Edwin Vanderbruggen
Senior Partner
Myanmar
2012年からヤンゴンに在住。エネルギー・発電、交通、通信分野での取引及び民営 化に関する政府への常任アドバイザーを務め、豊富な知識（Legal 500）と官僚主義 の難しさを知る能力に長けた弁護士（Chambers2016）として広く知られています。 ミャンマー大型プロジェクトを進める国際金融機関、石油・ガス、LNG発電のメジ ャー企業、外国企業の通信プロジェクト、或いは日本政府が進めるテラワSEZ等々に 対して、法制・税制面のアドバイスを行っております。新たにライセンスが供与さ れた外国銀行の設立支援或いは8億ドル都市インフラPPPプロジェクトなどへのサポ ートも行っております。2016年に締結された電力案件取引7件のうち6件に関与して おります。
Educational Attainment
- 1992 Bachelor of Laws, LL.B (Licenciaat in de Rechtsgeleerdheid) University of Antwerp, Belgium
- 1994 Master of Laws, LL.M (Bijzonder Licenciaat in Bedrijfsrecht en Fiscaal Recht) Thesis: “Do Domestic Anti-Avoidance Measures Interfere with International Tax Law?” (published and awarded) Free University of Brussels, Belgium
- In process – Doctoral Thesis (in Law): The International Protection of Investors under Bilateral Investment Treaties in Matters of Taxation and Tax Administration
Professional Employment History
- Partner – VDB Loi (March 2012 to Present)
- Partner; Managing Director, Tax & Customs Practice Group – DFDL MEKONG, Ho Chi Minh City, Vietnam (2007 – 2012)
- Advisor to Tax Department Direction – MINISTRY OF ECONOMY AND FINANCE, Phnom Penh, Cambodia (2006 – 2007)
- Partner/Tax Lawyer – ASIA PACIFIC TAX CONSULTANTS, S.E. Asian Region (1997 – 2006)
- Director, Tax Engineering – SNGI/GROUPE SUEZ, Paris, France (1994 – 1997)
- Lawyer International Tax Law – LOYENS & VOLKMAARS, Antwerp, Belgium (1991 – 1994)
- Legal Advisor – COMIRA, Antwerp, Belgium (1989 – 1991)
Teaching Experience
| INSTITUTE | PROGRAM | YEAR(S) | ||
| CFVG – National University of Economics (Vietnam) | Master of Business Administration | 2006 – 2007 | ||
| Royal University of Law and Economics (Cambodia) | Master in International Business Law | 2004 – 2005 | ||
| ITC – Leyden University (The Netherlands) | Master in International Tax Law (two lectures) | 2003 – 2004 | ||
| Chulalongkorn University (Thailand) | Master in International Business Law | 2002 – 2005 | ||
| IPO – Ufsia University (Belgium) | Master in International Tax Law | 1992 – 1995 | ||
| Handelshoge School University (Belgium) | Bachelor in Commercial and Diplomatic Relations |
Details of Major Projects Undertaken
MYANMAR
- Advisory for three of the ‘supermajors’ on their acquisitions of oil and gas interests in Myanmar
- Acted for a foreign-state-owned airport operator on its bid for the new Yangon International Airportumentation
- Acted for a foreign telecom operator on its multibillion dolar investment in Myanmar
- Advisory for a major Australian oil company on its farm-in into Myanmar
- Advisory for leading oilfield services companies regarding the legal and tax regime for drilling projects, lease of equipment and seismological services in Myanmar
- Acted for a Fortune 500 corporation in the tobacco industry with respect to its investment in Myanmar
- Acted for the SGX-listed developer of a major township in Myanmar
- Legal and tax advisory for a cluster of gas-fired power plants in Myanmar, including on licensing, corporate structure, tax structure and contractual documentation
- Advisory for a multinational provider of telecommunications systems on its market entry into Myanmar
- Acted for a multinational manufacturer of electronic products on its market entry into Myanmar
CAMBODIA
- Acquisition of a US$425M participation in a major telecommunication company, including regional tax structuring
- Tax-efficient structuring of a US$250M complex casino, hotel and tourism resort
- Merger of two telecommunications companies in Cambodia, tax structuring of the asset divestiture
- Divestiture of real estate assets of a listed property fund, legal and tax aspects
- Joint venture structure between a listed casino operator and a major property developer
- Tax structuring for a private equity fund
- Tax and legal advisory for the IPO of a major group of garment manufacturers
VIETNAM
- Tax-efficient structuring of a US$300M complex hotel and tourism resort
- Tax advice on a US$4.2B petrochemical plant
- Tax due diligence of a group of six real estate companies for acquisition by a listed equity fund
- Tax advice on loan restructuring for a French bank
- Tax structuring for a US$200M power plant of a listed power producer
- Transfer pricing advisory services for multinationals in the financial services sector, real estate development, and the manufacturing sector
- Tax structuring advice for engineering services to a public infrastructure project
- Pre-listing tax restructuring of a large consumer group
LAOS
- Tax structuring advice for engineering services to a mining project
- Tax dispute assistance for a telecommunications company
- Tax dispute assistance for a multinational in mineral extraction
- Tax structuring of the market entry of a multinational bank
- Legal and tax structure of a hospitality project
- Tax advisory in relation to the acquisition of a telecommunications company
