Netherlands

August 16, 2017

Frits Barnard
	Deloitte Netherlands Gustav Mahlerlaan 2970 NL-1081 LA Amsterdam The Netherlands Tel: +31 (0)88 2886857 Fax: +31 (0)88 2889758 Email: fbarnard@deloitte.com Website: www.deloitte.com Frits Barnard, Deloitte Netherlands, is an international tax partner in the Amsterdam office. He specialises in international corporate tax, controversy and tax litigation. Frits became a partner with a Big 4 firm in 1993 and Deloitte in 2002. Frits has been responsible for providing tax advice mainly to Dutch, UK, and US multinationals. Frits has substantial experience in handling tax audits, conducting negotiations with Dutch revenue authorities, and tax litigation. In the latter capacity he has handled a number of benchmark Supreme Court cases. He has also negotiated/renegotiated a number of rulings for large multinationals on their Dutch tax base, for example on the allocation of income on the basis of informal capital concepts. He now acts as a trouble-shooter in a variety of situations where clients of Deloitte Netherlands need assistance with dispute resolution. Experience teaches that addressing a dispute often leads to opportunities to improve the tax position. He is now trying to get a grip on where legally acceptable planning turns into undesired tax evasion, clearly a topic that will keep tax professionals busy in the coming years. He is a graduate of Leiden University (1983) and holds a master's degree in tax law.

Frits Barnard

Deloitte Netherlands

Gustav Mahlerlaan 2970

NL-1081 LA Amsterdam

The Netherlands

Tel: +31 (0)88 2886857

Fax: +31 (0)88 2889758

Email: fbarnard@deloitte.com

Website: www.deloitte.com

Frits Barnard, Deloitte Netherlands, is an international tax partner in the Amsterdam office. He specialises in international corporate tax, controversy and tax litigation. Frits became a partner with a Big 4 firm in 1993 and Deloitte in 2002. Frits has been responsible for providing tax advice mainly to Dutch, UK, and US multinationals.

Frits has substantial experience in handling tax audits, conducting negotiations with Dutch revenue authorities, and tax litigation. In the latter capacity he has handled a number of benchmark Supreme Court cases. He has also negotiated/renegotiated a number of rulings for large multinationals on their Dutch tax base, for example on the allocation of income on the basis of informal capital concepts.

He now acts as a trouble-shooter in a variety of situations where clients of Deloitte Netherlands need assistance with dispute resolution. Experience teaches that addressing a dispute often leads to opportunities to improve the tax position.

He is now trying to get a grip on where legally acceptable planning turns into undesired tax evasion, clearly a topic that will keep tax professionals busy in the coming years.

He is a graduate of Leiden University (1983) and holds a master's degree in tax law.

Johan Hollebeek
	Deloitte Netherlands Gustav Mahlerlaan 2970 NL-1081 LA Amsterdam Netherlands Tel: +31 88 288 1992 Mobile: +31 6 5151 6811 Email: jhollebeek@deloitte.nl Website: www.deloitte.com/nl Johan Hollebeek, Deloitte Netherlands, is a tax partner with the customs and global trade service line. He has been with Deloitte Netherlands since 2002. Before joining Deloitte, Johan was with Arthur Andersen for four years. Johan specialises in customs duties, VAT, and excise duties. Johan's practices focus on customs valuation, tariff classification matters and processing regimes. Johan uses mediation techniques to resolve disputes at an early stage but also has extensive experience in litigation before Dutch and EU courts on customs duties, VAT, and excise duty related matters. He is also a member of the customs working group of VNO-NCW (the Confederation of Netherlands Industry and Employers). Johan is a permanent contributor to the journal Douanerechtspraak (customs jurisprudence). Johan is a graduate of Leiden University (indirect taxation) and also completed a post-graduate course in appropriate dispute resolution at the Amsterdam ADR Institute.

Johan Hollebeek

Deloitte Netherlands

Gustav Mahlerlaan 2970

NL-1081 LA Amsterdam

Netherlands

Tel: +31 88 288 1992

Mobile: +31 6 5151 6811

Email: jhollebeek@deloitte.nl

Website: www.deloitte.com/nl

Johan Hollebeek, Deloitte Netherlands, is a tax partner with the customs and global trade service line. He has been with Deloitte Netherlands since 2002. Before joining Deloitte, Johan was with Arthur Andersen for four years. Johan specialises in customs duties, VAT, and excise duties.

