Belgium

PwC

Woluwe Garden – Woluwedal 18

1932 Sint-Stevens-Woluwe

Belgium

Tel: +32 (0)2 710 43 66

Email: patrick.boone@be.pwc.com

Website: www.pwc.com/taxcontroversy

Patrick Boone is the Belgian managing partner for tax and legal services, and representative in the PwC global transfer pricing network.

Patrick joined PwC in 1994. He has obtained relevant experience in corporate structuring and restructuring from a domestic and international perspective. In 1999 and 2000, Patrick worked in PwC's London transfer pricing group and gained additional experience with respect to transfer pricing and value chain transformation projects in a wide range of sectors. He was also involved in Competent Authority and APA negotiations on a European level.

Besides tax planning, Patrick also assisted clients in defence work. Patrick is a central cluster co-leader of the PwC tax controversy and dispute resolution worldwide network. He is the European tax lead for major Japanese, European and American accounts. He is specialised in global core documentation and the financial services industry, as well as in tax controversy and dispute resolution.

He is now heavily focussing on assisting clients in addressing BEPS-related consequences and has, for example, already been involved in various country-by-country reporting projects.

Patrick teaches transfer pricing in the academic world (Vlekho UAMS), is a regular speaker at seminars and conferences and runs transfer pricing sessions during international training courses within PwC.

Law Square

(an independent law firm in Belgium with a privileged cooperation with the PwC network)

Woluwe Garden – Woluwedal 20

1932 Sint-Stevens-Woluwe

Belgium

Tel: +32 (0)2 710 78 17

Email: veronique.de.brabanter@lawsquare.be

Website: www.lawsquare.be

Véronique De Brabanter is a counsel at Law Square, an independent law firm with a privileged cooperation with the PwC network. Her practice focuses on dispute resolution and litigation related to all types of taxes.

Over a period of 20 years, Véronique has built up experience in advising both Belgian and international clients on procedural matters and in handling both administrative and court proceedings (such as complex transfer pricing disputes).

As a specialist in Belgian and international tax law, she assists clients in tax audits and negotiates settlements with the administrative authorities. She assists clients in developing a litigation strategy on the basis of national legislation, EU law and the case law of the Court of Justice of the European Union and of the Human Rights Court.

Véronique also carries out risk analysis (e.g. penalties, criminal prosecution, liability of managers, etc.) and helps clients with voluntary disclosures.

Véronique has expertise in litigation aftercare and assists clients in the execution of settlements or court decisions and files requests for waivers of interest and penalties.

She regularly lectures at seminars with respect to tax matters.

Véronique is a member of the Brussels Bar. She is fluent in Dutch, English and French.

Deloitte Belgium

Berkenlaan 8a

1831 Brussels / Diegem

Belgium

Tel: +32 2 800 70 10

Fax: +32 2 800 70 01

Email: ldebroe@laga.be

Website: www.laga.be

Luc De Broe, Deloitte Belgium, joined the tax controversy solutions department in 2010. Before joining, he was partner and senior counsel with Stibbe.

Luc has been a member of the Brussels Bar since 1982. He is also a professor of tax law at the Katholieke Universiteit Leuven (KUL). Since 2007, he has been a member of the executive committee of the International Fiscal Association (IFA).

Luc is the author of numerous articles on Belgian, international and European tax law. In 1988, he was awarded the IFA's Mitchell B Carroll Prize for his manual on cross-border leasing between Belgium and the US. In 2008, he published the book, 'Tax Planning and the Prevention of Tax Avoidance'.

Luc graduated from the KUL and earned a master of laws degree from the Northwestern University School of Law (Chicago, 1986). Luc also earned a degree in tax law from the Ecole Supérieure des Sciences Fiscales Bruxelles (1987) and earned a doctorate from the KUL in 2007

Law Square

(an independent law firm in Belgium with a privileged cooperation with the PwC network)

Woluwe Garden – Woluwedal 20

1932 Sint-Stevens-Woluwe

Belgium

Tel: +32 (0)2 710 42 34

Email: jurgen.gevers@lawsquare.be

Website: www.lawsquare.be

Jurgen Gevers is a director (advocaat vennoot/avocat associé) at Law Square, an independent law firm with a privileged cooperation with the PwC network. Jurgen has more than 16 years of experience in tax dispute resolution and litigation. Before joining Law Square, he was a partner at Antaxius Advocaten.

Jurgen assists national and multinational enterprises with customs and excise issues, including anti-dumping and countervailing duties, as well as related tax aspects. In this context, he advises his clients on procedures and assists them in audits and criminal investigations, negotiations on amicable settlements, rulings and submissions of applications for reimbursement and remission.

