Germany

Markgrafenstraße 33

Berlin, 10117

Germany

Tel: +49 30 2 64 73 205

Email: stephan.busch@dentons.com

Website: www.dentons.com

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

JUVE Handbook, 2010-2011 points out that "the valued tax practice of the international law firm employs Dr. Stephan Busch, one of the heavyweights in the field of tax of the German capital…" and ranks him together with his team within the top 30 in Germany. Furthermore, Stephan has been recommended by Best Lawyers since 2009 and he has received the tax 'Lawyer of the Year' award 2011 in the Best Lawyers rating (listings published in Handelsblatt, a leading German business daily newspaper). European Legal Experts listed Stephan under tax in 2007, 2008, 2009, 2010, 2011 and 2012. Chambers and Partners named Stephan as one of the leaders in their field in Europe and one of the most recommended lawyers in the tax practice.

Moskauer Straße 19

D-40227 Düsseldorf

Germany

Tel: +49 (0)211 981 -1966

Email: heinz-klaus.kroppen@de.pwc.com

Website: pwc.com/taxcontroversy

Before joining PwC in June 2014, Heinz-Klaus gained more than 25 years of professional experience in a Big 4 firm, where he led the German tax function as well as the EMEA tax practice during his final years. His client work concentrates exclusively on international matters, mainly cross-border transactions, acquisitions and multinational corporations' tax issues with a strong focus on transfer pricing and controversy. His recognition as a leading German tax and transfer pricing expert has led to his consistent selection for inclusion in Euromoney's Guide to the World's Leading Tax Advisers and the Guide to the World's Leading Transfer Pricing Advisers.

Heinz-Klaus' clients include several DAX 30 multinationals, as well as other European, US and Japanese corporations representing a wide range of industries. In recent years he led a number of tax audits, competent authority procedures and court proceedings including representation of his clients in the German Tax Courts and Supreme Tax Courts in the area of transfer pricing and international tax. Heinz-Klaus regularly negotiates APAs for large multinational clients. In 2011 Heinz-Klaus was a general reporter on Subject 1 'Cross-border business restructuring' at the 65th Congress of the International Fiscal Association (IFA) in Paris.

Heinz-Klaus is editor and co-author of the leading German publication on transfer pricing, Handbuch Internationale Verrechnungspreise, and editor and co-author of Gosch/Kroppen/Grotherr, DBA-Kommentar, a leading commentary on double tax treaties. He also co-authored the German chapter in the International Bureau of Fiscal Documentation's (IBFD) publication The Tax Treatment of Transfer Pricing. He has published a number of articles on international tax and transfer pricing matters. Heinz-Klaus is a member of the tax board of the American Chamber of Commerce in Germany as well as a board member of the German branch of IFA. He is also a professor of international tax law at the Ruhr University in Bochum.

Heinz-Klaus studied law at the universities of Kiel, Hamburg, Cologne and later clerked at the German Tax Court in Düsseldorf and at the German/Korean Chamber of Commerce and Industry in Seoul. During this time, he wrote a dissertation on company and tax law problems for which he was awarded his PhD in law. Heinz-Klaus later attended Georgetown University Law School (Washington DC) for postgraduate studies, receiving an LLM in international law. He is a certified tax advisor (steuerberater).

Kurfuerstendamm 23 Neues Kranzler Eck

Berlin, 10719

Germany

Tel: +49 30 2546 8116

Email: mmassbaum@deloitte.de

Website: www.deloitte.com

Michael Maßbaum is a tax partner in the tax and legal practice of Deloitte Germany and has more than 23 years of experience serving national and multinational clients. He is leader of the private company services tax service line and is experienced in tax structuring and tax controversy work.

Michael has a wide industry expertise including 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.

Georgstrasse 52

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hramcke@deloitte.de

Website: www.deloittelegal.de

Heiko Ramcke is a partner of Deloitte Legal and the leader of the criminal tax law team for Deloitte Germany. Heiko has many years of experience in criminal tax law. He joined Deloitte Legal in 2001.

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 organisations as well as the management of national medium size 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.

Georgstrasse 52

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hstang@deloitte.de

Website: www.deloittelegal.de

Harald Stang is an attorney-at-law, tax consultant and partner at Deloitte Legal. 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 respect 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 worked as an assistant auditor with a medium size firm of auditors and tax consultants.

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

Alexander Voegele has more than 25 years of experience in transfer pricing. He has led hundreds of transfer pricing projects and provided economic advice on numerous defence cases for a variety of clients in a wide range of industries. His experience includes negotiating a multitude of mutual agreement procedures and arbitration cases.

He edits the leading German handbook on transfer pricing and is repeatedly listed among the 'Best of the Best' transfer pricing advisers by International Tax Review and Euromoney.

Before taking his position as chairman of the advisory board with NERA Frankfurt, he was a partner with both PwC and KPMG.

Voegele is a certified German and French auditor and a German tax adviser and holds a doctoral degree in economics and a master's degree in tax from the University of Mannheim (Germany).