Germany

PricewaterhouseCoopers GmbH WPG

Friedrich-Ebert-Anlage 35-37

60327 Frankfurt am Main

Germany

Tel: +49 (0) 69 9585-3551

Email: ulf.andresen@pwc.com

Website: pwc.com/taxcontroversy

Dr Ulf Andresen is an international tax partner in PwC's Frankfurt transfer pricing team with 20 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.

Ulf has substantial experience in serving multinational groups of companies in complicated tax audits, appeals procedures in German tax courts and mutual agreement procedures. He has advised on a large number of APAs including in Denmark, Finland, France (2), Ireland, Japan (2), South Korea, UK (2), and the US (3). In the most recent APA, he managed to have the two tax authorities extend the APA period beyond the original five years to a total of 14 years, including a rollback into a pending tax audit, within only six months.

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 Friedrich-Alexander University in Erlangen-Nuremburg and at the Federal Tax Academy (Bundesfinanzakademie).

PricewaterhouseCoopers GmbH WPG

Kapelle-Ufer 4

10117 Berlin

Germany

Tel: +49 (0) 30 2636-5204

Email: lorenz.bernhardt@pwc.com

Website: pwc.com/taxcontroversy

Lorenz Bernhardt is a senior transfer pricing partner at PwC Berlin.

Lorenz has more than 20 years of experience in tax consulting, in particular in planning, implementation and defence of transfer pricing systems as well as in international tax structuring. He advises large international clients (both German and foreign headquartered) and has led many projects with a broad variety. He is also acting as central European transfer pricing adviser for a number of multinational corporations. Additionally, Lorenz lectures on transfer pricing and international tax at professional seminars and at renowned universities. He is regularly named as one of the top tier transfer pricing advisers in Germany.

Recent projects of Lorenz include:

• Advice 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.

Lorenz is also heading the transfer pricing practice of PwC Europe (comprising Austria, Belgium, Germany, the Netherlands and Turkey) as well as PwC's EMEA TP practice.

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 adviser and has been admitted as attorney-at-law both to the German Bar as well as to the New York Bar.

PricewaterhouseCoopers GmbH WPG

Moskauer Strasse 19

40227 Duesseldorf

Germany

Tel: +49 (0) 211 981-1144

Email: axel.eigelshoven@pwc.com

Website: pwc.com/taxcontroversy

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

Axel is working on a wide variety of transfer pricing projects including tax audits, intellectual property migration, tax effective supply chain management, permanent establishment issues, advance 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 is focused 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.

Axel holds a degree in business economics (Diplom-Kaufmann) from the University of Cologne. He is a certified tax adviser (Steuerberater) and is a member of the Tax Advisors Association and the International Fiscal Association.

PricewaterhouseCoopers GmbH WPG

Alsterufer 1

20354 Hamburg

Germany

Tel: +49 (0) 40 6378-1304

Email: kati.fiehler@pwc.com

Website: pwc.com/taxcontroversy

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.

Deloitte Germany

Schwannstr. 6

40476 Düsseldorf

Germany

Tel: +49 211 8772 3538

Fax: +49 211 8772 2277

Email: sgrube@deloitte.de

Website: www.deloitte.com

Stefan Grube, Deloitte Germany, joined Arthur Andersen in 1996 following his graduation in German tax administration (Dipl. Finanzwirt). In 2002, he started with Deloitte Germany in Düsseldorf, becoming the German business tax advisory leader in 2013. He is a member of Deloitte Germany's governance board and internal tax quality assurance board, the latter one dealing especially with difficult tax technical questions on specific and general tax topics.

He serves a wide range of different clients with a focus on large multinational inbound investors into Germany, especially US and UK headquartered multinationals with large German and European operations. Apart from regular client tax advice, he focuses on transaction-related tax advice such as M&A transactions, PMI restructurings, internal group restructurings, etc. with an international focus.

In this context, Stefan experienced the change of the approach by the German tax administration in tax audits by being generally more aggressive compared to past years. This requires a more focused, concentrated and organised approach on tax audits applied by Stefan. Besides tax technical defence and negotiations in tax audits in which Stefan is engaged, his experience covers tax litigation at different tax courts with a wide range of tax technical topics such as tax accounting, international tax, German participation exemption and German capital gain exemption. Furthermore, he is actively involved in managing competent authority and arbitration procedures.

