Germany

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Frankfurt am Main

+49 69 9585 3551

ulf.andresen@pwc.com

www.pwc.de

Languages: German, English, French

Bar admissions: Eligible to appear in all German tax courts

Dr. Ulf Andresen is an international tax partner in PwC's Frankfurt transfer pricing team with 23 years of experience in advising multinational enterprises in international tax matters and transfer pricing. Moreover, he is a specialist in permanent establishment taxation and in transfer pricing matters in the financial services industry.

Concluded several APAs and mutual agreement procedures and has taken over a number of court cases on transfer pricing matters.

He is the co-publisher and co-author of the Permanent Establishment Handbook (Betriebsstätten Handbuch), the leading publication in PE taxation in Germany, and speaks frequently at tax conferences and contributes to national and international tax journals on a regular basis.

Ulf is also lecturing on tax and transfer pricing matters at the Otto Beisheim School of Management WHU, Coblence and at the Federal Tax Academy (Bundesfinanzakademie), i.e. the training institution for tax auditors in Germany.

Chartered Accountant (Australia)

Certified Tax Advisor (Steuerberater/StB)

Doctorate in Business Administration

Master Degree in Business Administration

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Berlin

+49 (0)30 2636 5204

lorenz.bernhardt@pwc.com

www.pwc.de

Languages: German, English

Bar admissions: Germany, New York (NY)

Lorenz Bernhardt is a senior transfer pricing partner at PwC Berlin. Lorenz also leads the transfer pricing practice of the PwC Europe Firm (its members being Austria, Belgium, Germany, The Netherlands, Turkey and Switzerland) as well as the EMEA region in the international PwC transfer pricing network.

Recent projects of Lorenz Bernhardt have included:

• Advising on, and implementation of, large restructuring projects including treatment under the German transfer of function rules;

• Negotiations and comprehensive filings relating to bilateral Advance Pricing Agreements matters for Blue Chip Groups; and

• Tax audit defence work with a focus on very large cases and high end transfer pricing matters.

Restructuring, Cost-sharing arrangements, Audit defence, Litigation, Transfer pricing

Industrials, Natural resources, Real estate, Transport

Lorenz obtained a law degree from the University of Munich and an LLM from New York University School of Law. Before joining the tax practice of an international accounting firm in Germany he had been working as a foreign associate with Fried Frank in New York. Lorenz is a German certified tax advisor and has been admitted as attorney-at-law both to the German Bar as well as to the New York Bar.

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Düsseldorf

+49 211 9811144

axel.eigelshoven@pwc.com

www.pwc.de

Languages: German; English

Axel Eigelshoven is a transfer pricing partner in PwC's Düsseldorf office and heads up the PwC German transfer pricing practice. He has more than 20 years of experience in international taxation and transfer pricing.

Axel works on a wide variety of transfer pricing projects including tax audits, intellectual property migration, tax effective supply chain management, permanent establishment issues, advanced pricing agreements and competent authority procedures under the tax treaty and the EU arbitration convention. His clients involve a number of DAX 30 companies, large multinationals and mid-size companies. Axel's primary focus is on the automotive, engineering and chemical industry.

Axel lectures at the Mannheim Business School, the Vienna University of Economics and Business and is a frequent speaker on transfer pricing at national and international seminars. He is co-author of Vogel/Lehner, Doppelbesteuerungsabkommen, a leading commentary on tax treaties, co-author of Kroppen, Handbuch der Verrechnungspreise, a leading publication on transfer pricing and is contributing to the German country chapter in IBFD's Global Transfer Pricing Explorer. Moreover, he has published numerous articles in national and international tax journals.

Audit defence, Dispute resolution, MAPs/ADRs, Litigation, Arbitration

Automotive, Aviation, Consumer goods and services, Industrials

Member of the Tax Advisors Association and the International Fiscal Association.

Axel holds a degree in business economics (Dipl.-Kfm. (MBA) from the University of Cologne) and is a certified tax adviser (Steuerberater).

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Hamburg

+49 (0) 40 6378 1304

kati.fiehler@pwc.com

www.pwc.de

Kati Fiehler is a transfer pricing partner in Hamburg.

She has an economic background and specialises in international transfer pricing issues and value chain transformation. She has gained extensive experience in advising multinational companies especially on restructuring of business models, on the design of inter-company business transactions and implementing or managing permanent establishment structures.

Kati has managed numerous projects for multinational corporations regarding outsourcing of business functions, implementation of transfer pricing models and documentation of transfer pricing issues. Kati has gained extensive experience in advising companies in several industries with a focus on renewable energy, defence and logistics.

Kati is a certified tax adviser (Steuerberaterin) and has completed a secondment at PwC's transfer pricing practise in London. She lectures in national seminars on her specialism.

