Switzerland

August 16, 2017

Peter Brülisauer
	Deloitte Switzerland General-Guisan-Quai 38 8022 Zürich Switzerland Tel: +41 58 279 7290 Fax: +41 58 279 6600 Email: pbruelisauer@deloitte.ch Website: www.deloitte.com Peter Brülisauer, Deloitte Switzerland, has extensive experience in providing tax advisory services to multinational enterprises. His tax experience comprises corporate restructuring, acquisition, finance restructuring, intellectual property and research and development planning, international cross-border tax planning, tax effective supply chain management as well as function and risk allocation within multinational groups. In addition, he advises on permanent establishment (PE) planning and profit attribution between PEs. Peter is a lecturer for international taxation and transfer pricing at the University of St. Gallen and a frequent speaker at tax conferences. He writes commentaries on national and international corporate taxation, particularly on determination and profit allocation of corporations and PEs. Peter has strong and extensive contact with the federal tax authorities, the cantonal tax authorities and State Secretariat for International Financial Matters (SIF). He is member of the working group for corporate tax reform III and of the SIF BEPS group. Peter has a PhD in law from the University of St. Gallen and is a Swiss certified tax expert.

Peter Brülisauer

Deloitte Switzerland

General-Guisan-Quai 38

8022 Zürich

Switzerland

Tel: +41 58 279 7290

Fax: +41 58 279 6600

Email: pbruelisauer@deloitte.ch

Website: www.deloitte.com

Peter Brülisauer, Deloitte Switzerland, has extensive experience in providing tax advisory services to multinational enterprises. His tax experience comprises corporate restructuring, acquisition, finance restructuring, intellectual property and research and development planning, international cross-border tax planning, tax effective supply chain management as well as function and risk allocation within multinational groups. In addition, he advises on permanent establishment (PE) planning and profit attribution between PEs.

Peter is a lecturer for international taxation and transfer pricing at the University of St. Gallen and a frequent speaker at tax conferences. He writes commentaries on national and international corporate taxation, particularly on determination and profit allocation of corporations and PEs.

Peter has strong and extensive contact with the federal tax authorities, the cantonal tax authorities and State Secretariat for International Financial Matters (SIF). He is member of the working group for corporate tax reform III and of the SIF BEPS group.

Peter has a PhD in law from the University of St. Gallen and is a Swiss certified tax expert.

Sarah Dahinden
	PwC Birchstrasse 160 CH – 8050 Zürich Switzerland Tel: +41 58 792 44 25 Email: sarah.dahinden@ch.pwc.com Website: pwc.com/taxcontroversy Sarah Dahinden is a senior manager at PwC in Switzerland's tax services practice. As a lawyer, she regularly and successfully assists clients in tax litigation cases. After passing the law and the attorney-at-law degree, Sarah wrote her thesis in international tax law, concerning tax sheltering of foreign companies. Subsequently, she passed the exam for certified tax experts. Before joining PwC in 2007, Sarah worked at a district court, at the University of Zurich (dealing with tax law), at two of the bigger law firms in Zurich and in the legal department of the tax authority of the canton of Zurich. Sarah renders services in different tax fields, usually with a clear focus on legal procedures and tax litigation in the corporate tax field. Sarah is a member of the International Fiscal Association (IFA). She is fluent in English.

Sarah Dahinden

PwC

Birchstrasse 160

CH – 8050 Zürich

Switzerland

Tel: +41 58 792 44 25

Email: sarah.dahinden@ch.pwc.com

Website: pwc.com/taxcontroversy

Sarah Dahinden is a senior manager at PwC in Switzerland's tax services practice. As a lawyer, she regularly and successfully assists clients in tax litigation cases.

After passing the law and the attorney-at-law degree, Sarah wrote her thesis in international tax law, concerning tax sheltering of foreign companies. Subsequently, she passed the exam for certified tax experts.

Before joining PwC in 2007, Sarah worked at a district court, at the University of Zurich (dealing with tax law), at two of the bigger law firms in Zurich and in the legal department of the tax authority of the canton of Zurich.

Sarah renders services in different tax fields, usually with a clear focus on legal procedures and tax litigation in the corporate tax field. Sarah is a member of the International Fiscal Association (IFA). She is fluent in English.