His experience lets him develop a process and a training programme together with Norbert Endres, external negotiation experts and representatives from the tax administration on "how to professionally manage a tax audit". The training course was released in 2016 and deals with the structured negotiation process in tax audits based on the Harvard Concept. It was further developed by Norbert Endres and in 2017 successfully offered to Deloitte Germany's premium clients to optimise their controversy process and improve the outcome of their tax audits.

Stefan is a certified tax adviser (Steuerberater).

Deloitte Germany

Kurfürstendamm 23

10719 Berlin

Germany

Tel: +49 (0)30 25468 258

Fax: +49 (0)30 25468 213

Email: ugruenwald@deloitte.de

Website: www.deloitte.com

Ulrich Grünwald, Deloitte Germany, has been a partner in the indirect tax service team in the Berlin office in 2015. Ulrich has more than 23 years of professional experience in the field of taxes with a strong focus on indirect taxation. Ulrich started his professional career as the head of a VAT audit department with the German tax authorities. He continued his career as head of the VAT service team, as well as the international VAT centre of excellence of a global audit network for more than 10 years when he joined a well-known tax focused German law firm as a partner specialising in indirect taxes.

Ulrich has extensive practical experience in advising domestic and multinational clients. He focuses on German and European VAT law, as well as in insurance premium tax law. His professional experience includes VAT, insurance premium tax, other indirect taxes and procedural law. He has developed a broad working experience and serves clients in a wide variety of industries including the service sector, the manufacturing and consumer industries.

He is a regular speaker at public tax events and a frequent publisher on VAT and other indirect tax issues.

Ulrich received his JD in European VAT law at Erlangen/Nürnberg University. He is a certified tax adviser and a lawyer.

PricewaterhouseCoopers GmbH WPG

Bernhard-Wicki-Str. 8

80636 Munich

Germany

Tel: +49 (0) 89 5790-5424

Email: joerg.hanken@pwc.com

Website: pwc.com/taxcontroversy

Jörg Hanken is a transfer pricing partner in Munich and the global TP technology solutions leader. He has performed and managed numerous projects such as analysing, planning, implementing, documenting and defending transfer pricing structures for more than 15 years. The recent projects mainly refer to dispute resolution, value chain transformation and holistic TP implementation including the use of software technology.

Some of his recent MAP/APA projects comprise of 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). He concluded the first bilateral APA regarding 'extraction royalty concepts' (automotive, Poland) and he applied a similar APA with Romania (automotive). Joerg negotiated some MAPs, recently regarding distribution and repair services (aerospace industry, France).

Jörg gained experiences as an adviser, as well as a head of tax Central Europe, for a US multinational. He frequently performs national, as well as international, transfer pricing workshops and seminars and he is the author of a leading German publication on transfer pricing from a tax and controlling perspective, Verrechnungspreise im Spannungsfeld von Controlling und Steuern.

Jörg is a German certified tax adviser and a certified valuation analyst.

PricewaterhouseCoopers GmbH WPG

Moskauer Strasse 19

40227 Duesseldorf

Germany

Tel: +49 (0) 211 981-1966

Email: heinz-klaus.kroppen@pwc.com

Website: pwc.com/taxcontroversy

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 and in Germany. He is a member of the PwC German tax and 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).

PricewaterhouseCoopers GmbH WPG

Friedrich-List-Str. 20

45128 Essen

Germany

Tel: +49 (0) 211 981-5201

Email: claudia.lauten@pwc.com

Website: pwc.com/taxcontroversy

Claudia Lauten is a transfer pricing partner at PwC Duesseldorf and Essen, Germany.

Claudia has more than 20 years of comprehensive experience in tax consulting, and more than 15 years in the area of transfer pricing.

Her expertise lies in the execution of global documentation projects as well as the optimisation of value chains in consideration of principal structures. She also has extensive experience in merger and acquisition projects (due diligence, post-merger structuring), monitoring audits by fiscal authorities and negotiating transfer pricing structures with competent authorities, including advance pricing agreement procedures. Claudia's clients comprise large multinationals, both headquartered in Germany or abroad.

