Argentina

Peron 646, 2nd floor

C1038 AAN

Buenos Aires

Argentina

Tel: +54 11 4320 2700 ext. 2145/3003

Fax: +54 11 4320 4071

Email: dcaracciolo@deloitte.com

Daniel Caracciolo is a Deloitte Argentina tax partner with more than 23 years of experience serving multinational clients. He leads the Deloitte Argentina international tax group and is a member of the tax controversy group. Before joining Deloitte in 2002 he worked for Arthur Andersen.

Daniel has developed extensive experience in corporate and international tax matters and has been leading and assisting clients relative to tax controversy cases. He serves clients working in the consumer business, oil and gas and financial services industries.

Daniel has been recognised as a leading tax adviser by specialist international publications such as International Tax Review and Practical Law. He is a regular lecturer at business institutions and professional entities. Additionally, Daniel has taught at the School of Economic Sciences at the University of Buenos Aires and at the Di Tella University.

Daniel speaks fluent Spanish, English and Portuguese.

Bouchard 557

C1106ABG – Ciudad de Buenos Aires

Argentina

Tel: (54-11) 4850-6728

Email: eduardo.gil.roca@ar.pwc.com

Website: pwc.com/taxcontroversy

Eduardo is a public accountant who graduated from Universidad de Belgrano in 1992 and he obtained a law degree from Universidad de Buenos Aires in 1996.

He joined PwC in 1993. In 2008 he was appointed as partner in charge of the tax and legal department of PwC.

He has taken postgraduate courses in law and economics at the Universidad de Buenos Aires and in tax criminal law at the Instituto de Estudios Fiscales in Madrid.

Eduardo is the head professor of Universidad de Ciencias Empresariales y Sociales (UCES), as well as in Universidad de Belgrano, and is a member of the Argentine Association of Tax Studies.

He has written several articles in local and international media on tax issues. He is a permanent lecturer in the training sessions on tax professional practice, organised by the Professional Council in Economic Sciences, and in courses organised by PwC.

He has led the tax litigation practice of PwC Argentina since 2008.

Eduardo has broad experience in the design and management of legal strategies for highly complex tax cases and has acted in many leading cases at the Argentine Supreme Court of Justice and the Tax Court. The cases resolved by the Supreme Court include: tax deductions of tax assessments (Scania Argentina), deductions of bad debts (BBVA Banco Francés), VAT on interest on the purchase of shares (Chryse), tax exemptions for welfare organisations (Fundación Perez Companc), and tax-free reorganisations (International Engines), among others.

The cases resolved by the Tax Court include: deduction of interest on loans (Swift), transfer pricing relating to financial transactions (Ericsson), and transfer pricing relating to exports (Laboratorios Bago, Nobleza Piccardo and Toyota), among others.

Florida 234 Piso 5°

C1005AAF

Buenos Aires

Argentina

Tel: +54 (11) 4320 2700 ext. 2145

Fax: +54 (11) 4325 8081

Email: ptonina@deloitte.com

Pablo Tonina is a tax partner with Deloitte Argentina in the Buenos Aires office. He has more than 27 years of experience serving multinationals and major local companies and financial institutions.

Pablo has developed extensive experience in corporate, international and tax controversy issues and serves as the lead tax partner for large consumer, manufacturing, technology and financial services industry clients. He is also responsible for the Latin American coordination of tax services for several of Deloitte's global strategic clients. Pablo joined Deloitte in 2002 as a partner in the tax area.

His clients include BBVA Banco Frances, Bank Boston NA, ICBC Argentina, Bank of America NA, Acindar (Arcelor Mittal), GE Money, Toyota Industries, IBM Argentina, Lenovo and Cervecería y Malteria Quilmes (AB-Inbev).

Since 2000, Pablo has been consistently listed among the leading tax advisers in Argentina by various market surveys, including those undertaken by International Tax Review and Euromoney. He is a regular lecturer at business institutions, universities, and professional entities on different tax matters and has also written several articles for local and international publications.

Pablo is a certified public accountant and graduated from the School of Economics, Argentine Catholic University. He is also a member of the International Fiscal Association, the Argentine Tax Association and the International Tax Association.