Lewis Culliver has over 30 years of experience in tax roles for large financial services companies. He has expertise in international tax, M&A transactions, strategic planning, tax compliance, and managing the impacts of tax law reforms. As the Global Corporate Tax Leader for AXA, he led tax functions across Asia, Europe, and Australia, and collaborated on large cross-border financing and acquisition deals totaling billions of dollars. He has a track record of effectively managing tax risks, disputes, and ensuring compliance with authorities in multiple countries.

1. Core competencies
Deeptax knowledge
 Financial services expertise (top 50 global company) – insurance, funds management.
 International corporate groups – profit repatriation, transfer pricing, CFC management, international tax treaties.
 M&A– due diligence, contractual tax indemnities, structuring.
 Strategic planning – entitystructuring, debt structuring, risk management, employee share plans, forecasting.
 Compliance- reporting, regulator liaison, lodgements, rulings, dispute resolution, consolidated groups, thin capitalisation.
 Tax law reform- business impacts, change management.
 Broad coverage - profits taxes, GST, VAT, Stamp duties, employment related taxes.
 International tax law – Asia, USA, Europe.
Businesspartner and trusted advisor
 Excellent relationship development.
 Ability to understand the business context and deliver pragmatic solutions.
 Ability to simplifytechnical information and educate operational teams.
 Ability to identifyand manage keyrisks and prioritise resources.
Leadership
 Excellent stakeholder management: boards, CEO, regulators, senior managers.
 Effective change management.
 Strategic thinker.
Lewis Culliver
Global Corporate Tax Leader
7 Sheedy St, Richmond Vic 3121 AUSTRALIA lewis.culliver@gmail.com +61 (0) 447 713 086 Citizenship: Australian

2. Employment history
AXA SA - Deputy Head of Tax (reportingto the global head oftax), Paris, France, April 2011 – July2015.
AXA is a global financial servicescompany listedin Paris witha market capitalisationin
excessof €50 billion.AXA operatesin more than 60 countriesand employsmore than
120,000 people.Itskeybusinessesarelifeinsurance, generalinsuranceand funds
management.
 Liaisonwithinternational tax teams.
 M&A- tax risk identificationandlegal documentationtoaddressthose risks.
 Costsand benefitappraisal of entities,branchesandpermanentestablishments.
 Identificationof global tax risks associatedwithOECDinitiatives.
 Financial structuringrequiringtax-treatyinterpretation.
 Designandimplementationof the global responsetothe US FATCA legislation.(ForeignAccountTax
Compliance Act)
 Ongoingmanagementof the Australiansubsidiary requiringtechnical updateof Australianlaw
developments.
AXA Asia Pacific Holdings,GroupTax Manager, 1998 - 2011
 Reporting to the CFO, full planning and compliance responsibilities for direct and indirect taxes in
Australia and across Asia-Pacific.
 8 direct reports (Australia) and 7 indirect reports (Asia).
 Industry participation and advisor networking so as to be informed about law reform.
 Lodgement of all Income tax, GST, Payroll tax, FBT and stamp duty returns.
 Tax reporting in statutory accounts.
 Employee share plans.
 Transfer pricing involving foreign branches.
 Application of Controlled Foreign Company laws to Australian parent entities.
 Management of franking and foreign dividend accounts.
 Management of potential application of the thin capitalisation regime.
 Internal financing and the application of the debt/equity rules.
 Management of key reforms: life insurance; GST; tax consolidation; TOFA.
 Management of the Finance Graduate Program from 2005 to 2009.
National Mutual Life Association, various tax and finance roles from 1987 until 1998
 Broad tax roles encompassing compliance and reporting across direct and indirect taxes.
 3 years as Finance & Planning Manager for the Corporate Super business unit.
Henderson and Varalla Public Accountants, Accountant, 1984 - 1987
 Small business tax compliance work.
 Establishing corporate and trust structures and superannuation funds.
Ernst & Whinney, Senior Auditor, 1981 – 1984
 Audits of a wide variety of clients – manufacturers, law firms, stock brokers, insurance companies

3. Key achievements
Tax reform
Solution design and management of the business impacts of the following tax law
reform:
 Australian GST implementation - 2000.
 Life insurance tax reform – 2000.
 Tax consolidation – 2003.
 Thin capitalisation – 2003.
 Debt /equity reform – 2003.
 Controlled Foreign Corporations – 2004.
 Taxation of financial arrangements (TOFA) – 2010.
 Foreign Account Tax Compliance Act (FATCA) – 2014.
 Monitoring of OECD initiated reforms associated with Base Erosion and Profit Shifting
(BEPS) – 2015.
 Participation in industry and corporate tax associations.
Strategic projects
Collaboration with management and advisers on the following transactions:
 Australia / NZ / HK/ France cross border financing. ($500m)
 Divestment of Australian health insurance operations. ($570m)
 Divestment of Australian assets from France. ($3b)
 Divestment of Asian assets from Australia. ($10b)
 Acquisitions from Australia into: India, Philippines, Hong Kong, Singapore.
 Acquisitions from France into: India, UK, Hong Kong.
 Established a variety of pooled investment structures involving cross-border cash flows
(>$100m).
 Establishment of the AXA Asia Pacific employee and executive share plans.
 CreatedHK branchof AXA AsiaPacificHoldingsandimplementedtransferpricingpolicies for
Head Office services (annual service charges of $30m).
 Establishment of a Luxembourg investment fund enabling US loan origination. (€500m)
 Establishmentof a UK branch as a central insurance risk carrier (annual premium of €300m).
Risk management
Management of the following key compliance risks:
 ATO dispute resolution on GST, capital gains tax, and transfer pricing matters involving
private ruling appeals and federal court challenges.
 Dispute resolution with Indian, Hong Kong and New Zealand tax authorities.
 Franking account and foreign dividend account forecasting.
 Tax assumptions embedded in client product pricing (both life insurance products and unit
trust products).
 R&D credit claims.
 Passive income ratios for foreign entities.
 AFBAP ratios for foreign divestments.
 Transfer pricing practices and documentation for cross border transactions.

4. Education / qualifications
1984 Admitted to the Institute of CharteredAccountants of Australia
1981 BachelorofCommerce,MelbourneUniversity
Leadership/Mentoring
o Management of the AXA Asia Pacific Finance Graduate Program from 2005 through 2009.
This involved the recruitment of 8 graduates each year and on-going performance
management/mentoring during the 3 years of their graduate status.
o Fostered a collaborative and transparent global tax community during my time at AXA in
Paris through regular liaison with local tax managers and the organisation of annual
conferences.