Claudia is heading the German TP dispute resolution practice, focusing on avoidance of disputes, tax audit defence work, litigation and competent authority procedures. She has excellent working relationships with various representatives from the German competent authority. In addition, 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.

She publishes articles on dispute resolution issues and is a frequent speaker on the topic.

Deloitte Germany

Kurfuerstendamm 23 Neues Kranzler Eck

Berlin, 10719

Germany

Tel: +49 30 2546 8116

Email: mmassbaum@deloitte.de

Website: www.deloitte.com

Michael Massbaum, Deloitte Germany, is a tax partner in the tax and legal practice and has more than 26 years of experience serving national and multinational clients. He is a member of Deloitte Germany's governance board, tax and legal management team and experienced in tax structuring and tax controversy work. Michael has broad experience in serving a wide range of clients with different legal structures including the specialties of cross-border partnerships. This does not only cover technical defence and negotiations in tax audits but also includes tax litigations at local fiscal courts and the Federal Fiscal Court. Michael is part of a team around Norbert Endres specialised in professionally managing tax audits based on special soft skills considering the Harvard Concept.

Michael has wide industry expertise in manufacturing, energy, resources and real estate.

Michael is a lawyer and a member of the Berlin Bar. He is also a licensed tax adviser. Michael is a member of the International Fiscal Association, German Tax Law Society (Deutsche Steuerjuristische Gesellschaft) and Verein Berliner Kaufleute und Industrieller.

Michael is the author of several articles on national and international tax law. He is co-author of the DBA-Kommentar, a leading publication on double tax treaties, and of the Hermann Heuer Raupach, Einkommensteuer und Körperschaftsteuer, a leading publication on income and corporate tax. Furthermore, he is a regular lecturer for corporate and international tax law.

Michael studied at the University of Osnabrück. He wrote a dissertation on international tax law for which he was awarded his PhD in law.

Deloitte Germany

Kurfuerstendamm 23

10719 Berlin

Germany

Tel: +49 30 25468-5979, +49 151 58071648

Fax: +49 30 25468-136

Email: cneuling@deloitte.de

Website: www2.deloitte.com/dl/de/services/legal.html

Dr C Alexander Neuling, Deloitte Germany, joined the firm in October 2016. He is a partner at Deloitte Legal in Berlin. He is a member of Deloitte's global tax and legal controversy team.

Alex advises countrywide, representing and defending corporate clients (corporations, corporate executives) of numerous industries as well as private clients on all aspects of procedural tax law, tax disputes (tax audits, administrative appeals, trial and appellate tax court litigation) and criminal defence matters (preventive tax fraud advice, corporate and individual disclosures, criminal investigations, trial and appellate criminal court litigation). He also cooperates closely with Deloitte tax service lines, especially transfer pricing, indirect tax, business tax advisory, private company services, global employer services (in- and ex-patriate taxation of multinational corporations' employees) and M&A tax.

For 12 years Alex has exclusively focused his experience in procedural tax law advice, tax dispute representation and criminal defence. He successfully advised and represented corporate clients of several industries in critical tax field audits, administrative appeals and tax court litigation obtaining victorious verdicts or favourable settlements. He successfully advised corporate executives of several industries as well as private individuals on disclosures obtaining exemption from criminal punishment or successfully defended them in criminal proceedings alleging tax fraud obtaining pre-trial abandonment of charges or acquittal.

Alex is a certified tax attorney, certified tax adviser and attorney-at-law. He is a lecturer at University Bremen (tax criminal law). He was a lecturer in seminars preparing candidates for the German tax adviser bar exam (procedural tax law, tax court litigation, tax criminal law, 2011-15). He is a member of the procedural tax law expert network to the CDU parliamentary group within the German Parliament's finance committee.

Deloitte Germany

Schwannstraße 6

40476 Düsseldorf

Germany

Tel: +49 211 8772 2235

Fax: +49 151 5800 3880

Email: mpuls@deloitte.de

Website: www.deloitte.com

Dr Michael Puls, Deloitte Germany, is a tax partner in the Duesseldorf office leading the transfer pricing service line there. He has more than 15 years of relevant professional experience in the area of transfer pricing and international tax.