Jean-Blaise Eckert
	Lenz & Staehelin Route de Chêne 30 CH-1211 Geneva 17 Switzerland Tel: +41 58 450 70 00 Fax: +41 58 450 70 01 Email: jean-blaise.eckert@lenzstaehelin.com Website: www.lenzstaehelin.com Jean-Blaise Eckert is a partner at Lenz & Staehelin and co-head of the tax group. His practice areas include tax, private clients, contract law and commercial. He speaks French, English and German. Jean-Blaise studied law at the University of Neuchâtel and was admitted to the Bar of Neuchâtel in 1989 and to the Bar of Geneva in 1991. He studied business administration at Berkeley, Haas Business School, where he acquired an MBA in 1991. He received his diploma as a certified tax expert in 1994 and is a certified specialist in inheritance law. Jean-Blaise is considered as a leading lawyer in Switzerland. He advises a number of multinational groups of companies as well as high-net-worth individuals. He sits on the board of a number of public and private companies. He has been nominated by Chambers in 2017 as a leading individual in tax. Jean-Blaise is a frequent speaker at professional conferences on tax matters. Jean-Blaise is general secretary of the International Fiscal Association (IFA).

Jean-Blaise Eckert

Lenz & Staehelin

Route de Chêne 30

CH-1211 Geneva 17

Switzerland

Tel: +41 58 450 70 00

Fax: +41 58 450 70 01

Email: jean-blaise.eckert@lenzstaehelin.com

Website: www.lenzstaehelin.com

Jean-Blaise Eckert is a partner at Lenz & Staehelin and co-head of the tax group. His practice areas include tax, private clients, contract law and commercial.

He speaks French, English and German. Jean-Blaise studied law at the University of Neuchâtel and was admitted to the Bar of Neuchâtel in 1989 and to the Bar of Geneva in 1991. He studied business administration at Berkeley, Haas Business School, where he acquired an MBA in 1991. He received his diploma as a certified tax expert in 1994 and is a certified specialist in inheritance law.

Jean-Blaise is considered as a leading lawyer in Switzerland. He advises a number of multinational groups of companies as well as high-net-worth individuals. He sits on the board of a number of public and private companies. He has been nominated by Chambers in 2017 as a leading individual in tax. Jean-Blaise is a frequent speaker at professional conferences on tax matters. Jean-Blaise is general secretary of the International Fiscal Association (IFA).

Jackie Hess
	Deloitte Switzerland General-Guisan-Quai 38 P.O. Box 2232 CH- 8022 Zurich Switzerland Tel: +41 58 279 63 12 Fax: +41 58 279 66 00 Email: jahess@deloitte.ch Website: www.deloitte.ch Jackie Hess, Deloitte Switzerland, is the managing partner for tax and legal and is a member of the Swiss executive team. She is a very experienced international tax partner who has more than 20 years of experience serving some of Deloitte's largest multinational clients in Switzerland. Her areas of focus include business model optimisation in the BEPS era, Swiss rulings and tax holiday negotiations, tax controversy, and audit defence. In addition, she has extensive experience in cross-border tax planning including substance reviews, intellectual property structuring, and finance planning, in particular with US multinationals that have or are in the process of establishing business operations in Switzerland as well as serving Swiss multinationals on a global basis. Jackie's industry focus is life sciences where she frequently advises multinationals companies in the biotech and medtech space that have their European headquarters in Switzerland. Jackie holds a BA from the University of Chicago, JD from Cornell Law School and an LLM from the Catholic University in Leuven, Belgium. She is also a Swiss certified tax expert.

Jackie Hess

Deloitte Switzerland

General-Guisan-Quai 38

P.O. Box 2232

CH- 8022 Zurich

Switzerland

Tel: +41 58 279 63 12

Fax: +41 58 279 66 00

Email: jahess@deloitte.ch

Website: www.deloitte.ch

Jackie Hess, Deloitte Switzerland, is the managing partner for tax and legal and is a member of the Swiss executive team.

She is a very experienced international tax partner who has more than 20 years of experience serving some of Deloitte's largest multinational clients in Switzerland.

Her areas of focus include business model optimisation in the BEPS era, Swiss rulings and tax holiday negotiations, tax controversy, and audit defence. In addition, she has extensive experience in cross-border tax planning including substance reviews, intellectual property structuring, and finance planning, in particular with US multinationals that have or are in the process of establishing business operations in Switzerland as well as serving Swiss multinationals on a global basis.

Jackie's industry focus is life sciences where she frequently advises multinationals companies in the biotech and medtech space that have their European headquarters in Switzerland.

Jackie holds a BA from the University of Chicago, JD from Cornell Law School and an LLM from the Catholic University in Leuven, Belgium. She is also a Swiss certified tax expert.

