Spain

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 4609

Email: miguel.cruz@es.pwc.com

Website: pwc.com/taxcontroversy

Miguel Cruz got his degree in law from the Complutense University of Madrid and holds a diploma in community law awarded by the Constitutional Study Centre.

He is a member of the State Treasury Inspectors, of the Ministry of Economy and Finance (on extended leave of absence), was appointed as the taxation general director of the Ministry of Economy and Finance and as general director of the Cabinet of the Ministry of Public Works, Transport and Environment.

Today he is an associate professor at the Spanish Open University (UNED).

He has taken part in numerous courses, congresses, conferences and discussion groups intended to increase knowledge of tax affairs, and he frequently writes in specialised reviews and publications.

Miguel Cruz has been national tax director at PwC since June 1996 and is a partner of PwC Tax & Legal Services in Spain.

In the present, Miguel works for priority accounts of PwC Spain as a tax senior consultant or as a tax litigation lawyer. Telefonica, Nestle, BBVA and Banco Santander are some of his principal clients.

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 542

Email: javier.gonzalez.carcedo@es.pwc.com

Website: pwc.com/taxcontroversy

Javier González Carcedo joined PwC at the beginning of 2006 as the national leader of PwC Spain's transfer pricing group.

Javier is qualified in economic sciences, business studies and law and is a member of the body of National Finance Inspectors in Spain.

Between 2000 and 2003, he was coordinator of international taxation within the General Directorate for Taxation at the Ministry of Finance, which is the competent authority for international tax matters in Spain. In 2003, he joined the cabinet of the Secretary of State for Finance.

In May 2004, he joined the OECD in Paris as adviser for the Centre for Tax Policy and Administration, with competences in tax treaties, transfer pricing and relations with non-member countries of the OECD. During his time with the OECD, he worked extensively in coordination of the proceedings with the different Latin American tax administrations and the Inter-American Tax Administration Centre.

Javier is a partner of PwC Tax & Legal Services and in his experience with the firm, he has focused on transfer pricing planning and documentation services as well as all kinds of dispute resolution procedures involving the Spanish tax administration, including audits, advance pricing agreements and mutual agreement procedures.

Av Diagonal 654

Barcelona 08034

Spain

Tel: + 34 932304848 ext 3960

Email: jpelegay@deloitte.es

Javier Pelegay is a Deloitte Spain tax partner based in the Barcelona office. He joined Deloitte in 2000 and has more than 20 years of experience in tax services. In 2012, he was promoted to the position of global managing director – tax controversy management, Deloitte Touche Tohmatsu Ltd.

Javier possesses wide-ranging experience serving international clients and their subsidiaries in the Catalonian region, including tax due diligence services. Although his experience covers a wide range of sectors and industries, he has mainly focused in the automotive, pharmaceutical and chemical sectors which are very prominent in the Barcelona area.

He has extensive specialisation in inbound investments for both US and EU countries, local and international restructuring engagements, and due diligence and tax planning acquisition engagements.

Important clients include Henkel, Ralston, Johnson Control, Brose, ArvinMeritor, Lear Corporation, Honda, Almirall Prodesfarma, Laboratorios Ferrer, Novartis, ICI, Dade Behring, Lundbeck, Bayer and Solvay.

Javier holds a law degree from Universidad de Barcelona and a master's degree in taxation from Abad Oliba, Barcelona.

He has been a member of the Barcelona Bar Association since 1986 as well as an elected member of the tax commission. In addition, he is a member of the editorial board of the publication Fiscal al Día and a member of the Spanish Tax Association.

Paseo de la Castellana 259 B

28046 – Madrid

Spain

Tel: +34 91 568 45 41

Email: antonio.puentes@es.pwc.com

Website: pwc.com/taxcontroversy

Antonio Puentes is partner at PwC Tax & Legal Services in Madrid.

Antonio joined PwC in early 1999 after two years working in a medium size Spanish law firm. He has a degree in law and two postgraduate courses, one development programme in tax controversy and dispute resolution, and one master's degree in taxation.

Antonio has been a member of Madrid's Bar Association since 1997, and having worked in PwC´s tax controversy and dispute resolution (TCDR) department since arriving at the firm, he now leads the Spanish TCDR practice, embedded in PwC's TCDR network, which includes more than 650 tax controversy professionals, located in more than 45 countries worldwide.

Antonio's experience involves all areas of tax controversy issues: international, state, regional and local tax.

Since 2005 he has also been involved in more than 100 projects with PwC´s European direct tax group, working together with PwC´s global tax solutions and transfer pricing networks, assisting clients who are proactively defending the refund of taxes paid in breach of EU law.

He has broad experience in giving assistance in tax audit, tax litigation and judicial proceedings from a domestic and international point of view throughout the complete controversy lifecycle.

He has published articles on tax controversy and dispute resolution issues as well as collaborating in the preparation of some academic books in the area. Antonio also regularly lectures on several programmes in the TCDR area in prestigious Spanish universities such as Complutense and San Pablo-CEU.

Plaza Pablo Ruiz Picasso, 1

Madrid 28020

Spain

Tel: +34 915820900; ext 1662

Email: apuig@deloitte.es

Alejandra Puig is a lawyer and member of the Madrid Bar association. She specialises in representing clients before the Spanish tax authorities and in coordinating complex tax audits for multinational corporations. Alejandra also has significant experience in handling the negotiation of complex tax disputes.

Alejandra regularly represents clients at all stages of the dispute process, including litigation before the Spanish Supreme Court, and of supporting and negotiating settlements.

She helps clients to efficiently resolve their tax disputes, assisting the negotiation of favourable settlements with the tax authorities or, when necessary, bringing appeals to the courts.

For more than 20 years, Alejandra has represented clients in a variety of industries, including financial services, manufacturing, pharmaceuticals, consumer products, media, and retail.

Alejandra also has significant experience in Spanish penalty procedures and has spoken and written extensively on numerous Spanish procedural issues.

Alejandra has a master's degree in European law from Granada University and she is a professor in several Spanish master's programmes for new tax lawyers.