Sebastian Ma'ilei

Sebastian assists financial services clients with a range of transfer pricing issues ranging from policy design and implementation, cross border mergers (incl Brexit) and restructuring, Permanent Establishment threshold and attribution issues, Pillar 2 blending structures, tax residence domiciliation and branch profit exemption (BPEs), audit defence, APAs, US FTC planning using TP, IP strategy and policy design, TP disputes and controversy management (incl. PDCF), competent authority negotiations and litigation.

Sebastian has led assignments across Insurance clients (covering P&C and Life & Health, Lloyd's Syndicates, insuretech, MGAs and brokers), fintech (including. payment processing), investment & wealth management (traditional, multi-strategy managers, real estate, private equity, wealth management, and family offices).

Prior to joining the Firm, Sebastian handled the following matters:

• Advised on a dispute resolution of a traditional mainstream asset manager (US-Europe-Asia) involving global fee split policy and reward of investment committee and successfully defended the TP policies adopted by the client in respect of the above inter-company transactions.
• Advised on a MAP case in relation to brand royalty for a large asset management company and successfully defended the TP policy adopted.
• Advised and agreed the first UK/German branch profit attribution bi-lateral Advance Pricing Agreement (APA) for a large multinational insurance company under the new German branch profit attribution rules.
• Advised on the IP strategy and TP policy design for payment processing services and cryptocurrency platforms.
• Agreed the first unilateral reinsurance Advance Pricing Agreement (APA) in the UK for a large European reinsurance company.
• Advised on a PDCF for a major insurance company covering services, branch profit attribution and inter-company reinsurance.

• Chartered Accountant of New Zealand and Australia (CA)