Spain

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 4609

Email: miguel.cruz@es.pwc.com

Website: pwc.com/taxcontroversy undefined

Miguel Cruz received his degree in law from the Complutense University of Madrid and holds a diploma in community law awarded by the Constitutional Study Centre.

He is a member of the State Treasury Inspectors, of the Ministry of Economy and Finance (on extended leave of absence), was appointed as the taxation general director of Ministry of Economy and Finance and as general director of the Cabinet of the Ministry of Public Works, Transport and Environment.

Today he is an associate professor in the Spanish Open University (UNED).

He has taken part in numerous courses, congresses, conferences and discussion groups intended to increase knowledge of tax affairs and frequently writes in specialised reviews and publications.

Miguel Cruz has been national tax director at PwC since June 1996 and is a partner of PwC Tax & Legal Services in Spain.

At present, Miguel works for priority accounts of PwC Spain as a tax senior consultant or as a tax litigation lawyer. Telefonica, Nestle, BBVA and Banco Santander are some of his principal clients.

Avenida Diagonal, 654

Barcelona, Cataluña 08034

Spain

Tel: +34 932304848; ext 035804

Email: jdemolina@deloitte.es

Website: www.deloitte.com undefined

Juan Ignacio de Molina joined Deloitte Spain in 2009 as a transfer pricing partner in the international tax group. He now leads the Spanish transfer pricing practice comprising 50 professionals.

In the course of his professional career he has participated in projects dealing with tax efficient supply chain management (TESCM) structures, tangible transfer pricing projects, valuation of intangibles, business restructuring, profit participating financing agreements, R&D and IT licensing for several major clients in various industries.

Juan Ignacio has a degree in economics and business administration from Universidad de Barcelona; he has completed the senior management programme (PADE) at IESE Business School and a postgraduate degree in business valuation from New York City University, along with other specialised master's in taxation and Insurance companies.

As a result of his leading positioning in the international market, Juan Ignacio's team has been recognised by International Tax Review as best transfer pricing practice in Spain for 2009, 2010 and 2011.

Plaza Pablo Ruiz Picasso, 1 – Torre Picasso

Madrid 28020

Spain

Tel: +34 914432000

Email: rgomezacebo@deloitte.es

Website: www.deloitte.com undefined

Ricardo Gómez-Acebo, lawyer and economist (Spanish Universities) and MPA (Harvard University), has been a partner of Deloitte Abogados since 2005, when he joined the firm from the Ministry of Economy and Finance of the Spanish central government, where he had occupied relevant positions as a finance inspector.

Ricardo is in charge of the tax professional committee of Deloitte Abogados and advises his clients mainly in the corporate and international taxation areas, as well as on litigation and procedures before the tax administration. His main clients are large companies in the energy, infrastructure, real estate and services industries.

Ricardo is a member of the tax commission of the Spanish Confederation of Business Organisation; of the board of the Impuestos y Competitividad Foundation, promoted by the eight largest Spanish tax firms; of the Madrid Economists Association and of the Spanish Official Auditors Register (ROAC).

He is very active in terms of publications and teaching. In this sense, he is co-director of the four editions of the book 'Jurisprudencia Tributaria Básica' . Besides, he is a lecturer in the master's programme in taxation at ICADE and, formerly, at CEU and the Institute for Fiscal Studies. He is also a regular speaker at seminars organised by different institutions including the European Commission, the World Bank, the Inter American Bank for Development, the Institute for Fiscal Studies, APD or Expansion.

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 4542

Fax: +34 91 568 4672

Email: javier.gonzalez.carcedo@es.pwc.com

Website: pwc.com/taxcontroversy

Javier González Carcedo joined PwC Tax & Legal Services at the beginning of 2006 as the national leader of PwC Spain's transfer pricing group.

Javier is qualified in economic sciences, business studies and law and is a member of the body of National Finance Inspectors in Spain. Between 2000 and 2003, he was coordinator of international taxation within the General Directorate for Taxation at the Ministry of Finance, which is the competent authority for international tax matters in Spain. In 2003, he joined the cabinet of the Secretary of State for Finance.

In May 2004, he joined the OECD in Paris as adviser for the Centre for Tax Policy and Administration, with competences in tax treaties, transfer pricing and relations with non-member countries of the OECD. During his time with the OECD, he worked extensively in coordination of the proceedings with the different Latin American tax administrations and the Inter-American Tax Administration Centre.

In his experience with PwC, he has focused on transfer pricing planning and documentation services as well as all kinds of dispute resolution procedures involving the Spanish tax administration, including audits, advance price agreements and mutual agreement procedures.

Avenida Diagonal, 654

Barcelona, Cataluña 08034

Spain

Tel: +34 932304848 ext 3960

Email: jpelegay@deloitte.es

Website: www.deloitte.com undefined

Javier Pelegay is a Deloitte Spain tax partner based in the Barcelona office. He joined Deloitte in 2000 with more than 20 years' experience in tax services. In 2012, he was promoted to the position of global leader for tax controversy management.

Javier possesses wide-ranging experience serving international clients and their subsidiaries in the Catalonian region, including tax due diligence services. Although his experience covers a wide range of sectors and industries, he has mainly focused in the automotive, pharmaceutical and chemical sectors which are very prominent in the Barcelona area.