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Munich

+49 89 57905424

joerg.hanken@pwc.com

www.pwc.de

Languages: German, English

Jörg has performed and managed numerous projects such as analyzing, planning, implementing, documenting and defending transfer pricing structures for about 20 years. Recent focus on developing and implementing TP software solutions for TP setting, margin monitoring, TP documentation, CbCR, data analytics, robotics.

• Bilateral APAs regarding distribution (Germany/US, TNMM berry ratio), manufacturing (Germany/Poland, C+), distribution (Germany/Switzerland, TNMM ROS), business restructuring (Germany/US, valuation), manufacturing (Germany/Romania, C+), manufacturing/distribution/service (Germany/Sweden, profit split)

• First bilateral APA regarding "variable royalty concepts" (automotive, Poland, Romania, Hungary)

• Several MAPs

Technology services, APAs, Dispute resolution, Arbitration, Transfer pricing, Operational TP, Digital services, Data analytics, Robotics, Software development

Automotive, Consumer goods and services, Industrials, Pharma and life sciences, Tech and telecoms

ICV, NACVA, Controlling Academy

German Certified Tax Advisor

Certified Valuation Analyst

Master Information Technology and Economics

Partner | Corporate Tax

PricewaterhouseCoopers GmbH WPG

Düsseldorf

+49 (0) 211 981 1966

heinz-klaus.kroppen@pwc.com

www.pwc.de

Before joining PwC in June 2014, Prof Dr Heinz-Klaus Kroppen gained more than 25 years of professional experience at Deloitte, where he led the German tax and legal function and the EMEA tax and legal practice during his last years. He was the co-founder and major shareholder of Deloitte Legal in Germany.

His work concentrates exclusively on international matters, mainly cross-border transactions, acquisitions and multinational corporations' tax issues with a strong focus on controversy.

Heinz-Klaus has led a number of tax audits, competent authority procedures and court proceedings including representation of his clients in the German tax courts and supreme tax courts.

He regularly negotiates advance pricing agreements (APAs) for large multinational clients. He was also involved in more than 50 APAs/MAPs and numerous court cases.

Since May 1, 2017 he has been leading PwC Legal globally, comprising of almost 4,000 lawyers in almost 100 countries. In addition to his global legal role he also leads PwC Legal in Germany. Furthermore he is a member of the PwC German Tax & Legal Leadership Team.

His recognition as a leading German tax and transfer pricing expert has led to his consistent selection for inclusion in Euromoney's guide to the world's leading tax advisers and the guide to the world's leading transfer pricing advisers.

Heinz-Klaus has been teaching international taxation for more than 20 years at the Ruhr University Law School in Bochum.

He studied law at the universities of Kiel, Hamburg, Cologne and later clerked at the German Tax Court in Duesseldorf and at the German/Korean Chamber of Commerce and Industry in Seoul. During this time, he wrote a dissertation on company law problems for which he was awarded his PhD in law. Heinz-Klaus later attended Georgetown University Law School (Washington DC) for postgraduate studies, receiving an LLM in international law. He is a certified tax adviser (Steuerberater).

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Düsseldorf

+49 (0)211 981 5201

claudia.lauten@pwc.com

www.pwc.de

Languages: German, English

Bar admissions: Certified tax advisor, admitted to all German fiscal courts

Claudia is a Tax Partner in the Transfer Pricing Team at PwC Germany. She has almost 25 years comprehensive experience in tax consulting, thereof more than 15 years in Transfer Pricing. Her expertise lies in the avoidance and solution of TP tax disputes, in particular tax audit defence, mutual agreement procedures, APAs and TP tax litigation.

Claudia is a member of PwC's global "Tax Controversy Dispute Resolution" leadership team, combining efforts with PwC offices in other countries on a day-to-day basis, and is heading the German TCDR practice. She is publishing and a frequent speaker on TP tax dispute resolution issues.

Business model optimisation, APAs, Audit defence, Dispute resolution, MAPs/ADRs, Litigation, Transfer pricing

Chamber of Tax Advisors

Business Administration, University of Augsburg, year 1996, German Certified tax Advisor, year 2000

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Munich

+49 (0)89 5790 5378

stephan.rasch@de.pwc.com

www.pwc.de

Languages: German & English

Bar admissions: Munich Bar

Prof. Dr. Stephan Rasch is a transfer pricing partner in PwC's Munich office. He has 18 years of experience in international taxation and transfer pricing. Before joining PwC in December 2013, Stephan worked with another Big Four firm as transfer pricing partner. Besides all transfer pricing-related matters, Stephan is successfully involved in German and European tax/transfer pricing audits, defending the restructuring and/or the transfer of intangible property in business model reorganizations. Stephan's experience with MAPs includes bilateral and multilateral cases as well as the negotiation of APAs. He is also involved in tax court litigation relating to transfer pricing cases.