Michael specialises in advising multinational enterprises in all transfer pricing questions, being experienced in managing global documentation projects, relocating of functions, supporting clients with government tax audits, mutual agreements and arbitral procedures, as well as in terms of tax planning projects including advance pricing agreements (APAs).

Michael is the author of various publications in national and international tax law and transfer pricing. For example, he is the co-author of the Wassermeyer/Baumhoff handbook of transfer pricing, a leading publication on transfer pricing in Germany. Michael is a frequent speaker at transfer pricing and international tax expert seminars. Moreover, he is a lecturer at the University of Augsburg, faculty of economics, in international tax law.

He is a lawyer and certified tax adviser.

Deloitte Germany

Aegidientorplatz 2a

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hramcke@deloitte.de

Website: www.deloitte.com

Heiko Ramcke, Deloitte Germany, is a partner and the leader of the criminal tax law team. Heiko joined Deloitte in 2001 and has many years of experience in criminal tax law.

With his team, Heiko defends clients in criminal tax proceedings and prepares self-disclosures to gain impunity for the clients. He also advises clients in preliminary investigations. Heiko serves multinational enterprises, as well as the management of national medium-sized businesses and individuals.

Heiko is also specialised in procedural tax law and advises clients in all types of national disputes with tax authorities. Throughout his career, Heiko has represented businesses and individuals in all stages of litigation proceedings and has assisted many companies to litigate tax issues before the German tax authorities and the finance courts.

Heiko is an attorney-at-law and studied law at the University of Kiel.

PricewaterhouseCoopers GmbH WPG

Bernhard-Wicki-Str. 8

80636 Munich

Germany

Tel: +49 (0) 89 5790-5378

Email: stephan.rasch@pwc.com

Website: pwc.com/taxcontroversy

Prof Dr Stephan Rasch is a transfer pricing partner in PwC's Munich office. He has 17 years of experience in international taxation and transfer pricing. Before joining PwC in December 2013, Stephan worked with another Big 4 firm as transfer pricing partner. Stephan advises clients in tax matters associated with cross-border transactions, including permanent establishment issues and value chain transformations. Stephan's clients include German-based DAX companies and European and US multinationals.

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 reorganisations. Stephan's experience with mutual agreement procedures include bilateral and multilateral cases as well as the negotiation of bi- and multilateral advance pricing agreements. Finally, he is involved in tax court litigation relating to transfer pricing cases. He was appointed as German national reporter on Subject 1 'Dispute Resolution' for the 70th International Fiscal Association (IFA) Congress in Madrid in 2016.

Stephan lectures on international and European tax law at the University of Augsburg since 2007 and is a frequent speaker on transfer pricing at national and international seminars. He has published a volume on transfer pricing legislation in international German, bilateral and European tax law. He is co-editor and author of one of the leading transfer pricing publications in Germany, Handbuch Internationale Verrechnungspreise, and co-author of a leading commentary on double tax treaties. He is also editor of the Internationale Steuer-Rundschau (ISR), a German international tax journal. Stephan is professor of international tax law at the University of Augsburg and is a frequent speaker on transfer pricing at national and international seminars.

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

PricewaterhouseCoopers GmbH WPG

Friedrichstrasse 14

70174 Stuttgart

Germany

Tel: +49 (0) 711 25034-3107

Email: martin.renz@pwc.com

Website: pwc.com/taxcontroversy

Martin Renz is a transfer pricing partner in PwC's Stuttgart office. He has 20 years of experience in international taxation and transfer pricing and leading the transfer pricing group at PwC in Stuttgart.

Martin has significant experience with the approach of German and foreign tax authorities towards transfer pricing and has been involved in several transfer pricing projects including dispute resolution, carrying out value chain transfer pricing studies, implementation of entrepreneur structures, licensing structures and tax consulting within advance pricing agreement (APA) procedures (including the first APA between Germany and Switzerland). He has led many projects for multinationals to set up global transfer pricing structures including the BRIC countries. His clients involve mainly large multinationals and mid-size companies. Martin is focused on the automotive, engineering and healthcare industry.

