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Portugal

16 August 2017

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Jaime Carvalho Esteves

PwC Portugal

Palácio Sottomayor
Rua Sousa Martins 1, 2º
1069-316 Lisbon
Portugal

Tel: +351 213 599 601
Email: jaime.esteves@pt.pwc.com
Website: www.pwc.com/pt

Jaime Carvalho Esteves is a partner of PwC Portugal and is PwC Angola, Cape Verde and Portugal head of tax. He is PwC's government and public sector leader and is an arbitrator at the Portuguese Court of Tax Arbitration (CAAD), being regularly involved in decisions in tax matters. He is a member of the governing board of the Forum for Competitiveness (Forum para a Competitividade).

During his career, he was partner of two prestigious law firms, being in charge of the Epson (STA) and Norvalor (STA) cases.

He is a specialist in national and international tax planning (both individual and corporate), transfer pricing, mergers and acquisitions, corporate reorganisations, high-net-worth individuals and family business, including family offices.

He has significant experience in the areas of oil and gas, automotive, civil construction and public works, retail, hospitality and leisure, industrial and consumer products, real estate, services and telecommunications.

Jaime teaches tax matters at several universities in Portugal (IPCA, ISAG, PBS, Católica Lisbon, and Católica Oporto) and participates regularly as a speaker in several courses, seminars and conferences, both domestically and internationally, dealing with subjects such as foreign investment and public policy as well as tax topics. He also collaborates regularly with several television stations, radio broadcasters and periodicals on the same topics.

During his career, Jaime has been awarded several prizes, granted by relevant entities in the field of taxation.

Jaime has written numerous articles and published several studies including: "Notes about the Epson Case" in Court Decisions, Almedina; "Partial Amortization of Shares without share capital reduction" and "Harmonization of Direct Taxation and the Gift and Inheritance Tax" in Fisco n 46 of 1992 and n 72/73 of 1995; "The Relevance of TNMM in Transfer Pricing", AAVV, Vida Económica, September of 2006; "Portugal" in The Determination of Corporate Taxable Income in the Member States, Kluwer Law International, 2007; "Budget Act Proposal 2009" in Practical European Tax Strategies (Vol. 10, In. 10 – Portugal); "Effective taxation of distributed profits", "Dealings" and "Profits and losses arising from mergers and spin-offs", respectively Minutes of the I, II and III Tax Congress of the Law Faculty of the Oporto University (2011, 2012, 2013); "Fat Capitalization" in Studies in Tribute to Professor Saldanha Sanches (2012) and "Permanent establishments and business conversions" in TP Studies (2013); co-authorship with Rosa Areias of CIT – Practice Notes; Resolving International Tax Disputes: The Emerging Role of Arbitration and the Portuguese Example, co-authorship with C David Swenson and Crystal A Thorpe, in The Portuguese Tax Arbitration Regime, of 2015, Almedina, CAAD.


Tânia Rodrigues

Deloitte Portugal

Av. Eng. Duarte Pacheco, 7
1070-100 Lisbon
Portugal

Tel: +351 210 427 660
Email: tarodrigues@deloitte.pt
Website: www.deloitte.com

Tânia Rodrigues, Deloitte Portugal, is a senior manager in the Portugal Office and has more than 16 years of experience within Deloitte as a tax and transfer pricing controversy specialist.

Tânia has extensive experience in multi-jurisdictional international tax and transfer pricing projects for multinational groups, ranging from global business reorganisations, contemporaneous documentation engagements, risk review in the BEPS context, intellectual property (IP) tax planning, controversy and audit defence, such as assistance on administrative claims and in arbitration convention disputes. Tânia's controversy cases included, among others:

  • Assistance in arbitration convention disputes, including the preparation of documentation and support in transfer pricing adjustments;
  • Support in disputes involving permanent establishment (PE) structures and results (allocation of profits and costs);
  • Participation in a state aid process as technical adviser, presenting economic analysis and data with a view to demonstrate the economic rationality of the transactions;
  • Preparation, support and negotiation follow-up between taxpayers and Portuguese tax authorities on the context of cost sharing agreements;
  • Support in tax audits regarding pricing of financial transactions (equity versus debt) and intercompany services, where technical arguments were presented in order to demonstrate compliance of such transactions with the arm's-length principle;
  • Support in an administrative claim regarding self-initiated transfer pricing adjustments, in cases where a Portuguese branch performed a self-initiated negative transfer pricing adjustment to reflect the arm's-length pricing of a controlled transaction;
  • Assistance on indirect methods process/appeals, especially using transfer pricing methodologies for determination of the taxable profit; and
  • Assistance in hierarchical appeals, where technical arguments were presented in order to demonstrate compliance of different group transactions following the arm's-length principle.

Tânia is also experienced across a wide range of industries including energy and resources, communications, infrastructure, technology, financial services and other highly regulated markets.

Tânia was a lawyer and also teacher in the Law School.

She graduated in law from the Lisbon Law School (FDL) and obtained her LLM in international economic law from Warwick University (UK).


Leendert Verschoor

PwC Portugal

Palácio Sottomayor
Rua Sousa Martins 1, 2º
1069-316 Lisbon
Portugal

Tel: +351 213 599 631
Email: leendert.verschoor@pt.pwc.com
Website: www.pwc.com/pt

Leendert Verschoor is a tax and transfer pricing partner of PwC Portugal, Angola and Cape Verde. He leads the PwC transfer pricing services group in Portugal, Angola and Cape Verde and is representing Portugal within PwC's global transfer pricing network.

