Turkey

Deloitte Turkey

Deloitte Values House

Maslak No1

Sarıyer

Istanbul 34398

Turkey

Tel: +90 212 366 60 91

Email: acangoz@deloitte.com

Website: www.deloitte.com

Ahmet Cangöz, Deloitte Turkey, joined as a tax partner in 2007, having previously worked for the Ministry of Finance as a tax inspector and for a major private Turkish group of companies as a top executive. He has 30 years of experience as a tax professional.

Ahmet leads the tax and legal practice and has been rendering corporate tax certification and tax consultancy services mostly to international clients.

During his career as a tax adviser, Ahmet specifically focused on taxation matters regarding energy and construction projects involving multinational consortia and joint ventures. Also, as a sworn tax adviser and a reputable collaborator, he has assisted with many sizeable tax disputes before the Tax Settlement Committee. He has been an expert witness in many local tax court cases and several international disputes as well.

Ahmet graduated from Ankara University with a BA in economics (1985), and earned an MBA from Southern New Hampshire University, US (1995). He also holds certificates from Ankara University (1992) and Cornell University (2012).

He is certified as a sworn financial adviser (1995) and is registered with the Chamber of Istanbul (2004).

Deloitte Turkey

Maslak Mah. Eski Buyukdere Cad. No: 1

Maslakno/1 Sariyer

Istanbul, 34398

Turkey

Tel: +90 212 366 60 69

Email: ncomez@deloitte.com

Website: www.deloitte.com

Niyazi Cömez, Deloitte Turkey, is a partner with more than 30 years of experience as a Turkish international and local tax specialist. Before joining Deloitte, Niyazi spent 14 years as an inspector of taxes and head of department at the Turkish tax authority. Since leaving the Turkish tax authority in 1999, he has been an adviser, assisting clients with strategic planning and defence of their tax disputes. He has also appeared in tax courts and tax settlement committees as an expert witness relating to tax matters.

Niyazi serves a range of multinational clients, with particular focus on real estate investment, private equity, financial services, insurance and mergers and acquisitions. As an experienced trainer, he lectured at various OECD tax training programmes in Ankara, Budapest and Vienna. Niyazi is a member of the tax steering committee of the Association of Turkish Industrialists and Businessmen (TUSIAD) and working group of the Tax Council, and is a sworn-in tax adviser.

Niyazi has an MA in economics from Ankara University and an MBA from Leicester University in the UK. He also holds a certificate from Harvard University's international tax programme.

Deloitte Turkey

Deloitte Values House

Maslak No 1 Sarıyer

İstanbul 34398

Turkey

Tel: +90 212 3666256

Fax: +90 212 3666015

Email: gdurak@deloitte.com

Website: www.deloitte.com

Gündoğan Durak, Deloitte Turkey, is a tax partner and has more than 15 years of experience as a Turkish international and local tax specialist. He joined Deloitte Turkey in 2013 and focused on tax litigation and controversy practice, as well as the taxation of the financial sector. Prior to joining Deloitte, he was a tax inspector at the Ministry of Finance and conducted tax audits of companies operating in different sectors including finance, manufacturing, infrastructure, construction and textiles.

Gündoğan possesses extensive knowledge of direct and indirect tax laws and has expertise in the taxation of financial instruments. He worked on the tax due diligence and international tax compliance projects. Gündoğan has been rendering tax return certification and tax consultancy services to national and international clients.

He manages tax disputes for clients during their tax investigations and advises them on how to secure the most favourable outcome in an efficient manner. He represents clients in law courts and administrative hearings.

Gündoğan is a member of the tax steering committee of the Association of Turkish Industrialists and Businessmen (TUSIAD).

He is certified as a sworn financial adviser (2013) and is registered with the Chamber of Istanbul.

Gündoğan has a bachelor's degree in public administration from Hacettepe University (2001). He earned his Masters of Science in finance from the University of Illinois (2010). He holds designations as a CPA (US, Illinois), CMA and CGMA. He is also a certified independent auditor in Turkey.

PwC Turkey

Süleyman Seba Cad. No:48 BJK Plaza

B Blok K:4 Akaretler Beşiktaş Istanbul

Turkey

Tel: +90 212 326 6080

Email: zeki.gunduz@tr.pwc.com

Website: www.pwc.com/tr

Zeki Gündüz is a partner at PwC Turkey and he leads the country's tax practice. Alongside his leadership role in the tax practice, he also leads the PwC turkey tax controversy and dispute resolution team.

Zeki worked for eight years as an auditor at the Ministry of Finance and then joined PwC in 1992. In his former role as a finance inspector, he performed numerous tax audits of private companies and state institutions and participated in inspections at various ministerial departments. He spent a year performing vocational work in the UK as an officer of the Ministry of Finance.

Zeki, a sworn financial adviser (YMM) and lawyer, is also an educator and is a regular speaker at tax forums and seminars organised by PwC, the Istanbul Chamber of Sworn Financial Advisors (İYMMO), the Istanbul Chamber of Certified Public Accountants (İSMMMO), publication houses, professional associations and other institutions. He has worked in numerous tax commissions and published articles in several publications.