Martin is a frequent speaker on transfer pricing seminars. He is co-publisher and author of Renz/Wilmanns Internationale Verrechnungspreise – Handbuch für Praktiker, co-author of Bernhardt, Verrechnungspreise and contributing author of the transfer pricing chapter in Beck's Handbuch der AG. Moreover, he has published numerous articles in tax journals.

Martin holds a German MBA (Diplom-Kaufmann) and practices as a certified tax adviser (Steuerberater).

Deloitte Germany

Rosenheimer Platz 6

81669 Munich

Germany

Tel: +49 (0)89 290368916

Fax: +49 (0)89 290368911

Email: alschemmel@deloitte.de

Website: www.deloittelegal.de

Alexander Schemmel, Deloitte Germany, is a partner and joined the firm in 2015.

At Deloitte Legal he is responsible for the white collar crime prevention and investigations service line and his core areas are corporate defence and corporate compliance.

With his team, Alexander defends national and international companies as well as individuals in all areas of white collar and tax criminal law. He has extensive experience conducting internal investigations and in the field of public, regulatory and corporate compliance. Alexander has defended several officers of DAX companies and has advised major corporations in large scale tax investigations.

Chambers Europe and Best Lawyers ranked Alexander as one of the best consultants in the area of white collar crime in the past.

Alexander has been an attorney-at-law since 2001. He studied law at the University of Passau.

Deloitte Germany

Aegidientorplatz 2A

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hstang@deloitte.de

Website: www.deloittelegal.de

Dr Harald Stang, Deloitte Germany, is an attorney-at-law, tax consultant and partner. He joined the firm in 1998 and was appointed equity partner in 2002.

Harald has 19 years' experience in advising different clients in M&A transactions as well as in all respects of corporate law, in particular corporate restructurings. He also focuses on advising the shareholders of family owned companies in connection with the law of succession.

Harald is also specialised in procedural tax law and advises clients in all types of national disputes with tax authorities. Throughout his career, Harald has represented businesses and individuals in all stages of litigation proceedings and has assisted many companies to litigate tax issues before the German tax authorities and the finance courts.

Harald has studied law and economics at the University of Göttingen. He previously worked as an assistant auditor with a medium size firm of auditors and tax consultants.

PricewaterhouseCoopers GmbH WPG

Moskauer Strasse 19

40227 Duesseldorf

Germany

Tel: +49 (0) 211 981-7451

Email: susann.van.der.ham@pwc.com

Website: pwc.com/taxcontroversy

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).

NERA Economic Consulting

Messeturm

60308 Frankfurt

Germany

Tel: +49 69 710 447 501

Fax: +49 69 710 447 550

Email: alexander.voegele@nera.com

Website: www.nera.com

During more than 35 years of advising international corporations and leading law firms, Alexander Voegele has specialised in the defence of major international transfer pricing and IP cases. He has developed innovative economic structures for transfer pricing strategies which have become the industry standard. He has led hundreds of large transfer pricing and intellectual property projects and defence cases for clients in a wide range of industries all over the world. In recent years, he has defended transfer pricing audits and litigation in North America, Scandinavia, Eastern Europe, and Germany.

In recent years, Alexander and his colleagues Philip de Homont and Tom Braukmann have established new standards for the separation and quantification of IP, financial instruments, and contractual clauses. They have advanced discussion within the industry by frequently explaining their methods at conferences and in publications. Using economic reasoning, they lead arbitrations and testify as expert witnesses in court. Their insights have helped shape transfer pricing and audit standards in Germany and Austria, and they regularly exchange views with tax inspectors at conferences and seminars. In negotiations, they find well-structured and understandable arguments that are convincing and relatable.

Alexander regularly publishes articles and books on transfer pricing and international tax planning, and is the author and editor of the two leading German commentaries on IP, transfer pricing, and economic consulting: Transfer Pricing and Intellectual Property. His publications have anticipated many aspects of the recent base erosion and profit shifting (BEPS) discussions, such as the use of profit split methods or the analysis and quantification of risk. He has spoken at more than 250 conferences and seminars on transfer pricing and IP in Europe, the US, and Asia.

Alexander holds a PhD in economics and a MSc in tax and business administration from the University of Mannheim.