Portugal

PwC Portugal

Palácio Sottomayor

Rua Sousa Martins 1, 2º

1069-316 Lisbon

Portugal

Tel: +351 213 599 601

Email: jaime.esteves@pt.pwc.com

Website: www.pwc.com/pt

Jaime Carvalho Esteves is a partner of PwC Portugal and is PwC Angola, Cape Verde and Portugal head of tax. He is PwC's government and public sector leader and is an arbitrator at the Portuguese Court of Tax Arbitration (CAAD), being regularly involved in decisions in tax matters. He is a member of the governing board of the Forum for Competitiveness (Forum para a Competitividade).

During his career, he was partner of two prestigious law firms, being in charge of the Epson (STA) and Norvalor (STA) cases.

He is a specialist in national and international tax planning (both individual and corporate), transfer pricing, mergers and acquisitions, corporate reorganisations, high-net-worth individuals and family business, including family offices.

He has significant experience in the areas of oil and gas, automotive, civil construction and public works, retail, hospitality and leisure, industrial and consumer products, real estate, services and telecommunications.

Jaime teaches tax matters at several universities in Portugal (IPCA, ISAG, PBS, Católica Lisbon, and Católica Oporto) and participates regularly as a speaker in several courses, seminars and conferences, both domestically and internationally, dealing with subjects such as foreign investment and public policy as well as tax topics. He also collaborates regularly with several television stations, radio broadcasters and periodicals on the same topics.

During his career, Jaime has been awarded several prizes, granted by relevant entities in the field of taxation.

Jaime has written numerous articles and published several studies including: "Notes about the Epson Case" in Court Decisions, Almedina; "Partial Amortization of Shares without share capital reduction" and "Harmonization of Direct Taxation and the Gift and Inheritance Tax" in Fisco n 46 of 1992 and n 72/73 of 1995; "The Relevance of TNMM in Transfer Pricing", AAVV, Vida Económica, September of 2006; "Portugal" in The Determination of Corporate Taxable Income in the Member States, Kluwer Law International, 2007; "Budget Act Proposal 2009" in Practical European Tax Strategies (Vol. 10, In. 10 – Portugal); "Effective taxation of distributed profits", "Dealings" and "Profits and losses arising from mergers and spin-offs", respectively Minutes of the I, II and III Tax Congress of the Law Faculty of the Oporto University (2011, 2012, 2013); "Fat Capitalization" in Studies in Tribute to Professor Saldanha Sanches (2012) and "Permanent establishments and business conversions" in TP Studies (2013); co-authorship with Rosa Areias of CIT – Practice Notes; Resolving International Tax Disputes: The Emerging Role of Arbitration and the Portuguese Example, co-authorship with C David Swenson and Crystal A Thorpe, in The Portuguese Tax Arbitration Regime, of 2015, Almedina, CAAD.

Deloitte Portugal

Av. Eng. Duarte Pacheco, 7

1070-100 Lisbon

Portugal

Tel: +351 210 427 660

Email: tarodrigues@deloitte.pt

Website: www.deloitte.com

Tânia Rodrigues, Deloitte Portugal, is a senior manager in the Portugal Office and has more than 16 years of experience within Deloitte as a tax and transfer pricing controversy specialist.

Tânia has extensive experience in multi-jurisdictional international tax and transfer pricing projects for multinational groups, ranging from global business reorganisations, contemporaneous documentation engagements, risk review in the BEPS context, intellectual property (IP) tax planning, controversy and audit defence, such as assistance on administrative claims and in arbitration convention disputes. Tânia's controversy cases included, among others:

• Assistance in arbitration convention disputes, including the preparation of documentation and support in transfer pricing adjustments;

• Support in disputes involving permanent establishment (PE) structures and results (allocation of profits and costs);

• Participation in a state aid process as technical adviser, presenting economic analysis and data with a view to demonstrate the economic rationality of the transactions;

• Preparation, support and negotiation follow-up between taxpayers and Portuguese tax authorities on the context of cost sharing agreements;

• Support in tax audits regarding pricing of financial transactions (equity versus debt) and intercompany services, where technical arguments were presented in order to demonstrate compliance of such transactions with the arm's-length principle;

• Support in an administrative claim regarding self-initiated transfer pricing adjustments, in cases where a Portuguese branch performed a self-initiated negative transfer pricing adjustment to reflect the arm's-length pricing of a controlled transaction;

• Assistance on indirect methods process/appeals, especially using transfer pricing methodologies for determination of the taxable profit; and

• Assistance in hierarchical appeals, where technical arguments were presented in order to demonstrate compliance of different group transactions following the arm's-length principle.

Tânia is also experienced across a wide range of industries including energy and resources, communications, infrastructure, technology, financial services and other highly regulated markets.

Tânia was a lawyer and also teacher in the Law School.

She graduated in law from the Lisbon Law School (FDL) and obtained her LLM in international economic law from Warwick University (UK).

PwC Portugal

Palácio Sottomayor

Rua Sousa Martins 1, 2º

1069-316 Lisbon

Portugal

Tel: +351 213 599 631

Email: leendert.verschoor@pt.pwc.com

Website: www.pwc.com/pt

Leendert Verschoor is a tax and transfer pricing partner of PwC Portugal, Angola and Cape Verde. He leads the PwC transfer pricing services group in Portugal, Angola and Cape Verde and is representing Portugal within PwC's global transfer pricing network.

He started his professional activity in the area of taxation in the Netherlands. In 1999, he joined PwC in Portugal and became partner in 2008. He specialises in areas related to international taxation of multinational companies, with 24 years of experience in these matters. Since 2002, he devotes part of his time advising Portuguese subsidiaries of multinational groups and national groups with international presence in various sectors of activity with transfer pricing planning and transfer pricing documentation obligations. He has been involved in several restructuring projects of multinational companies in the Portuguese market, advance pricing agreement projects and transfer pricing defence work following audits conducted by Portuguese tax authorities.

He is responsible since 2007 for the tax services rendered by PwC in Cape Verde.

Leendert has a degree in business economics from Erasmus University Rotterdam and a degree in tax law from the University of Leiden, both in the Netherlands.

He is the author of the country section on Portuguese transfer pricing rules in the book International Transfer Pricing, of the Portuguese section in the book Mastering the IP Life Cycle and the book Substance, Aligning international tax planning with today's business realities, and wrote various articles about transfer pricing in economic newspapers and the International Transfer Pricing Journal. He wrote an article in Cadernos Preços de Transferência 2013, Almedina; on "Changes in the business model and permanent establishments".

Leendert lectures at the post-academic tax education at the Faculty of Law of the Catholic University in Lisbon on transfer pricing matters. He regularly participates as a speaker in several (training) courses, seminars and conferences.