Austria

August 16, 2017

Herbert Greinecker
	PwC Erdbergstrasse 200 1030 Vienna Austria Tel: +43 1 50188 3300 Email: herbert.greinecker@at.pwc.com Website: pwc.com/taxcontroversy Herbert Greinecker is a partner and head of the Austrian transfer pricing team. He joined the firm in 1985 and has more than 30 years of professional experience in advising domestic and multinational enterprises in national and international legal and tax matters. Herbert has been involved in a number of transfer pricing projects covering tax planning, transfer of functions (value chain transformation) and transfer pricing documentation aspects. He serves a large number of subsidiaries of international corporations in Austria as well as Austrian based multinational clients. He has intense tax audit experience, mostly on transfer pricing matters, and assisted clients in obtaining advance rulings, as well as negotiating advance pricing agreements. Further, Herbert is a frequent speaker at conferences and seminars on transfer pricing related matters as well as an author in the field of transfer pricing. Herbert holds an MBA from the Vienna University of Economics and a doctorate from the University of Vienna. Herbert is a member of the Austrian Chamber of Accountants as a certified public accountant and tax adviser, member of the tax experts board of the Austrian Chamber of Accountants and several working groups thereof, and member of the Austrian branch of the International Fiscal Association.

Herbert Greinecker

PwC

Erdbergstrasse 200

1030 Vienna

Austria

Tel: +43 1 50188 3300

Email: herbert.greinecker@at.pwc.com

Website: pwc.com/taxcontroversy

Herbert Greinecker is a partner and head of the Austrian transfer pricing team. He joined the firm in 1985 and has more than 30 years of professional experience in advising domestic and multinational enterprises in national and international legal and tax matters.

Herbert has been involved in a number of transfer pricing projects covering tax planning, transfer of functions (value chain transformation) and transfer pricing documentation aspects. He serves a large number of subsidiaries of international corporations in Austria as well as Austrian based multinational clients. He has intense tax audit experience, mostly on transfer pricing matters, and assisted clients in obtaining advance rulings, as well as negotiating advance pricing agreements. Further, Herbert is a frequent speaker at conferences and seminars on transfer pricing related matters as well as an author in the field of transfer pricing.

Herbert holds an MBA from the Vienna University of Economics and a doctorate from the University of Vienna. Herbert is a member of the Austrian Chamber of Accountants as a certified public accountant and tax adviser, member of the tax experts board of the Austrian Chamber of Accountants and several working groups thereof, and member of the Austrian branch of the International Fiscal Association.

Bernhard Groehs
	Deloitte Austria Renngasse 1/Freyung 1013 Vienna Austria Tel: +43 1 53700 5500; +43 1 53700 99 5500; +43 664 80537 5500 Email: bgroehs@deloitte.at Website: www.deloitte.at Bernhard Groehs, Deloitte Austria, is the CEO. His practice includes mergers and acquisitions, structured investments and strategic consulting in public sector projects. His team includes more than 15 specialised litigation experts. Bernhard has specialised in tax and criminal tax law for many years, and has been a court-certified expert since May 2014. Bernhard has written more than 100 pieces published in all leading Austrian legal magazines and publications. He has been a teaching assistant at the Law University of Economics, Vienna, and a member of the University of Vienna law faculty. Bernhard is a member of the Austrian Institute of Certified Public Accountants, the International Association of Boalt Hall Alumnis (IABA), the International Fiscal Association, Rotary, and the Board of CFO Club Austria.

Bernhard Groehs

Deloitte Austria

Renngasse 1/Freyung

1013 Vienna

Austria

Tel: +43 1 53700 5500; +43 1 53700 99 5500; +43 664 80537 5500

Email: bgroehs@deloitte.at

Website: www.deloitte.at

Bernhard Groehs, Deloitte Austria, is the CEO. His practice includes mergers and acquisitions, structured investments and strategic consulting in public sector projects. His team includes more than 15 specialised litigation experts. Bernhard has specialised in tax and criminal tax law for many years, and has been a court-certified expert since May 2014.

Bernhard has written more than 100 pieces published in all leading Austrian legal magazines and publications. He has been a teaching assistant at the Law University of Economics, Vienna, and a member of the University of Vienna law faculty.