Jurgen also handles disputes with the Customs and Excise Administration or the VAT authorities and assists his clients in administrative proceedings and proceedings before the civil and criminal courts, the Belgian Constitutional Court and the Supreme Court. Jurgen has been involved in cases before the Court of Justice of the European Union (e.g. C-499/14, C-351/11, C-367/09 and C-201/04).

Jurgen assists his clients in the negotiation and drafting of contracts between logistic services and importers/exporters, between importers and suppliers/customers, and between exporters and customers. He also represents them before the commercial courts in related disputes.

He teaches customs and excise in tax and accountancy management at the Karel de Grote University College in Antwerp and has published numerous tax-related articles.

Jurgen is a member of the Brussels Bar. He is a Dutch native speaker and speaks English and French.

Law Square

(an independent law firm in Belgium with a privileged cooperation with the PwC network)

Woluwe Garden – Woluwedal 20

1932 Sint-Stevens-Woluwe

Belgium

Tel: +32 (0)2 710 78 05

Email: ine.lejeune@lawsquare.be

Website: www.lawsquare.be

Ine Lejeune is a partner and leads the tax policy, tax dispute resolution and tax litigation practice at Law Square, an independent law firm with a privileged cooperation with the PwC network.

Her team of 15 tax lawyers provides support related to all sorts of taxes (corporate income taxes, personal income taxes, customs, excise, anti-dumping duties, VAT and environmental taxes) by developing local or globally coordinated dispute resolution and litigation strategies, and developing a defence strategy for clients using national legislation, EU law and the jurisprudence of the Court of Justice of the European Union (ECJ). The team has also assisted with both regulatory and voluntary disclosure, acted on behalf of clients during audits, (fraud) investigations and raids, assisted clients with administrative appeals and settlement negotiations with authorities, policymakers and mediation and arbitration procedures, and defended clients' interests in all courts in Belgium (from the lowest to the Constitutional Court and the Supreme Court), the EU and the ECJ. The team is also highly experienced in filing complaints with the European Commission (EC).

Before joining Law Square as a partner, Ine held multiple leadership positions within PwC, which she joined in 1984, including global indirect tax network leader, global indirect tax policy leader and partner in charge of PwC's services to the EU institutions.

Ine assists clients with tax disputes and procedures before national courts in Belgium, and other European countries, as well as before the ECJ. Ine has filed complaints with the EC, resulting in infraction procedures and changes in national legislations to resolve litigations.

Ine has been responsible for 36 studies delivered to DG TAXUD (EC), has provided policy services to Belgium (VAT grouping), other EU member states and non-EU countries (UAE, GCC, China and India).

She is a member of the EC's VAT expert group, and the OECD's technical advisory group (TAG) for consumption taxes.

Ine was elected 'Belgian Taxman' in 2009 (an annual award recognising an outstanding contribution to tax).

She lectures at the University of Vienna (WU) in the LLM programme in international tax law and has lectured at other universities in Europe and China.

She has published several books and articles on EU, global and Belgian VAT and the case law of the Court of Justice. She has a master's degree in law and a postgraduate degree in tax studies.

Ine is a member of the Brussels Bar. She is fluent in Dutch, English and French.

Mayer Brown

Avenue des Arts 52

1000 Brussels

Belgium

Tel: +32 2 551 5968

Fax: +32 2 502 5421

Email: apieron@mayerbrown.com

Website: www.mayerbrown.com

Astrid Pieron has more than 35 years of tax experience, which includes over 30 years of focus on international taxation.

Her practice includes counseling on the transactional aspects of transfer pricing, tax optimisation of mergers and acquisitions, structuring of investment funds and general assistance to private equity deals.

Astrid heads Mayer Brown's European transfer pricing center and coordinates transfer pricing strategies and controversies in Europe. She participates in the EU platform for tax good governance and has previously served as a non-governmental member to the EU joint transfer pricing forum advising the European Commission on transfer pricing matters (2012-15).

Before joining Mayer Brown, Astrid practiced in Brussels and Luxembourg with two of the world's leading tax and accounting firms Deloitte (2002-06) and Arthur Andersen (1981-02).

Law Square

(an independent law firm in Belgium with a privileged cooperation with the PwC network)

Woluwe Garden – Woluwedal 20

1932 Sint-Stevens-Woluwe

Belgium

Tel: +32 (0)2 710 42 34

Email: philippe.renier@lawsquare.be

Website: www.lawsquare.be

Philippe Renier is a director (advocaat vennoot/avocat associé) at Law Square, an independent law firm with a privileged cooperation with the PwC network.

Philippe has more than 15 years of experience in tax in different law firms.