Johan's practices focus on customs valuation, tariff classification matters and processing regimes. Johan uses mediation techniques to resolve disputes at an early stage but also has extensive experience in litigation before Dutch and EU courts on customs duties, VAT, and excise duty related matters. He is also a member of the customs working group of VNO-NCW (the Confederation of Netherlands Industry and Employers). Johan is a permanent contributor to the journal Douanerechtspraak (customs jurisprudence). Johan is a graduate of Leiden University (indirect taxation) and also completed a post-graduate course in appropriate dispute resolution at the Amsterdam ADR Institute.

Pascal Schrijver
	Deloitte Netherlands Gustav Mahlerlaan 2970 1081 LA Amsterdam Netherlands Tel: +31 88 288 4614 Fax: +31 88 288 9763 Email: pschrijver@deloitte.nl Website: www.deloitte.com Pascal Schrijver, Deloitte Netherlands, is a partner in the indirect tax department of the Amsterdam office. Pascal serves both international and national clients. He advises on the indirect tax aspects of all kinds of business flows, compliance issues as well as mergers and acquisitions all in the technology, media and telecommunications industries. Over the past 19 years he has been involved in many (inter)national business transactions and restructuring projects for, among others, operators, telecom equipment manufacturers, software developer/publishers and other content providers and e-commerce businesses. Pascal holds a degree in tax law from the University Groningen and is a board member of the indirect tax department of the Dutch Association of Tax Lawyers. Pascal also lecturers on VAT at University of Leiden, the Netherlands.

Pascal Schrijver

Deloitte Netherlands

Gustav Mahlerlaan 2970

1081 LA Amsterdam

Netherlands

Tel: +31 88 288 4614

Fax: +31 88 288 9763

Email: pschrijver@deloitte.nl

Website: www.deloitte.com

Pascal Schrijver, Deloitte Netherlands, is a partner in the indirect tax department of the Amsterdam office. Pascal serves both international and national clients. He advises on the indirect tax aspects of all kinds of business flows, compliance issues as well as mergers and acquisitions all in the technology, media and telecommunications industries. Over the past 19 years he has been involved in many (inter)national business transactions and restructuring projects for, among others, operators, telecom equipment manufacturers, software developer/publishers and other content providers and e-commerce businesses. Pascal holds a degree in tax law from the University Groningen and is a board member of the indirect tax department of the Dutch Association of Tax Lawyers. Pascal also lecturers on VAT at University of Leiden, the Netherlands.

Stef van Weeghel
	PwC Thomas R Malthusstraat 5 1066 JR Amsterdam The Netherlands Tel: +31 88 792 6763 Email: stef.van.weeghel@pwc.com Website: www.pwc.nl Stef van Weeghel is tax partner and global tax policy leader at PwC. He is also professor of international tax law at the Amsterdam Centre for Tax Law at the University of Amsterdam. Stef's primary focus is on tax policy, strategic tax advice and tax controversy. He has been involved in large cross-border transactions, structuring and tax controversy/litigation. He regularly renders advice and second opinions to clients and to other advisers on corporate income tax and tax treaty matters and is also consulted by the Dutch government on a regular basis. On several occasions he has acted as expert witness in tax matters before Dutch and foreign courts and in investment treaty arbitration. Stef graduated from the University of Leiden in business law (1983) and tax law (1987) and obtained an LLM in taxation from New York University (1990). In 1997, he received a doctorate in law from the University of Amsterdam (PhD thesis: Improper Use of Tax Treaties); in 2000 he was appointed a tenured professor of international tax law at that same university. He has authored and co-authored several books and many articles on Dutch and international taxation. He has lectured extensively in the Netherlands and internationally. Before joining PwC, Stef was a partner at Linklaters (2007-2009) and a partner at Stibbe (1992-2007) where his roles included membership of the executive committee, head of tax and resident partner in the New York office. He is chair of the permanent scientific committee of the International Fiscal Association (IFA) and former chair of the Dutch branch of IFA. He is also chair of the board of trustees of the International Bureau for Fiscal Documentation. In 2010, he was the general reporter for Subject 1 (tax treaties and tax avoidance: application of anti-avoidance provisions) at the IFA Congress in Rome. In 2009/2010 Stef chaired the study group tax system, a committee that advised the Dutch government on comprehensive tax reform. In 2000, he was a member of the Van Rooy-committee that advised the Dutch government on corporate income tax reform.