OTHER COUNTRIES IN SOUTHEAST ASIA
- Singapore tax structure for a regional holding vehicle of a gaming enterprise
- Singapore tax structure for a regional holding vehicle of a multinational in petrochemicals
- Advice on filing restated corporate income tax returns, tax dispute in Singapore
- Transfer pricing analysis and justification for multinational corporations, including energy and engineering sectors covering Thailand and Indonesia
- VAT and corporate income tax implications and optimization for income derived from the construction and installation of a power plant project in Thailand (for a European multinational engineering company)
- Tax optimization of oil and gas operations on the continental shelf of Thailand/Cambodia/Malaysia (for a US oil company)
- Tax aspects of expatriate remuneration and special purpose employment vehicles in Thailand/Singapore/Hong Kong (for a US soft drink owner)
- Tax and customs duty aspects of an electric power project in Thailand
- Optimization of income derived from leasing equipment (for an Australian oil contractor)
- Tax due diligence of banks, multinational enterprises, airlines, real estate investment funds, and energy/infrastructure corporations
- Defense in tax and customs disputes (administrative phase and judicial) for various multinational enterprises in Thailand
- Transfer pricing analysis and defense for a multinational telecommunication company in Indonesia
Government Consulting Projects
| MYANMAR | |
| Assistance and Advice – Ministry of Commerce | (2013) |
| Assistance and advice on anti-dumping (in collaboration with international law firm Shearman & Sterling). | |
| Training and Assistance – Ministry of Finance and Revenue | (2013) |
| Training and assistance to the Customs Department on customs duty valuation and post-clearance audits. | |
| Training and Assistance – Ministry of Finance and Revenue | (2012) |
| Training and assistance to the Internal Revenue Department on income tax, DTAs, tax compliance and other tax issues. | |
| Research and Training – Ministry of Energy | (2012) |
| Assistance with research of production sharing contracts for onshore and offshore oil and gas exploration and production. Training to the Energy Planning Department: “PSC Features for Offshore Petroleum Exploration: Comparison of Cambodia, Indonesia, Myanmar and Vietnam” | |
| CAMBODIA | |
| Policy Evaluation – Taxation Department | (2006) |
| “Tax on Profit for Capital Gains realized by Physical Persons (Financial Act 2007)”: policy evaluation, drafting of law, drafting of regulation, discussions with Senior Minister and Tax Department Direction. | |
| Drafting Model Double Tax Agreement | (2006) |
| “Cambodia Model Double Taxation Agreement”: research and drafting of model agreement for future treaty negotiations, training of taskforce, comparative analyses of policy objectives, reports to Senior Minister and Tax Department. | |
| VIETNAM | |
| Training Project – Vietnam Government | (2006) |
| “International Dispute Resolution, Investment Arbitration and WTO law” Training Project, Ministry of Trade/Ministry of Commerce by CFVG National University of Economics (Vietnam) | |
| THAILAND | |
| Training Project – Thai Revenue Department | (2003-2004) |
| “Detecting and Assessing International Tax Avoidance and Evasion” Training Project, Thai Revenue Department 2003-2004 | |
| Project – World Bank | (2002) |
| “Suggestions for Tax Law Reform Thailand” World Bank (Economic Monitor) | |
Professional Publications
| Edwin has authored seven textbooks on international and Asian taxation and international law including: |
| “Thailand’s Double Taxation Agreements” (ISBN 974-203-159-2) | “Current Trends in Asian and International Business Taxation” (ISBN 974-203-073-1) | |
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| “Above and Beyond the Treaty: Essays on the International Legal and Institutional Structure of Double Taxation Agreements” (ISBN974-91981-6-6) | “The Law and Practice of Transfer Pricing in Thailand” (ISBN 974-92532-7-2) | |
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| “Tax in Cambodia”: A Practical Guide for Your Business (ISBN 978-999-636-060-2) | “Above and Beyond the Treaty: Essays on the International Legal and Institutional Structure of Double Taxation Agreements(2nd Revised Edition)” (ISBN 9-789996-360664) | |
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| “Vietnam Taxation of Permanent Establishments and the Foreign Contractor Tax: Source Taxation of Business, Construction and Services under Double Taxation Agreements (ISBN 9-789996-370700) | ||
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Furthermore, Edwin has published over 40 major contributions in international tax and legal journals. Some examples:
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