused on natural resource governance, climate resilience, energy access, and environmental democracy.

Mark previously occupied senior positions at the Department for International Development, the Institute of Development Studies, the Ford Foundation and the Overseas Development Institute. He has held numerous board and advisory roles, and currently serves as Board Chair of the Open Government Partnership Secretariat. Mark holds an MA and DPhil in Comparative Politics from the University of Sussex, and a BA honours degree in Social and Political Science from the University of Cambridge.

Sjoerd Douma is a Partner at Lubbers, Boer & Douma and Professor of International & European Tax Law at the University of Amsterdam. Prior to his appointment in October 2017, he was a professor at Leiden University.

At the IFA Congress in Rio de Janeiro (2017), Douma was appointed as a Member of the Permanent Scientific Committee of the International Fiscal Association. Douma has specialized in corporate income taxation, tax treaties, European tax law (including Fiscal State Aid) and procedural law. He is a Member of the Board of the Dutch Association for International Tax Law (‘Nederlandse Vereniging voor Internationaal Belastingrecht’).

Douma is the lead instructor in the massive open online course ‘Rethinking International Tax Law’ which has attracted more than 40,000 participants from all over the world. In 2017, Douma received Coursera's Learners First Outstanding Educator Award, out of over 2,000 courses on Coursera. This award honours the instructor who best exemplifies the “Learners First” principle, as demonstrated by a combination of course ratings and course completions.

Douma has been a Deputy Judge in the Court of Appeals of Arnhem-Leeuwarden and a Deputy Judge in the District Court of Haarlem in the Netherlands between 2005-2018. He is a permanent contributor to leading Dutch and international tax journals and has authored and co-authored numerous publications and reports on national, international and European tax law. He is a frequent speaker at high level domestic and international conferences and seminars. In 2012, Douma’s PhD thesis ‘Optimization of Tax Sovereignty and Free Movement’ won the prestigious bi-annual Dissertation Prize of the Dutch Association for Tax Research.

Prior to joining Lubbers, Boer & Douma in March 2017, Douma has been practicing tax law at one of the big four accountancy firms for more than 12,5 years. He has represented both natural persons and companies before the tax authorities, the European Commission, the Dutch Supreme Court and the Court of Justice of the European Union. Douma has acted multiple times as an expert witness in international arbitration and court proceedings. Before joining private practice, Douma was a legal clerk at the Dutch Supreme Court, where he wrote draft judgments and opinions of the Advocate-General.

2005- Oil Taxation Office (director of Tax Audit Department since 1st Nov 2012, responsible for the annual tax assessment of oil and gas companies operating on the Norwegian continental shelf )
2002-2005 Office of the Auditor General of Norway (executive officer)
1998-2002 Studies at NHH the Norwegian School of Economics ("siviløkonom")

Joachim is head of BAHR’s tax group. His tax practise covers a wide range of areas within corporate and international tax, including transfer pricing, the special petroleum tax regime and structuring M&A transactions. Joachim’s vast experience of M&A transactions, including the corporate side, makes him a particularly valuable tax advisor in complicated transactions.

He is also one of the leading transfer pricing experts in Norway and assists clients with a variety of transfer pricing issues including tax litigation. Joachim has written one of the leading textbooks about transfer pricing in Norway and together with Jan B. Jansen, he also wrote a short introduction to the Petroleum Tax Regime, used as reading material at the University of Oslo.

Joachim was a member of the government-appointed eight-person expert tax that considered and proposed changes to the tax system in Norway (2013-2014). Their report forms the basis for last tax reform in Norway, implemented from 2015 onwards.

Joachim is also often used as lecturer in various tax subjects.

PROFESSIONAL EXPERIENCE
2003 - Partner, BAHR
2000 – 2002 Senior Associate, BAHR
1997 – 1999 Associate/Senior Associate, Law Firm Thommessen AS
2000 International Tax Program, Harvard University, USA
1996 Cand. jur., University of Oslo

PUBLICATIONS

Ongoing:
• Country chapter for Norway in IBFD's Mergers & Acquisitions database, updated twice a year.
• Country chapter for Norway in IBFD's Transfer Pricing database, updated twice a year.
• Various articles/commentaries in tax journals, newspapers and magazines.

2019 Bedrift, selskap og skatt, 7th edition (2019), 6th edition (2014), 5th edition (2010) and 4th edition (2006), co-author, leading text book for corporate tax in Norway.

2014 Transfer Pricing and Corresponding Adjustments, chapter in the book Festskrift til Frederik Zimmer, Oslo 2014.

2011 An introduction to Norwegian Petroleum Taxation, Oslo 2011 (with Jan B. Jansen)

1997 Internprising: Skattemessig prising av transaksjoner mellom tilknyttede parter – en historisk og komparativ fremstilling, Oslo 1997.

Jim Robertson B.Acc CA CTA FCMA is a non-executive director in the Scottish Government and deputy chair of the Government's Audit and Assurance Committee. He was global head of oil & gas tax in Shell for 11 years and is a Senior Fellow of ITIC, an education foundation based in Washington DC. In that role he delivers capacity-building programs to tax officials in developing countries together with the IMF, OECD and UN. He is a member of the UN Subcommittee on Extractive Industries Taxation Issues for Developing Countries and the conference committee of the Norwegian Petroleum Association.
Jim chairs the academic board of the Advanced Diploma in International Tax of the UK Chartered Institute of Taxation (CIOT). He sits on the governing Council of the Institute of Chartered Accountants of Scotland (ICAS) and is a member of its Scottish Taxes Committee. He was the inaugural chair of the Scottish Tax Policy Forum, a joint venture between ICAS and CIOT.
Jim qualified with PwC in 1981 and joined Shell the same year. He had nine different tax and finance roles in Shell and lived in London, The Hague, Kuala Lumpur, Aberdeen and Houston. He was a founder member of Shell’s Finance Social Investment Network which connected staff to voluntary organizations in need of finance skills and experience. In Shell Finance he had global responsibility for promoting professional qualifications and for communications on diversity & inclusion.

Stig Sollund: Cand. Jur. from University of Oslo 1975. Has held various positions at the Norwegian Ministry of Finance since 1980 where his areas of work have included legislation on business taxation, special tax regimes for petroleum production, hydro power and shipping, transfer pricing and tax treaties. His present position is director general for international tax at the Tax Law Department. Mr. Sollund is delegate to the OECD Committee on Fiscal Affairs and Member of its Bureau, Working Party no 6 and its Bureau (on Taxation of Multinational Enterprises). He was a member of the United Nations Committee of Experts on International Cooperation in Tax Matters for twelve years (2005-2017) and coordinator of its Subcommittee on Transfer Pricing mandated to develop and keep updated the UN Transfer Pricing Manual for developing countries. He has also served as deputy judge and practiced tax law in the private sector as partner of the Oslo law firms Arntzen & Underland and Bugge, Arentz-Hansen and Rasmussen (BAHR).