Treaty shopping paper

Paul Korganow

Paul Korganow, ATI, is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice, Public Groups and International. Paul leads an International Tax Structuring team based in Melbourne and Sydney. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2, the Australian ATO representative at OECD Working Party 11 and represented the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at two Big 4 firms in their International Tax and M&A groups. - Current at 16 February 2018

Chetan Prabhu

Chetan is a Senior Manager at Ernst & Young. - Current at 01 July 2010

Jayde Thompson

Jayde Thompson is a Managing Director with Alvarez & Marsal Tax in Melbourne. With over 16 years of experience in corporate international taxation, M&A, cross-border-related party arrangements and tax policy considerations. Jayde spent two years in New York advising US multinational companies and has also worked with the Board of Taxation on various policy considerations. - Current at 19 November 2025