Experienced in various local and international projects, Zeki has led PwC Turkey's pharmaceutical industry and the transfer pricing, client training and tax/customs disputes groups in the tax and legal services department. He has represented a broad range of corporate clients on various tax and customs related dispute resolution projects for about 25 years. With his extensive experience and background in law, Zeki is considered as one of the foremost experts in the field of tax and customs litigation.

Alongside his professional interests, Zeki is a member of numerous business organisations, including the Turkish Industrialists and Businessmen's Association (TÜSİAD), Tax Commission and the board of Transparency International and IFA in Turkey, he is representing International Investors Association (YASED) in the Tax Council. Zeki is the author of various articles and supplements in periodicals as well as PwC publications.

Zeki has graduated from the Ankara University Faculty of Law and is admitted to the Istanbul Bar Association.

Nazali Attorney Partnership

Elit Residence

19 Mayıs Cad.

Dr. İsmet Öztürk Sok. 3/28 Kat: 10

Şişli 34360 Istanbul

Turkey

Tel: +90 212 380 0640

Fax: +90 212 217 1890

Email: enazali@nazali.av.tr

Website: www.nazali.av.tr

Ersin Nazali, who worked as a tax inspector for nine years under the Revenue Administration, is an expert and has considerable knowledge in several tax and corporate law areas, especially customs disputes, customs litigation, transfer pricing, tax inspections and tax-free restructuring of companies.

He graduated from Ankara University and also Dicle University. He has master's degrees from Istanbul University in fiscal law (MSc) and also from King's College London in international tax law (LLM). He is now working on his PhD thesis on transfer pricing methods at Istanbul University.

After graduating from university in 2001, he worked as a tax assistant in Arthur Andersen and then as deputy inspector in the Prime Ministry Board of Inspection. On April 14 2004, he was assigned as the deputy tax inspector upon his success in the entrance exam. In May 2007, he became a tax inspector.

In 2011 and 2012, he worked as a tax inspector at the Istanbul Tax Inspection Board within the presidency of thin capital, transfer pricing and foreign based income group. As of August 2012, Ersin now works as a tax consultant and attorney in the private sector. He has a very good command of English.

He is registered with the Istanbul Bar Association as a lawyer and with the Istanbul Chamber of Sworn in CPA as a CPA. He is also a member of the Istanbul Bar Association Tax and Administration Law Center, TUSIAD (Turkish Industry and Business Association) Tax Law Study Group, Tax Inspectors Association and Foundation, and Prime Ministry Inspectors Association.

Ersin has been listed as a leading tax adviser and attorney in Turkey by Legal 500 (2013, 2014 and 2015) and International Tax Review (2014, 2015, and 2016).

Ersin has also published more than 80 articles in several tax journals. His recent publications and studies include:

• Liquidation, Merger, Acquisition, Spin-off and Conversion of Joint Stock and Limited Liable Companies in respect of Tax and New Turkish Commercial Code (4th edition, 2015);

• Tax of Law (Tax Criminal Law, Tax Litigation Law) (1st edition, 2014);

• International Tax Law (Transfer Pricing, Double Tax Treaties) (1st edition, 2015);

• Work Place/Permanent Establishment in respect of Tax Treaties and Turkish Tax Law (1st edition, 2017);

• Taxation of Securities within the Scope of European Union Harmonization Proficiency Study-Tax Inspectors' Board, Unpublished, Istanbul, 2007;

• Criminal and Tax Liability of Company Directors; and

• Proficiency Study-Prime Ministry Inspectors Board, Unpublished, Ankara, 2003.

PwC Turkey

Süleyman Seba Caddesi, BJK Plaza B Blok

No: 48 Beşiktaş – İstanbul

Turkey

Tel: +90 212 326 64 41

Email: ezgi.turkmen@pwc.com

Website: pwc.com/taxcontroversy

Ezgi Türkmen started to work for PwC after her graduation from Ankara University, Faculty of Law, in 1999. After working as an auditor on tax audit, certification and consultancy of international and local corporations for a year, she joined the tax and customs disputes management department.

Ezgi is specialised in tax law and she is providing consultancy in settling the tax or customs disputes of companies from various sectors either by administrative or judicial ways.

Ezgi is the leader of the team that provides dispute consultancy on corporate tax issues for the Turkish operations of leading internet based companies for the past couple of years. She is very experienced in disputes about the taxation of online services, and highly complex transfer pricing disputes in various sectors. With her sophisticated approach in litigation processes, which applied ECHR (European Court of Human Rights) to the tax disputes, she made a substantial contribution to the judicial precedent in Turkey.

She has focused on large internet-based companies and multinational clients. These clients are operating in various sectors including real estate, manufacturing, pharmaceutical and the chemical industry. Her experiences in corporate tax disputes also includes indirect tax disputes and the tax amnesty process in Turkey.

Ezgi has participated in many seminars and training programmes as a lecturer and trainer along with organising seminars and in-house client training. She is also a founding member of the International Fiscal Association (IFA) Turkey and a member of the Istanbul Bar Association. Together with being a lawyer, she is a certified public accountant (SMMM).