Philippe has extensive experience assisting national and multinational industrial and financial companies with complex tax controversy issues. He has an excellent reputation and good contacts with the tax authorities. Philippe has significant experience undertaking remedial action after an audit by the special tax inspectors' team, as well as tax settlement procedures before tax authorities and the public prosecutor, thereby using mediation and negotiation techniques.

As a tax litigator, Philippe has significant experience on complex tax litigation procedures before all Belgian and European courts with specific regard to tax fraud, withholding tax claims, transfer pricing, permanent establishment issues and anti-avoidance rules.

Philippe has experience assisting multinational industrial and financial clients (banks) for EEC Arbitration Convention procedures, as well as on claims and ruling requests (involving domestic and EU law, application of tax treaties, anti-avoidance rules, and the non-discrimination principle).

Philippe litigated/is litigating some milestone cases before the European Court of Justice, including one on excess dividend deductions received by taxpayers (C-499/07) and another on tax fairness and the tax on dividends (C-68/15).

He has also successfully defended cases before the Belgian Constitutional Court.

Philippe is a professor at the University of Brussels where he lectures on tax procedural law. He is linked to the University of Hasselt as a voluntary researcher in the area of tax law.

He has published numerous tax-related articles in matters that concern national and international tax litigation. He regularly lectures on specialised tax seminars and is frequently quoted in the press.

Philippe is a member of the Brussels Bar. He is a Dutch native speaker, is fluent in French and English and proficient in Spanish.

Deloitte Belgium

President Kennedylaan 8a/0001

8500 Kortrijk

Belgium

Tel: +32 56 59 43 00

Fax: +32 56 59 43 01

Email: jspeecke@laga.be

Website: www.laga.be

Johan Speecke, Deloitte Belgium, is a founding partner of the tax law service line, created in 1997. Before this, he was a partner at the Tournicourt & Vanistendael law office.

As a senior partner of the tax team, Johan specialises in tax litigation, advising companies and individuals during the administrative process (advice on tax challenges leading to final assessments, negotiations with both local and central tax administration, individual rulings, claims against assessments, notices, among others) as well as before the tax and criminal courts both in Belgium (Court of First Instance, Court of Appeal, Supreme Court) and elsewhere in Europe.

Johan is a professor at the Fiscale Hogeschool Brussels and a permanent member of the editorial staff of the Tijdschrift voor Fiscaal recht. He holds a degree in law from the University of Leuven (KUL) and a degree in economics from EHSAL

Deloitte Belgium

Berkenlaan 8a

1831 Brussels / Diegem

Belgium

Tel: +32 2 800 70 11

Email: dstas@laga.be

Website: www.laga.be

Danny Stas, Deloitte Belgium, is a VAT expert and managing partner.

Danny has 20 years of experience as an adviser/lawyer in VAT. He started his career as a VAT consultant with Arthur Andersen, later working as a managing partner at a tax boutique. He joined Deloitte in January 2012. He is a tax lawyer specialised in VAT, in particular with respect to real estate and financial transactions, as well as eco taxes and contributions.

In the real estate industry, Danny focuses on VAT consulting for clients in the private sector (for example real estate developers, REITs, hospitals, senior housing) and public sector, and the broad corporate market at national and international levels. In addition to specific VAT topics (for example reduced VAT rates, VAT exemptions), he also has good knowledge of alternative financing of real estate and transfer duties.

Danny earned a degree in law from KUL, Leuven (1994) and a degree in tax and accounting from Vlerick, RUG (1995). He has authored several books and articles discussing VAT related matters. He is also a regular speaker at internal and external seminars and is regularly consulted by professional federations in Belgium on legislative initiatives.

Deloitte Belgium

Berkenlaan 8a

1831 Brussels / Diegem

Belgium

Tel: +32 2 800 70 80

Fax: +32 2 800 70 01

Email: avisschers@laga.be

Website: www.laga.be

Annick Visschers, Deloitte Belgium, joined the tax controversy solutions team in 2010. Before this, Annick practised at Stibbe until 1999.

A member of the Brussels Bar since 1996, Annick specialises in Belgian and international tax law and focuses on tax risk management (preventing disputes and resolving business issues), tax litigation (defending clients before Belgian tax courts, the Supreme Court and the European Court of Justice), tax recovery and criminal tax matters.

Annick is a member of the editorial staff of the journal Révue Générale du Contentieux Fiscal and CFO-magazine and of the chief editorship (doctrine) of the Tijdschrift voor Fiscaal Recht. She is also the author of numerous articles on tax risk management and the investigative powers of the tax authorities.

Annick graduated from the University of Leuven in 1995 and studied tax law at the Université Libre de Bruxelles.