Niklaus Honauer
	PwC Birchstrasse 160 CH – 8050 Zürich Switzerland Tel: +41 58 792 59 42 Email: niklaus.honauer@ch.pwc.com Website: pwc.com/taxcontroversy Niklaus Honauer is a partner at PwC in Switzerland's tax services practice. He regularly and successfully assists clients in tax litigation. After completing his law degree and the attorney-at-law, Niklaus joined PwC in 1990 as partner and leader of the Swiss VAT team. In 2000, he became a member of the competence centre for indirect taxes of the Swiss Chamber of Tax Advisers, which he leads as president. Since 2001, he has been a member of the indirect tax leading team within PwC. Niklaus has been a tax and legal consultant for nearly 30 years. He consults for both multinational and mid-sized enterprises in all kinds of indirect tax issues. He is one of the leading indirect tax consultants in Switzerland and is well known in the industry and the tax administration. With his position as a member of the indirect tax leading board in Europe, he has a direct link to all PwC indirect tax partners all over the world. Niklaus's mother tongue is Swiss German. He speaks English and French fluently.

Niklaus Honauer

PwC

Birchstrasse 160

CH – 8050 Zürich

Switzerland

Tel: +41 58 792 59 42

Email: niklaus.honauer@ch.pwc.com

Website: pwc.com/taxcontroversy

Niklaus Honauer is a partner at PwC in Switzerland's tax services practice. He regularly and successfully assists clients in tax litigation.

After completing his law degree and the attorney-at-law, Niklaus joined PwC in 1990 as partner and leader of the Swiss VAT team. In 2000, he became a member of the competence centre for indirect taxes of the Swiss Chamber of Tax Advisers, which he leads as president. Since 2001, he has been a member of the indirect tax leading team within PwC.

Niklaus has been a tax and legal consultant for nearly 30 years. He consults for both multinational and mid-sized enterprises in all kinds of indirect tax issues. He is one of the leading indirect tax consultants in Switzerland and is well known in the industry and the tax administration.

With his position as a member of the indirect tax leading board in Europe, he has a direct link to all PwC indirect tax partners all over the world.

Niklaus's mother tongue is Swiss German. He speaks English and French fluently.

Benjamin Koch
	PwC Birchstrasse 160 Ch-8060 Zurich Switzerland Tel: +41 58 792 43 34 Email: benjamin.koch@ch.pwc.com Website: pwc.com/taxcontroversy Benjamin Koch leads the transfer pricing and value chain transformation practice of PwC Switzerland. Before joining PwC, Benjamin gained diversified international management experience in finance as controller and CFO of companies in the pharmaceutical research and development and pharmaceutical distribution industry, the telecommunications sector, and the construction industry. He also gained international experience as a senior consultant for mergers, acquisitions, and equity finance. Benjamin's experience includes advising multinational enterprises on the structuring of global manufacturing and distribution, development of global core documentation, migration of intangible property, establishing global trademark royalty schemes and the development of service fee concepts. Benjamin has successfully implemented various value chain/business model transformation projects including post-merger integration. Benjamin also has substantial experience assisting companies in preventing tax audits and managing international tax controversies through the proactive use of advance pricing agreements (APAs), tax rulings and mutual agreement procedures (MAPs). Benjamin is PwC's Swiss territory leader for tax controversy and dispute resolution. In his capacity as an experienced transfer pricing partner, he is representing PwC Switzerland in the technical working groups of the Swiss Corporate Tax Reform III. Benjamin holds an MBA from the University of Rochester and is fluent in German and English.

Benjamin Koch

PwC

Birchstrasse 160

Ch-8060 Zurich

Switzerland

Tel: +41 58 792 43 34

Email: benjamin.koch@ch.pwc.com

Website: pwc.com/taxcontroversy

Benjamin Koch leads the transfer pricing and value chain transformation practice of PwC Switzerland.

Before joining PwC, Benjamin gained diversified international management experience in finance as controller and CFO of companies in the pharmaceutical research and development and pharmaceutical distribution industry, the telecommunications sector, and the construction industry. He also gained international experience as a senior consultant for mergers, acquisitions, and equity finance.

Benjamin's experience includes advising multinational enterprises on the structuring of global manufacturing and distribution, development of global core documentation, migration of intangible property, establishing global trademark royalty schemes and the development of service fee concepts. Benjamin has successfully implemented various value chain/business model transformation projects including post-merger integration.