He started his professional activity in the area of taxation in the Netherlands. In 1999, he joined PwC in Portugal and became partner in 2008. He specialises in areas related to international taxation of multinational companies, with 24 years of experience in these matters. Since 2002, he devotes part of his time advising Portuguese subsidiaries of multinational groups and national groups with international presence in various sectors of activity with transfer pricing planning and transfer pricing documentation obligations. He has been involved in several restructuring projects of multinational companies in the Portuguese market, advance pricing agreement projects and transfer pricing defence work following audits conducted by Portuguese tax authorities.

He is responsible since 2007 for the tax services rendered by PwC in Cape Verde.

Leendert has a degree in business economics from Erasmus University Rotterdam and a degree in tax law from the University of Leiden, both in the Netherlands.

He is the author of the country section on Portuguese transfer pricing rules in the book International Transfer Pricing, of the Portuguese section in the book Mastering the IP Life Cycle and the book Substance, Aligning international tax planning with today's business realities, and wrote various articles about transfer pricing in economic newspapers and the International Transfer Pricing Journal. He wrote an article in Cadernos Preços de Transferência 2013, Almedina; on "Changes in the business model and permanent establishments".

Leendert lectures at the post-academic tax education at the Faculty of Law of the Catholic University in Lisbon on transfer pricing matters. He regularly participates as a speaker in several (training) courses, seminars and conferences.


Gustavo Amaral
KPMG

Antonio Américo Coelho
KPMG

Frederico Antas
Vieira de Almeida

Rosa Areias
PwC

Ana Isabel Batista
Garrigues, Taxand Portugal

Catarina Belim
Belim Legal Services

Bruno Botelho Antunes
Ricardo da Palma Borges & Associados

António Pedro Braga
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Pedro Braz
Garrigues, Taxand Portugal

Serena Cabrita Neto
PLMJ

Susana Caetano
PwC

António Castro Caldas
Uría Menéndez-Proença Carvalho

José Calejo Guerra
JCG Advogados

Diogo Tavares Castro
PwC

Francisco Castro Guedes
PLMJ

Fernando Castro Silva
Garrigues, Taxand Portugal

Susana Claro
PwC

Francisco de Sousa da Câmara
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Patrick Dewerbe
CMS Rui Pena & Arnaut

Clara Madalena Dithmer
PwC

Rodrigo Rabeca Domingues
PwC

Ana Duarte
PwC

Susana Duarte
Abreu Advogados

João Espanha
Espanha e Associados

Samuel Fernandes de Almeida
Vieira de Almeida

Rogério Fernandes Ferreira
Rogerio Fernandes Ferreira & Associados

Isabel Santos Fidalgo
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Filipa Figueiredo
Garrigues, Taxand Portugal

Jorge Figueiredo
PwC

João Taborda da Gama
Gama Glória

Conceição Gamito
Vieira de Almeida

Nuno de Oliveira Garcia
Andersen Tax & Legal

Francisco Geraldes Simões
Galhardo Vilão Torres

Catarina Goncalves
PwC

André Gonçalves
Telles de Abreu Advogados

Maria Gouveia
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Mariana Gouveia de Oliveira
Miranda & Associados

Joana Lobato Heitor
Vieira de Almeida

Joaquim Pedro Lampreia
Vieira de Almeida

Patrícia Meneses Leirião
CRBA

Gonçalo Leite de Campos
Gonçalo Leite de Campos & Associados

Antonio Lobo Xavier
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Marta Machado de Almeida
Rogerio Fernandes Ferreira & Associados

Luis Magalhaes
KPMG

Rita Magalhães
Vieira de Almeida

Leonardo Marques dos Santos
Gama Glória

Tiago Marreiros Moreira
Vieira de Almeida

Alexandra Martins
KPMG

Elsa Silva Martins
PwC

Francisco Cabral Matos
Vieira de Almeida

José Pedroso de Melo
SRS Advogados

Antonio Rocha Mendes
Campos Ferreira, Sa Carneiro

Paulo Mendonça
EY

João Maricoto Monteiro
SRS Advogados

Ricardo Seabra Moura
Vieira de Almeida

Ana Moutinho Nascimento
Servulo

Paulo Núncio
Morais Leitão, Galvão Teles, Soares da Silva & Associados

Diogo Ortigão Ramos
Cuatrecasas

Ana Rita Pereira
Ricardo da Palma Borges & Associados

Ricardo Pereira
Ricardo Pereira Reigada

Antonio Moura Portugal
DLA Piper

Ana Reis
PwC

Miguel C Reis
PLMJ

Cláudia Reis Duarte
Uría Menéndez-Proença Carvalho

João Riscado Rapoula
Vieira de Almeida

Filipe Romão
Uría Menéndez-Proença Carvalho

Hugo Salgueirinho Maia
PwC

Adrião Silva
PwC

Joana Tavares de Oliveira
Garrigues, Taxand Portugal

Miguel Teixeira de Abreu
Abreu Advogados

Ana Teresa Tiago
DLA Piper

Maria Antónia Torres
PwC

Miguel Torres
Telles de Abreu Advogados






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