Stephan advises clients in tax matters associated with cross-border transactions, including permanent establishment issues and value chain transformations. He has worked on a broad variety of transfer pricing projects for various industries, including the automotive and automotive supplier industry as well as chemical and pharmaceutical industries, the machinery tool, and IT sectors. Stephan's clients include German-based DAX companies as well as European and US multinationals for which he serves as lead tax partner.

Business model optimisation, APAs, Audit defence, Litigation, Transfer Pricing

Automotive, Healthcare, Industrials, Tech and Telecoms, Transport

Stephan is a member of the Munich Bar, the International Fiscal Association (IFA) and the IFA Bavaria board.

Stephan is professor of International and European tax law at the University of Augsburg. Stephan holds a PhD in International Tax Law and a degree in law from the University of Bochum. He is a tax lawyer (Rechtsanwalt/Fachanwalt für Steuerrecht).

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Stuttgart

+49 (0)711 25034 3107

martin.renz@pwc.com

www.pwc.de

Languages: German, English

Martin Renz has over 20 years of experience in international taxation and transfer pricing and leads the transfer pricing group at PwC in Stuttgart. He is frequent speaker on transfer pricing seminars, co-publisher and author of Renz/Wilmanns Internationale Verrechnungspreise, author in several commentaries and has published numerous articles.

• Carrying out value chain transfer pricing studies

• Implementation of entrepreneur structures, licensing structures

• Tax consulting within Advance Pricing Agreement procedures

• Led many projects for multinationals to set up global transfer pricing documentation

• Focused on the automotive, engineering and health care industry

Policy design, Restructuring, APAs, Dispute resolution, Transfer pricing

Automotive, Healthcare, Industrials, Engineering

German MBA (Diplom-Kaufmann), University of Bayreuth, 1997

Certified tax advisor, Steuerberaterkammer Stuttgart, 2001

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Düsseldorf

+49 (0) 211 981 7451

susann.van.der.ham@pwc.com

www.pwc.de

Susann van der Ham has 20 years of experience in consulting multinationals in the field of transfer pricing. Her expertise encompasses transfer pricing structuring, value chain transformation, system implementation, documentation and tax audit defence.

Susann's clients include several DAX 30 multinationals, as well as other US, European and Chinese corporations representing a wide range of industries. During the past few years, Susann led a number of projects involving permanent establishments, complex restructurings including transfer of functions and post-merger integrations. Susann is PwC's EMEA retail and consumer tax leader and a member of the international retail and consumer transfer pricing network. As such, Susann has in-depth knowledge of industry specific transfer pricing aspects.

Susann is a certified speaker on the German Federal Certified Tax Consultant Association's seminars and events and regularly speaks on international tax and transfer pricing conferences. She is a co-author of one of the leading German publications Borberg Praxishandbuch Verrechnungspreise and publishes frequently in national and international tax magazines on transfer pricing. Her recent publications include an article about service permanent establishments in China, an article about recent OECD developments regarding the profit attribution to dependent agent PEs and an article about draft APA regulations in Russia (all published in the magazine IWB), an article comparing German and OECD profit attribution rules for dependent agent PEs in the magazine ISR as well as an article on transfer pricing principles applicable for cash pool transactions in the Russian magazine Nalogoved.

Susann studied business economics and tax law at the Dresden Technical University, Germany, and Japanese and international tax law at the KEIO University Tokyo, Japan. She later enrolled at Maastricht University for postgraduate studies of international tax law. She is a German certified tax adviser (Steuerberater).

Partner | Transfer Pricing

PricewaterhouseCoopers GmbH WPG

Düsseldorf

+49 211 981 2237

ludger.wellens@de.pwc.com

www.pwc.de

Ludger Wellens is a tax and transfer pricing partner of PwC in Germany. He has more than 20 years of experience in all aspects of transfer pricing, international tax planning and corresponding controversy.

Ludger is certified as a German tax adviser (Steuerberater). He holds a diploma in international business from the University College Dublin (Ireland), an MBA from the University of Aachen and a PhD from the University of Bayreuth.

Ludger has worked for two of the Big 4 firms in their tax and transfer pricing departments. He was also member of the board and head of the transfer pricing group of a German based tax consulting firm. Furthermore, he worked as tax director and head of global transfer pricing for a major German based multinational company.

Both as an in-house consultant in industry and as an outside expert, Ludger has planned and implemented numerous transfer pricing systems. He has worked extensively on value chain transformation projects both inbound and outbound.

He has extensive experience solving controversies through defending tax audits and supporting mutual agreement procedures as well as advance pricing agreements (APAs).

He has experience in planning, especially optimising value chains, dispute resolution (audits, MAPs and APAs), business restructurings and valuations, documentation and implementation of TP systems.

Ludger specialises in the pharma and life sciences industry, chemicals industry, as well as in the consumer products and energy sectors.