Benjamin also has substantial experience assisting companies in preventing tax audits and managing international tax controversies through the proactive use of advance pricing agreements (APAs), tax rulings and mutual agreement procedures (MAPs). Benjamin is PwC's Swiss territory leader for tax controversy and dispute resolution.

In his capacity as an experienced transfer pricing partner, he is representing PwC Switzerland in the technical working groups of the Swiss Corporate Tax Reform III.

Benjamin holds an MBA from the University of Rochester and is fluent in German and English.

Ferdinando Mercuri
	Deloitte Switzerland Avenue de Montchoisi 15 P.O. Box 460 1001 Lausanne Switzerland Tel: +41 58 279 9242 Fax: +41 58 279 9300 Email: fmercuri@deloitte.ch Website: www.deloitte.ch Ferdinando Mercuri, Deloitte Switzerland, is a tax partner and is a certified tax expert. He has broad experience in all taxation matters and has been advising both corporations and individuals for more than 18 years. Ferdinando serves several large listed and non-listed companies in Switzerland, providing them with meaningful advice and support in relocation, mergers and acquisitions, due diligence and compliance duties. He is in charge of individual clients, particularly in the field of private equity and hedge funds, and is the financial services industry tax leader for the French and Italian speaking parts of Switzerland. Ferdinando holds a law degree from the University of Lausanne. He teaches tax law in Western Switzerland and is responsible for the international tax module for the French part of the Swiss Tax Academy. He is also a frequent speaker at seminars on tax matters and has held numerous presentations and written several articles covering Swiss outbound investments and cross-border structuring, tax planning, dividend stripping, and financing.

Ferdinando Mercuri

Deloitte Switzerland

Avenue de Montchoisi 15

P.O. Box 460

1001 Lausanne

Switzerland

Tel: +41 58 279 9242

Fax: +41 58 279 9300

Email: fmercuri@deloitte.ch

Website: www.deloitte.ch

Ferdinando Mercuri, Deloitte Switzerland, is a tax partner and is a certified tax expert. He has broad experience in all taxation matters and has been advising both corporations and individuals for more than 18 years.

Ferdinando serves several large listed and non-listed companies in Switzerland, providing them with meaningful advice and support in relocation, mergers and acquisitions, due diligence and compliance duties. He is in charge of individual clients, particularly in the field of private equity and hedge funds, and is the financial services industry tax leader for the French and Italian speaking parts of Switzerland.

Ferdinando holds a law degree from the University of Lausanne. He teaches tax law in Western Switzerland and is responsible for the international tax module for the French part of the Swiss Tax Academy. He is also a frequent speaker at seminars on tax matters and has held numerous presentations and written several articles covering Swiss outbound investments and cross-border structuring, tax planning, dividend stripping, and financing.

Raoul Stocker
	Deloitte Switzerland General Guisan Quai 38 8022 Zurich Switzerland Tel: +41 58 279 6271 Fax: +41 58 279 6600 Email: rstocker@deloitte.ch Website: www.deloitte.ch Raoul Stocker, Deloitte Switzerland, has broad experience in all taxation matters and has been advising both corporations and individuals for more than 15 years. He focuses on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing, as well as taxation of financial institutions. He is specifically experienced in international tax litigation such as mutual agreement procedures and advance pricing agreements. Raoul Stocker is assistant professor for taxation (in particular for corporate taxation) at the University of St Gallen and a frequent speaker at tax conferences. He publishes articles in numerous national and international tax journals. From 2003 to 2008, Raoul Stocker was head of transfer pricing at the Swiss Federal Tax Administration, where he was responsible for MAP and APA negotiations in transfer pricing matters.

Raoul Stocker

Deloitte Switzerland

General Guisan Quai 38

8022 Zurich

Switzerland

Tel: +41 58 279 6271

Fax: +41 58 279 6600

Email: rstocker@deloitte.ch

Website: www.deloitte.ch

Raoul Stocker, Deloitte Switzerland, has broad experience in all taxation matters and has been advising both corporations and individuals for more than 15 years. He focuses on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing, as well as taxation of financial institutions. He is specifically experienced in international tax litigation such as mutual agreement procedures and advance pricing agreements.

Raoul Stocker is assistant professor for taxation (in particular for corporate taxation) at the University of St Gallen and a frequent speaker at tax conferences. He publishes articles in numerous national and international tax journals.

From 2003 to 2008, Raoul Stocker was head of transfer pricing at the Swiss Federal Tax Administration, where he was responsible for MAP and APA negotiations in transfer pricing matters.