Stef van Weeghel

PwC

Thomas R Malthusstraat 5

1066 JR Amsterdam

The Netherlands

Tel: +31 88 792 6763

Email: stef.van.weeghel@pwc.com

Website: www.pwc.nl

Stef van Weeghel is tax partner and global tax policy leader at PwC. He is also professor of international tax law at the Amsterdam Centre for Tax Law at the University of Amsterdam.

Stef's primary focus is on tax policy, strategic tax advice and tax controversy. He has been involved in large cross-border transactions, structuring and tax controversy/litigation. He regularly renders advice and second opinions to clients and to other advisers on corporate income tax and tax treaty matters and is also consulted by the Dutch government on a regular basis. On several occasions he has acted as expert witness in tax matters before Dutch and foreign courts and in investment treaty arbitration.

Stef graduated from the University of Leiden in business law (1983) and tax law (1987) and obtained an LLM in taxation from New York University (1990). In 1997, he received a doctorate in law from the University of Amsterdam (PhD thesis: Improper Use of Tax Treaties); in 2000 he was appointed a tenured professor of international tax law at that same university. He has authored and co-authored several books and many articles on Dutch and international taxation. He has lectured extensively in the Netherlands and internationally.

Before joining PwC, Stef was a partner at Linklaters (2007-2009) and a partner at Stibbe (1992-2007) where his roles included membership of the executive committee, head of tax and resident partner in the New York office. He is chair of the permanent scientific committee of the International Fiscal Association (IFA) and former chair of the Dutch branch of IFA. He is also chair of the board of trustees of the International Bureau for Fiscal Documentation. In 2010, he was the general reporter for Subject 1 (tax treaties and tax avoidance: application of anti-avoidance provisions) at the IFA Congress in Rome.

In 2009/2010 Stef chaired the study group tax system, a committee that advised the Dutch government on comprehensive tax reform. In 2000, he was a member of the Van Rooy-committee that advised the Dutch government on corporate income tax reform.

Edwin Visser
	PwC Netherlands Thomas R Malthusstraat 5 1066 JR, PO Box 90351 1006 BJ, Amsterdam Netherlands Tel: +31 (0) 88 792 6577 Email: edwin.visser@pwc.com Website: pwc.com/taxcontroversy Edwin Visser has been a tax partner at PwC in the Netherlands since January 1 2015. He is the tax policy leader for the EMEA, a member of the global tax policy core team, leader of PwC's tax controversy and dispute resolution network for the Netherlands and the EMEA region, and member of the global leadership team of PwC's tax controversy and dispute resolution (TCDR) network. Edwin's practice includes boardroom consulting, strategic tax advice, tax controversy, tax administration consulting and representing PwC in tax policy matters. Edwin is co-leading a global PwC team of around 20 former competent authorities and other specialists in mutual agreement procedures. Edwin graduated from Tilburg University in 1995. He is a member of the editorial board of a renowned tax encyclopaedia in the Netherlands, author of a handbook on transfer pricing (published in 2005), co-author of the Netherlands report to the IFA in 2007 on the treatment of intangibles. He has a broad experience in teaching (LLM in international taxation at Leiden University, IBFD and the tax assurance academy at Nyenrode Business University). Before joining PwC, he was deputy director-general for tax and customs policy and legislation and director for direct taxes at the Dutch Ministry of Finance. He represented the Netherlands in the bureau of the OECD's committee on fiscal affairs from 2012 through to 2014 and he co-chaired the OECD informal task force on tax and development (2010-14). Edwin was director for international tax policy and legislation from January 1 2009 to March 1 2012. In that capacity he also acted as competent authority. From 2004 to 2008 he was responsible for the co-ordinated treatment of the 2,000 largest companies in the Netherlands by the Netherlands' Tax and Customs Administration (NTCA). The main challenge was the implementation of the co-operative compliance approach. From 2000 to 2004 he was head of the transfer pricing division of the Dutch tax administration and in that capacity he was involved in many mutual agreement procedures.

