Germany

PwC

Friedrich-Ebert-Anlage 35-37

60327 Frankfurt am Main

Germany

Tel: +49 69 9585 3551

Mobile: +49 171 178 3720

Email: ulf.andresen@de.pwc.com

Website: www.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 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).

Dentons

Markgrafenstraße 33

Berlin, 10117

Germany

Tel: +49 30 2 64 73 205

Email: stephan.busch@dentons.com

Website: www.dentons.com

Dr Stephan Busch is the managing partner of Dentons' Berlin office and head of the German tax law practice group.

He is a lawyer, certified specialist in tax law, and a certified tax adviser, who works primarily in the areas of tax and corporate law.

Stephan focuses on mergers and acquisitions, restructuring, credit institutes, state-owned companies and also acts as a barrister before the finance courts and the Federal Fiscal Court (Bundesfinanzhof).

PwC

Moskauer Straße 19

D-40227 Düsseldorf

Germany

Tel: +49 (0)211 981 1144

Email: axel.eigelshoven@de.pwc.com

Website: www.pwc.com/taxcontroversy

Axel Eigelshoven is a transfer pricing partner in PwC's Düsseldorf office. He has more than 20 years of experience in international taxation and transfer pricing. Before joining PwC, Axel worked for another Big 4 firm and assumed various roles, including head of their transfer pricing practice.

Axel is working on a wide variety of transfer pricing projects including tax audits, IP migration, tax effective supply chain management, permanent establishment issues, APAs and Competent Authority procedures under the tax treaty and the EU Arbitration Convention. He has led many projects for multinationals to set up supply chain structures in BRICS countries. 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 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 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

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 dealing especially with difficult tax technical questions on specific and general tax topics.

He serves a wide range of different clients, focussing 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 transactions and project-related tax advice with an international focus, such as M&A transactions, PMI restructurings, internal group restructurings, etc.

In this context, Stefan has experienced the German tax administration's changing approach in tax audits by becoming generally more aggressive compared to previous years. Thus, Stefan has applied a more focused, concentrated and organised approach to tax audits. Besides tax technical defence and negotiations in tax audits in which Stefan is engaged, his experience covers tax litigations at different tax courts with a wide range of tax technical topics such as tax accounting, international tax, German participation exemption and German capital gains exemption. Furthermore, he is actively involved in managing Competent Authority procedures and arbitration procedures.

His experience has allowed him to develop a process and a training program 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 soft skill areas in tax audits considering the Harvard Concept.

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.

PwC

Bernhard-Wicki-Str. 8

80636 München

Germany

Tel: +49 89 5790 5424

Email: joerg.hanken@de.pwc.com

Website: www.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.

PwC

Friedrich-List-Str. 20

45128 Essen

Germany

Tel: +49 211 981 5201

Fax: +49 211 981 7362

Email: claudia.lauten@de.pwc.com

Website: www.pwc.com/taxcontroversy

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

Claudia has over 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 M&A projects (due diligence, post-merger structuring), monitoring audits by fiscal authorities and negotiating transfer pricing structures with competent authorities, including APA procedures. Claudia's clients comprise large multinationals, both headquartered in Germany or abroad.

Claudia is heading the German TP dispute resolution practice, focussing 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 25 years of experience serving national and multinational clients. He is the leader of the private company services tax service line, and is experienced in tax structuring and tax controversy work.

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

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 14 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.

PwC

Bernhard-Wicki-Straße 8

München 80636

Germany

Tel: +49 89 5790 5378

Fax: +49 69 9585 976532

Email: stephan.rasch@de.pwc.com

Website: www.pwc.com/taxcontroversy

Prof Dr Stephan Rasch is a transfer pricing partner in PwC's Munich office. He has 16 years of experience in international taxation and transfer pricing. Before joining PwC in December 2013, Stephan worked with another Big 4 firm as a 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 as well as 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 includes bilateral and multilateral cases as well as the negotiation of bilateral and multilateral advance pricing agreements. Finally, he is involved in tax court litigation relating to transfer pricing cases. He has been appointed as German national reporter on Subject 1, 'Dispute Resolution', for the 70th International Fiscal Association (IFA) Congress in Madrid in 2016.

Stephan is a professor at the University of Augsburg and has lectured on international and European tax law since 2007. He 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 a member of the Munich Bar, 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).

Deloitte Germany

Rosenheimer Platz 6

81669 München

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.

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.

In 2014, Alexander was ranked as one of the best consultants in the area of white collar crime by Chambers Europe and Best Lawyers.

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 16 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 AG WPG

Moskauer Straße 19

D-40227 Düsseldorf

Germany

Tel.: +49 (0)211 981 7451

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

Website: www.pwc.com/taxcontroversy

Susann van der Ham has more than 16 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 few last years, Susann led a number of projects involving permanent establishments, complex restructurings including transfer of functions and post-merger integrations. Susann is a member of PwC's German retail and consumer competence team and 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 at international tax and transfer pricing conferences. She is the co-author of one of the leading German publications, Borberg Praxishandbuch. Verrechnungspreise. She frequently publishes in national and international tax literature on transfer pricing in German and English. Her recent publications include 'New Profit Attribution Rules for Construction and Exploration Permanent Establishments', published in the International Transfer Pricing Journal and a German article on the current issue of whether foreign affiliated companies need to be charged for the use of the group's name, published in the German journal, Internationales Steuerrecht (IStR).

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

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 IP 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.

PricewaterhouseCoopers AG Wirtschaftsprüfungs-gesellschaft

Moskauer Str. 19

40227 Düsseldorf

Germany

Tel: +49 211 981 2237

Email: ludger.wellens@de.pwc.com

Website: www.pwc.com/taxcontroversy

Ludger Wellens is a tax and transfer pricing partner of PwC in Germany. He coordinates PwC's transfer pricing activities in the region of West. He has more than 19 years of experience in all aspects of transfer pricing and international tax planning.

Ludger is certified as a German tax adviser (Steuerberater). He holds a diploma in international business from the University College Dublin (Ireland), an MBA from the University of Aachen and a PhD from the University of Bayreuth.

Ludger has worked for two of the Big 4 firms in their tax and transfer pricing departments. He was also member of the board and head of the transfer pricing group of a German based tax consulting firm. Furthermore, he worked as tax director and head of global transfer pricing for a major German based multinational enterprise.

Both as an in-house consultant in industry and as an outside expert, Ludger has planned and implemented numerous transfer pricing systems. He has worked extensively on value chain transformation projects both inbound and outbound.

He has extensive experience solving controversies through defending tax audits and supporting mutual agreement procedures as well as advance pricing agreements (APAs).

He has experience in planning, especially optimising value chains, dispute resolution (audits, MAPs and APAs), business restructuring, documentation and IT-based documentation, and valuations.

Ludger specialises in the pharma and life sciences industry, chemicals industry, as well as in the consumer products and energy sectors.