Switzerland

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 had 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

Lenz & Staehelin

Route de Chêne 30

1208 Geneva

Switzerland

Tel: +41 58 450 70 00

Email: jean-blaise.eckert@lenzstaehelin.com

Website: www.lenzstaehelin.com

Jean-Blaise is a partner at Lenz & Staehelin, working across the tax, private clients, contract and commercial, and internal investigations groups.

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 (HNWIs). He sits on the board of a number of public and private companies. Jean-Blaise is a frequent speaker at professional conferences on tax matters. He also teaches on the master's programmes of the University of Geneva and is a vice president and member of the executive committee of the International Fiscal Association (IFA). He has been a partner at Lenz & Staehelin since 1999, having joined the firm eight years earlier, in 1991.

Jean-Blaise attended University of Neuchâtel (lic iur, 1987 summa cum laude), Haas Business School, UC Berkeley (MBA, 1991), qualified certified tax expert (1994). Admitted to Neuchâtel Bar in 1989.

Jean-Blaise is a member and vice president of the IFA Executive Committee, a member of the committee of the Swiss branch of IFA, reporter to the International Bar Association (IBA) and IFA congress on Swiss tax matters. He is also a teacher in the master's programmes of the University of Geneva and University of Lausanne.

Jean-Blaise speaks English, French and German.

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 companies in all kind 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.

PwC

Birchstrasse 160

Ch-8060 Zurich

Switzerland

Tel: +41 58 792 43 34

Email: benjamin.koch@ch.pwc.com

Website: pwc.com/taxcontroversy

Benjamin 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 R&D and pharmaceutical distribution industry, the telecommunications and the construction industry. He also gained international experience as a senior consultant for M&A and equity finance.

Benjamin's experience includes advising multinational companies 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.

Deloitte Switzerland

General Guisan-Quai 38

8022 Zurich

Switzerland

Tel: +41 58 279 7216

Email: rschreiber@deloitte.ch

René Schreiber is a corporate international tax partner and the outbound tax leader of Deloitte Switzerland. He has 20 years of experience in corporate and international tax matters.

René has advised many leading Swiss multinationals. His projects include advising on international structuring and financing matters as well as cross border reorganisations. He advises clients across manufacturing, energy and resources and biotechnology industries in all aspects of tax controversy matters including preparation of appeals against tax assessments and assisting with tax audits and complex tax ruling proceedings. His client portfolio consists of large Swiss based multinationals and well-established entities in the mid-market.

René is a Swiss certified tax expert, attorney-at-law and has a diploma in law (lic-iur) from the University of Bern.

He is a member of the study commission and lectures on international tax law at the Schweizerisches Institut für Steuerlehre (SIST) in Zurich for the master of advanced studies in taxation/LLM programme. René is also a frequent speaker at national and international tax conferences and has published numerous articles in the field of corporate and international taxation.