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Edwin Vanderbruggen

Edwin Vanderbruggen

Senior Partner

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。

Area of Practice

Tax and legal advisory

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

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


  • 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


  • 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


  • 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


  • 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


  • 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

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”
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.
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)
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)
“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)
“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)
“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)
Furthermore, Edwin has published over 40 major contributions in international tax and legal journals. Some examples:

  • “Source Taxation of Consideration for Technical Services and Know-How with Particular Reference to the Treaty Policy of China, India and Thailand”, Asia-Pacific Tax Bulletin.
  • “About the Deductibility of Head Office Expenses: A Commentary on Art. 7(3) of the OECD Model, the UN Model and Alternative Provisions Adopted in Tax Treaty Practice” Intertax
  • “AFTA Based Customs Duty Planning”, Asia-Pacific Tax Bulletin
  • “Salient Features of the ASEAN Model Tax Treaty”, Tax Notes International
  • “The Principle of Good Faith and Double Taxation Agreements”, British Tax Review
  • “Unless the Vienna Convention Requires Otherwise”, European Taxation


Edwin speaks English, Dutch and French and is conversant in Thai and German.