Bernhard is a member of the Austrian Institute of Certified Public Accountants, the International Association of Boalt Hall Alumnis (IABA), the International Fiscal Association, Rotary, and the Board of CFO Club Austria.

Alexander Lang
	Deloitte Austria Renngasse 1/Freyung 1013 Vienna Austria Tel: +43 1 53700 6650 Fax: +43 1 53700 99 6650 Mobile: +43 664 80537 6650 Email: alang@deloitte.at Website: www.deloitte.at Alexander Lang, Deloitte Austria, joined the firm in 2003 and leads the tax litigation and fiscal penal law team. The team supports clients in all types of national and international disputes with tax authorities. In fiscal penal law matters the team defends clients' tax positions in tax audits and before Austria's Tax Court of Appeal and the Administrative Supreme Court (VwGH). Alexander is a certified public accountant (CPA) and a certified tax consultant. He is a certified fiscal penal law expert and lectures on tax litigation and criminal tax law at the law faculty of the University of Vienna. He studied law and business administration at the University of Vienna and the University of Economics. Alexander has published various articles in all leading Austrian legal magazines and publications.

Alexander Lang

Deloitte Austria

Renngasse 1/Freyung

1013 Vienna

Austria

Tel: +43 1 53700 6650

Fax: +43 1 53700 99 6650

Mobile: +43 664 80537 6650

Email: alang@deloitte.at

Website: www.deloitte.at

Alexander Lang, Deloitte Austria, joined the firm in 2003 and leads the tax litigation and fiscal penal law team. The team supports clients in all types of national and international disputes with tax authorities. In fiscal penal law matters the team defends clients' tax positions in tax audits and before Austria's Tax Court of Appeal and the Administrative Supreme Court (VwGH).

Alexander is a certified public accountant (CPA) and a certified tax consultant. He is a certified fiscal penal law expert and lectures on tax litigation and criminal tax law at the law faculty of the University of Vienna. He studied law and business administration at the University of Vienna and the University of Economics. Alexander has published various articles in all leading Austrian legal magazines and publications.

Robert Rzeszut
	Deloitte Austria Renngasse 1/Freyung 1010 Vienna Austria Tel: +43 1 53700 6620 Email: rrzeszut@deloitte.at Website: www.deloitte.at Robert Rzeszut, Deloitte Austria, is a tax adviser who specialises in procedural tax law. He has been with the firm since 2007. He works in the tax litigation team assisting international corporations, medium size businesses, and private clients. He also defends clients in fiscal criminal law procedures and prepares self-disclosures to help clients become retroactively compliant. Robert gained experience by defending his clients' tax position in tax audits and subsequently before Austria's Tax Court of Appeal and the Administrative Supreme Court (VwGH). Furthermore, Robert managed mutual agreement procedures involving several jurisdictions to avoid double taxation in close cooperation with other Deloitte member firms. Robert Rzeszut studied business and law at the Vienna University of Economics and at Wake Forest University, North Carolina, US. He also holds a procedural law degree from the Austrian Chamber of Tax Advisers.

Robert Rzeszut

Deloitte Austria

Renngasse 1/Freyung

1010 Vienna

Austria

Tel: +43 1 53700 6620

Email: rrzeszut@deloitte.at

Website: www.deloitte.at

Robert Rzeszut, Deloitte Austria, is a tax adviser who specialises in procedural tax law. He has been with the firm since 2007. He works in the tax litigation team assisting international corporations, medium size businesses, and private clients. He also defends clients in fiscal criminal law procedures and prepares self-disclosures to help clients become retroactively compliant.

Robert gained experience by defending his clients' tax position in tax audits and subsequently before Austria's Tax Court of Appeal and the Administrative Supreme Court (VwGH). Furthermore, Robert managed mutual agreement procedures involving several jurisdictions to avoid double taxation in close cooperation with other Deloitte member firms.

Robert Rzeszut studied business and law at the Vienna University of Economics and at Wake Forest University, North Carolina, US. He also holds a procedural law degree from the Austrian Chamber of Tax Advisers.