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Denmark

Peter Bjare

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KPMG Acor Tax

Copenhagen

+45 5374 7025

peter.bjare@kpmg.com

www.kpmgacor.dk

Peter Bjare is a tax partner at KPMG Acor Tax and has worked with KPMG for more than 25 years.

He has long experience in advising clients on all Danish and international corporate tax aspects, including mergers, acquisitions, disposals and corporate restructuring and reorganizations. He is recognised as a leading expert in conducting tax cases before the Danish National Tax Tribunal and other administrative authorities.

Among these cases, he is particularly acknowledged for his persistent defence of the deductibility of expenses incurred in connection with business expansions and raising of loan capital, areas that have been challenged by the tax authorities in recent years.

Peter's long experience has provided him with the expertise of coordinating and understanding the interaction of multiple disciplines (corporate tax, individual tax, VAT, transfer pricing, etc.).

His experience as the lead tax partner for large Danish multinational clients has also provided him with an ability to understand the business strategy and related needs. For several years, Peter has been teaching on master of tax, etc. and is the author of a number of newspaper and journal articles.

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Johnny Bøgebjerg

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KPMG Acor Tax

Copenhagen

+45 5374 7090

johnny.bogebjerg@kpmg.com

www.kpmgacor.dk

Johnny Bøgebjerg is a senior Transfer Pricing Director within KPMG Acor Tax's controversy and dispute resolution practice. Johnny is a member of KPMG's global tax controversy team and has a leading role in Denmark embracing the post BEPS improvement of dispute resolution practices.

Johnny joined KPMG Acor Tax in 2015 and his background includes a 10-year managerial role as special adviser to the Danish competent authority being responsible for high-priority cases and development of the Danish tax authorities' transfer pricing practice. In this role, Johnny was the Danish delegate involved in the development of new guidance related to the interpretation of the arm's length principle (OECD's Working Party 6).

In addition, Johnny has industry experience working as an in-house special transfer pricing dispute resolution adviser for the group.

Johnny is an expert in dispute resolution and alternative dispute resolution. He leverages his unique insight in tax audits, litigation and competent authority MAP/APA strategies and processes seen from the perspective of all relevant stakeholders.

Johnny has played an active role in many of the major tax controversies in Denmark.

As a former special adviser to the Danish Competent Authority for more than ten years, Johnny has a strong understanding of Danish policy and practices, and experience at assisting clients and taxpayers achieve the best possible outcomes in negotiations with tax authorities in Denmark and Japan, China, US, Australia, Netherlands, UK, Germany, the Nordic area etc.

As such, Johnny was involved in high priority cases like the landmark APA between Denmark and Japan as well as the first APA between China and Denmark.

Johnny lectures on advanced transfer pricing at the master in tax education at Copenhagen Business School (CBS).

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Henrik Lund

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KPMG Acor Tax

Copenhagen

+45 5374 7066

henrik.lund@kpmg.com

www.kpmgacor.dk

Henrik Lund joined KPMG's tax department in 2001 and was promoted to partner in 2009. He has been part of KPMG's global transfer pricing services network since 2001. Henrik has worked at KPMG London and spent three years at KPMG Meijburg in the Netherlands.

Henrik originally established KPMG Denmark's transfer pricing audit task force. For the past 10 years, the task force has been focusing on assisting clients in dispute management and resolution, controversy and strategic handling of processes connected with international tax and transfer pricing audits. Henrik has also been involved in negotiating numerous tax cases, mutual agreement procedures (MAPs) and advance pricing agreements (APAs), and it should be noted that KPMG has been the leading tax provider in many of the MAPs and APAs involving the Danish competent authority. Most recently, Henrik was an advisor to the taxpayer in the first Danish landmark transfer pricing case, which was ruled by The Eastern High Court (Østre Landsret). The court ruled entirely in favor of the taxpayer.

Henrik's client relationships include multinational clients in different industries focusing mainly on global transfer pricing dispute management and controversy, including MAPs, APAs and litigation, but also value chain and planning analysis.

Henrik features as a lecturer and speaker on numerous tax and transfer pricing conferences and seminars in Denmark and abroad, and he has established a separate transfer pricing module as part of a master in tax education at the Copenhagen Business School.

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Martin Nielsen

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Partner

KPMG Acor Tax

Copenhagen

+45 5374 7055

martin.nielsen@kpmg.com

www.kpmgacor.dk

Martin Nielsen joined KPMG's tax department in 1997 and was promoted to partner in 2007. Martin has an effective and valuable network of relationships in the KPMG Global Tax Dispute Resolution & Controversy Network – and has been seconded to KPMG's London-based transfer pricing resource center.

Martin is a tax partner with a focus on transfer pricing and more than 20 years of experience from cross-border work with multinational clients in different industries. Working with both transfer pricing and international corporate tax, Martin has experience providing cross-functional solutions on cross-border business structures and supply chains.

Having worked on transfer pricing for multinationals for many years, he has extensive dispute resolution experience from successfully handling large transfer pricing audits on business restructurings, multi-country mutual agreement procedures (MAPs), bilateral advance pricing agreements (APAs) and large cases with the Danish National Tax Tribunal.

Martin is an external associate professor of transfer pricing for the Master in Tax degree course at Copenhagen Business School.

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Jakob Skaadstrup Andersen

Gorrissen Federspiel

Stine Andersen

Kromann Reumert

Kaspar Bastian

Bech-Bruun

Peter Rose Bjare

KPMG Acor Tax

Nikolaj Bjørnholm

Bjørnholm Law

Johnny Bøgebjerg

KPMG Acor Tax

Lena Engdahl

PwC

Anders Oreby Hansen

Bech-Bruun

Hans Severin Hansen

Plesner

Lida Hulgaard

Hulgaard Advokater

Tom Kári Kristjánsson

Plesner

Henrik Lund

KPMG Acor Tax

Martin Nielsen

KPMG Acor Tax

Søren Lehmann Nielsen

Bruun & Hjejle

Arne Møllin Ottosen

Kromann Reumert

Arne Riis

Accura

Michael Serup

Bech-Bruun

Eduardo Vistisen

Vistisen Tax Attorneys

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