He has extensive specialisation in inbound investments (for both US and EU countries), local and international restructuring engagements, and due diligence and tax planning acquisition engagements.

Javier holds a law degree from Universidad de Barcelona and a master's in taxation from Abad Oliba, Barcelona.

He has been a member of the Barcelona Bar Association since 1986 as well as an elected member of the tax commission. In addition, he is a member of the editing council of the publication Fiscal al Día and a member of the Spanish Tax Association.

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 45 41

Email: antonio.puentes@es.pwc.com

Website: pwc.com/taxcontroversy undefined

Antonio Puentes is a partner at PwC Tax & Legal Services (PwC) based in the Madrid office. Antonio joined PwC in early 1999 after two years working in a medium-sized Spanish law firm. He has a law degree and two postgraduate courses (one development programme in tax controversy and dispute resolution advice and one master's degree in taxation). Antonio has been a member of Madrid's Bar Association since 1997, and having worked in PwC´s tax controversy and dispute resolution (TCDR) department since arriving at the firm, he now leads the Spanish TCDR practice, embedded in PwC's TCDR Network, which includes more than 650 tax controversy professionals, located in more than 45 countries worldwide.

Antonio's experience involves the areas of all tax controversy issues: international, state, regional and local tax.

Since 2005 he has also been involved in more than 100 projects with PwC´s European direct tax group, working together with PwC´s international tax services network assisting clients who are proactively defending the refund of taxes paid in breach of EU law.

He has broad experience in giving assistance in tax audit, tax litigation and judicial proceedings from a domestic and international point of view throughout the complete controversy lifecycle.

He has published articles on tax controversy and dispute resolution issues as well as collaborating in the preparation of some academic books in the area. Antonio also regularly lectures on several programmes in the TCDR area in prestigious Spanish universities such as Complutense and San Pablo-CEU.

Plaza Pablo Ruiz Picasso, 1

Madrid 28020

Spain

Tel: +34 915820900; ext 1662

Email: apuig@deloitte.es

Website: www.deloitte.com undefined

Alejandra Puig is a lawyer and member of the Madrid Bar association. She specialises in representing clients before the Spanish tax authorities and in coordinating complex tax audits for multi-national corporations. Alejandra also has significant experience in handling negotiation for complex tax disputes.

Alejandra regularly represents clients at all stages of the dispute process, including litigation in front of the Spanish Supreme Court and supporting and negotiating settlements.

She helps clients to efficiently resolve their tax dispute, assisting to negotiate favourable settlements with the tax authorities or, when necessary, by bringing appeals to the courts.

For more than 20 years, Alejandra has represented clients in a variety of industries, including financial services, manufacturing, pharmaceuticals, consumer products, media, and retail.

Alejandra also has significant experience in Spanish penalty procedures and has both spoken and written extensively with respect to numerous Spanish procedural issues.

Alejandra has a master's in European law from Granada University and she is a professor in several Spanish master's programmes for aspiring tax lawyers.

Avenida García Barbón, 106

Vigo, Galicia 36201

Spain

Tel: +34914432000

Email: lrodriguezotero@deloitte.es

Website: www.deloitte.com undefined

Luis Enrique has been a partner of Deloitte Abogados since 2012, where he coordinates the tax controversy and litigation specialised area in the northwest region of Spain.

As a lawyer and a member of the Vigo Bar association for more than 15 years, Luis Enrique's professional career has included his participation in and coordination of tax audits, tax litigations and judicial proceedings, tax due diligences, tax planning acquisitions and family businesses tax advising projects, from a wide range of industries and sectors, such as the automotive, fishery, construction, textile, financial and media ones.

Luis Enrique holds a law degree from the Universidad de Navarra and a master's degree in taxation from the Instituto de Empresa.

He has published several articles and collaborated in the drafting of books on tax controversy and litigation; Luis Enrique is currently a professor in taxation and tax procedure at IFFE Business School.

Avenida Diagonal, 654

Barcelona, Cataluña 08034

Spain

Tel: undefined +34 664 560 445/ +34 93 230 48 48

Email: eseoanesmith@deloitte.es

Website: www.deloitte.com

Enrique has been a partner in the tax department of Deloitte Spain since 2014.

He has extensive professional experience developed in Agencia Estatal de Administración Tributaria (State Tax Administration Agency), where he held the position of deputy chief inspector in Unidad Provincial de Inspección de Barcelona and Unidad Regional de Recaudación Ejecutiva de Cataluña . Furthermore, he has carried out tasks as the inspector assigned to the National Office of Inspection.

Enrique has occupied several management positions in the Agencia Estatal de Administración Tributaria (AEAT), such as AEAT administrator in Terrassa and Sabadell (Barcelona), between 2001 and 2006; chief of the Unidad Regional de Gestión de Grandes Empresas (Regional Unit of Big Companies) and inspector assigned to Dependencia Regional de Inspección de Cataluña (Regional Inspection Unit of Cataluña), between 2006 and 2014.

Enrique is a frequent contributor in courses, lectures, masters and seminars organised by several public and private entities, such as the Colegio de Economistas de Cataluña, Colegio de Abogados in Barcelona and Sabadell, the Official Chambers of Commerce of Sabadell and Terrassa, the Asociación Profesional de Expertos Contables y Tributarios de España, EADA, ESADE and Escuela de Hacienda Pública del Ministerio de Hacienda, among others.