SHARANNE AU

September 2019 - December 2022: Shell International BV - The Hague, Netherlands

Supports Senior VP Finance - LNG in managing the tax affairs of the global integrated gas portfolio spanning natural gas exploration, development, production, liquefaction, and Gas to Liquids manufacturing.

Leadership

• Leads country teams and business tax advisors in developing and implementing tax strategies for new country entries and projects in existing integrated gas locations.
• Supports business decision-making, manages tax risks (transfer pricing, direct, and indirect tax), and optimizes tax positions across multiple jurisdictions.

Stakeholder Collaboration

Internal Stakeholders

• Collaborates with senior business and finance leaders, business representatives, and cross-functional teams within Shell.
• Articulates complex tax issues and strategies to stakeholders.
• Ensures opportunities and risks are well understood and accurately reflected in management and investor reports in a timely manner.
• Ensures key business decisions are documented for defense file purposes.
• Secures necessary buy-in for effective tax issue management, including internal and external resourcing requirements.

External Stakeholders:

• Engages with external auditors and consultants, joint venture partners, industry counterparts, government agencies, and international organizations such as the OECD.
• Enhances understanding of business operations, commercial rationale, and tax laws, rules, and regulations.
• Ensures alignment in tax and accounting positions.
• Advocates for sound tax policies.
• Strengthens relationships to facilitate cooperation on shared objectives.

Projects

• Head of Pillar 2 Centre of Excellence (2023 – Present) - Leads a global team of senior tax professionals in the interpretation and application of Pillar 2 rules and regulations.
• Pillar 1 Advocacy Lead (2020 – 2023) - Led a team of senior tax professionals in reviewing and editing draft OECD guidelines. Engaged with the OECD and counterparts in the extractives industry on policy development. Influenced the drafting of policy to secure the desired outcome for Shell’s Gas to Liquids manufacturing.
• Tax Digitalisation - Head of Project Mutatio (2020-2022) - Led a global team of tax professionals in researching digital technologies aimed at predicting tax risks in key jurisdictions, prior to the availability of advanced AI models like ChatGPT and Co-Pilot. This work enables ongoing monitoring of digital developments and potential future applications for tax.

• Accountable for all taxation matters relating to the Shell Group of Companies in Singapore and Myanmar (combined turnover and capex of approx. USD 100B and USD 10B respectively). Businesses supported include: Oil products and Chemicals manufacturing, LNG Trading, Oil & Products Trading, Shipping, Catalysts, Treasury and Myanmar Upstream Oil and Gas.
• Led a team of senior tax professionals (5 onshore and 14 offshore) in the delivery of in-house taxation services such as corporate tax advisory and compliance services, the management of tax audits, dispute resolution, goods and services tax, employment tax and pension fund related tax issues.
• Responsible for the design and operation of tax governance controls and procedures.
• Partner to the Shell businesses in the management of tax risks domestically and internationally.
• Led engagements with external stakeholders, including tax authorities, government departments, and industry associations.
• Shaped tax legislation and regulations in Singapore and Myanmar.
• Member of the tax leadership team for Asia Pacific.
• Member of a dynamic team responsible for the design and implementation of the mentoring scheme for Asian and Female Talent in Shell's global tax organisation.
• Director of Shell Treasury Centre East

• Regional tax advisor for the LNG trading and oil trading businesses in the East.
• Primary tax interface with the business on direct and indirect tax matters for the region, involving senior stakeholder management.
• Responsible for designing and implementing governance processes within the businesses to ensure senior management oversight and robust compliance from the business with key tax principles (eg. substance, corporate separateness, transfer pricing, permanent establishment etc).
• Project team lead for a bilateral advance pricing agreement involving Australia and Singapore. Member of tax team supporting Shell’s acquisition of British Gas. Provided tax advice on integration related issues (such as roles and responsibilities, corporate authorities, service level agreements, cost allocations etc) instrumental in the formulation of tax defensible transfer prices on various transactions for upstream and downstream business transactions.
• Led and engaged in discussions with tax authorities and government agencies in Singapore, Australia and the Maldives with successful outcomes.

• Responsible for international tax and transfer pricing “TP” oversight of the projects and technology businesses in the upstream, midstream and downstream (for cost sharers, non-cost sharers and third parties) in the Asia.
• Advised on tax issues for floating LNG technologies and services, involving multiple tax jurisdictions (Australia, UAE, France, Indonesia, Malaysia, the Netherlands, South Korea, Singapore) and negotiated tax contract clauses with Shell’s JV partners.
• Worked within tight deadlines with multiple stakeholders across various functional and business organisations within Shell, each with competing priorities.
• Other projects include: R&D investment in Japan for the development of a liquid hydrogen ship prototype, China transfer pricing risk mitigation, India transfer pricing audits.
• Conducted permanent establishment risk assessments for countries in Asia, and held regular training sessions for the business on permanent establishment, transfer pricing, withholding tax, and corporate & organisational authorities.
• Member of Shell's Permanent Establishment Centre of Tax Excellence team.

• Singapore Tax Advisor to the Singapore trading businesses (Oil Trading, LNG trading, Supply & Distribution, Global Sulphur, Bitumen, Chemicals Trading, Lubricants and Marine).
• Provided tax advice on activities including, the migration of business activities to Singapore, oil price exposure management, derivative trading, the taking of storage positions, and the setting up of new trading desks, review of commodity sale and purchase agreements, structuring of gas marketing activities and licenses.
• Member of project team for a bilateral advance pricing arrangement with Australia. Participated in discussions with the Singapore tax authorities, evaluated and developed arguments in defence of the transfer price.
• Assisted in shaping Singapore Global Trader Programme tax legislation, resulting in operational enhancements.
• Developed and implemented internal governance processes and guidelines and conducted tax awareness sessions for business stakeholders.

• Developed tax incentives together with government agencies such as Ministry for Finance (“MOF”), Economic Development Board and SPRING Singapore.
• Studied the UK R&D enhanced tax credit system, and worked with the Economic Development Board and the MOF to develop an R&D tax incentive for Singapore. This involved ensuring that policy details could be practically operationalised, evaluating the interactions of the policy with existing R&D tax provisions, and working with lawyers in both IRAS and the Attorney General's Office in the drafting of tax legislation. Authored the IRAS Practice Note: Research and Development Tax Measures that was published on 31 October 2008.
• Partnered government agencies in the administration of various tax incentives and provided clarification to companies on the interpretation of tax laws by way of advance rulings. Provided guidance to the corporate tax division in IRAS on the interpretation of tax laws.
• Other activities: Speaker at IRAS Budget Seminar for taxpayers in 2007; Speaker at internal briefing session for IRAS Officers in 2006 on the comparison of Singapore’s Research & Development, and Intellectual Property tax regime with respect to that of the United Kingdom and Ireland; Speaker at various IRAS engagements with foreign tax officials from developing countries, on the role Singapore's Tax Policy plays in attracting foreign investors.

• Dealt with corporate tax payers on tax compliance issues and dispute resolution. Provided clarification to tax agents and taxpayers on corporate income tax practices and on the application of corporate tax laws.
• Spoke at taxpayer education seminars and conducted in house training on topics such as transfer pricing.
• Member of organising committee for the Singapore Tax Policy & Administration Course 2003 hosted by IRAS for the public.

• Responsible for the corporate tax advisory and compliance matters of more than 50 active companies. Engaged with government agencies to promote client applications for tax incentives, and drafted updates for CCH Master Tax Guide in line with budget announcements and changes in tax legislation.