Edwin Visser

PwC Netherlands

Thomas R Malthusstraat 5

1066 JR, PO Box 90351

1006 BJ, Amsterdam

Netherlands

Tel: +31 (0) 88 792 6577

Email: edwin.visser@pwc.com

Website: pwc.com/taxcontroversy

Edwin Visser has been a tax partner at PwC in the Netherlands since January 1 2015. He is the tax policy leader for the EMEA, a member of the global tax policy core team, leader of PwC's tax controversy and dispute resolution network for the Netherlands and the EMEA region, and member of the global leadership team of PwC's tax controversy and dispute resolution (TCDR) network.

Edwin's practice includes boardroom consulting, strategic tax advice, tax controversy, tax administration consulting and representing PwC in tax policy matters. Edwin is co-leading a global PwC team of around 20 former competent authorities and other specialists in mutual agreement procedures.

Edwin graduated from Tilburg University in 1995. He is a member of the editorial board of a renowned tax encyclopaedia in the Netherlands, author of a handbook on transfer pricing (published in 2005), co-author of the Netherlands report to the IFA in 2007 on the treatment of intangibles. He has a broad experience in teaching (LLM in international taxation at Leiden University, IBFD and the tax assurance academy at Nyenrode Business University).

Before joining PwC, he was deputy director-general for tax and customs policy and legislation and director for direct taxes at the Dutch Ministry of Finance. He represented the Netherlands in the bureau of the OECD's committee on fiscal affairs from 2012 through to 2014 and he co-chaired the OECD informal task force on tax and development (2010-14).

Edwin was director for international tax policy and legislation from January 1 2009 to March 1 2012. In that capacity he also acted as competent authority. From 2004 to 2008 he was responsible for the co-ordinated treatment of the 2,000 largest companies in the Netherlands by the Netherlands' Tax and Customs Administration (NTCA). The main challenge was the implementation of the co-operative compliance approach. From 2000 to 2004 he was head of the transfer pricing division of the Dutch tax administration and in that capacity he was involved in many mutual agreement procedures.

Eric Vroemen
	PwC Fascinatio Boulevard 350 3065 WB, Postbus 8800 3009 AV Rotterdam Netherlands Tel: + 31 (0) 88 79 25 038 Mobile: + 31 (0) 6 13 48 12 42 Email: eric.vroemen@nl.pwc.com Website: pwc.com/taxcontroversy Eric Vroemen is a partner in PwC's Dutch tax and human resource services (HRS) practice with more than 20 years of relevant experience. He is specialised in transfer pricing. From 1989 until 1996, Eric worked with the Dutch tax authorities as a state auditor and between 1996 and 2010, he worked with Deloitte in the Netherlands. In 2001, he was seconded to New York, and from 2003 until 2006 he was located in Chicago as the managing partner of Deloite's Dutch desks. He moved to PwC in November 2010. Since 1999, Eric has focused on transfer pricing and business restructurings, and was involved in planning and controversy management for a large number of well-known and complex multinationals. As such, Eric has obtained an in-depth understanding of business operations in a wide variety of industries as well as being familiar with the tax systems and the methods of working of the tax administrations and competent authorities in the main economies. Eric is a frequent speaker on transfer pricing and a guest lecturer at the Leiden University, the IBFD and the PwC Tax Academy.

Eric Vroemen

PwC

Fascinatio Boulevard 350

3065 WB, Postbus 8800

3009 AV Rotterdam

Netherlands

Tel: + 31 (0) 88 79 25 038

Mobile: + 31 (0) 6 13 48 12 42

Email: eric.vroemen@nl.pwc.com

Website: pwc.com/taxcontroversy

Eric Vroemen is a partner in PwC's Dutch tax and human resource services (HRS) practice with more than 20 years of relevant experience. He is specialised in transfer pricing.

From 1989 until 1996, Eric worked with the Dutch tax authorities as a state auditor and between 1996 and 2010, he worked with Deloitte in the Netherlands. In 2001, he was seconded to New York, and from 2003 until 2006 he was located in Chicago as the managing partner of Deloite's Dutch desks. He moved to PwC in November 2010. Since 1999, Eric has focused on transfer pricing and business restructurings, and was involved in planning and controversy management for a large number of well-known and complex multinationals. As such, Eric has obtained an in-depth understanding of business operations in a wide variety of industries as well as being familiar with the tax systems and the methods of working of the tax administrations and competent authorities in the main economies.

Eric is a frequent speaker on transfer pricing and a guest lecturer at the Leiden University, the IBFD and the PwC Tax Academy.