Netherlands

Deloitte Netherlands

Gustav Mahlerlaan 2970

NL-1081 LA

Amsterdam

The Netherlands

Tel: +31 (0)88 2886857

Fax: +31 (0)88 2889758

Email: fbarnard@deloitte.com

Website: www.deloitte.com

Frits Barnard is an international tax partner in the Amsterdam office of Deloitte Netherlands. He specialises in international corporate tax, controversy and tax litigation.

Frits became a partner with a Big 4 professional services organisation in 1993 and Deloitte in 2002.

Frits has been responsible for international mergers and acquisitions and re-leverage and corporate tax reduction programmes, mainly for Dutch, UK and US multinationals. He developed structures aimed at income repatriation and demerging international business units.

Frits has substantial experience in handling tax audits, conducting negotiations with Dutch revenue authorities, and tax litigation. In the latter capacity he has handled a number of benchmark Supreme Court cases. He has also (re)negotiated a number of rulings for large multinationals on their Dutch tax base, for example on the allocation of income on the basis of informal capital concepts.

Presently his role is to act as a trouble-shooter in a variety of situations where clients of Deloitte Netherlands need assistance with dispute resolution. Experience teaches that addressing a dispute often leads to opportunities to improve the tax position.

Frits has contributed to a number of articles on the valuation of financial products for tax purposes.

He is a graduate of Leiden University (1983) and holds a master's degree in tax law.

Mazars Netherlands

Mazars Building

Rivium Promenade 200

Capelle aan den IJssel

PO Box 23123

3001 KC Rotterdam

Netherlands

Tel: +31 88 2771627

Mob: +31 6 15092532

Email: frank.herreveld@mazars.nl

Website: www.mazars.nl

Frank Herreveld is the Mazars Netherlands tax controversy and litigation leader. Frank has comprehensive and extensive experience in tax litigation and dealing with complex national and international tax controversies.

Before joining Mazars in April 2015, Frank was Deloitte's tax controversy leader. Before that he was attorney and international partner with Baker & McKenzie in Amsterdam. Frank also has broad experience as a tax inspector and worked at the Supreme Court in The Netherlands. Frank is a guest lecturer at the Universities of Leiden and Maastricht.

Frank focuses on corporate income tax, strategic tax advice, international tax planning for high net wealth families, revenue audits, tax disputes and litigation and tax opinions. Recent engagements include matters relative to international finance structuring, legal obligations of taxpayers, deductibility of cost and high level pension advice, among others. He regularly renders advice and second opinions not only to clients but also to other tax advisers. Frank has been involved in several opinions on finance structures and formal tax issues.

Frank serves multinational organisations, as well as large family enterprises, shipping and oil companies, and law firms. Frank is consulted on a regular basis by both the Dutch Parliament and the judiciary.

Frank is a long-standing member of the editorial board of Weekblad Fiscaal Recht, the leading professional tax magazine in The Netherlands and has published several articles on litigation, due diligence and pensions. He is chairman of the NOB (Dutch Organisation of Tax Lawyers) courses on litigation, assistant professor at the Universities of Leiden and Maastricht and a regular speaker on seminars and round tables with tax advisors, tax inspectors and judges.

Frank earned an LLM in taxation from Leiden University (1976-1981).

Deloitte Netherlands

Orlyplein 10

1043 DP Amsterdam

Netherlands

Tel: +31 88 288 1992

Mobile: +31 6 5151 6811

Email: jhollebeek@deloitte.nl

Johan Hollebeek is a tax partner with Deloitte Netherlands' customs and global trade service line. He has been with Deloitte Netherlands since 2002. Before joining Deloitte, Johan was with Arthur Andersen for four years.

Johan specialises in customs duties, VAT and excise duties. Johan's practices focuses on customs valuation, tariff classification matters and processing regimes. Johan uses mediation techniques to resolve disputes at an early stage but also has extensive experience in litigation before Dutch and EU courts on customs duties, VAT and excise duty related matters. He is also a member of the customs working group of VNO-NCW (The Confederation of Netherlands Industry and Employers). Johan is a permanent contributor to the journal Douanerechtspraak (customs jurisprudence).

Johan is a graduate of Leiden University (indirect taxation) and also completed a post-graduate course in appropriate dispute resolution at the Amsterdam ADR Institute.

Deloitte Netherlands

Orlyplein 10

1043 DP Amsterdam

Netherlands

Tel: +31 882884614

Mob: +31 650507849

Fax : +31 88 288 9763

Email: pschrijver@deloitte.nl

Pascal Schrijver, Deloitte Netherlands, is an indirect tax partner and leader of the DTTL Technology, Media and Telecommunications (TMT)/Indirect Tax industry group.

Pascal advises domestic and foreign clients operating in the TMT industry on indirect tax aspects of business transactions, compliance issues and mergers and acquisitions. Over the last 17 years Pascal has been involved in many restructuring projects for operators and technology equipment manufacturers, online gaming companies and various content providers, among others.

Pascal holds a degree in tax law from University Groningen and is a board member of the indirect tax department of the Dutch association of Tax Lawyers. Pascal also lectures on VAT at University of Leiden, the Netherlands.

PwC

Thomas R Malthusstreet 5

1066 JR, Amsterdam

The Netherlands

Tel: +31 88 792 6763

Email: stef.van.weeghel@nl.pwc.com

Website: pwc.com/taxcontroversy

Stef van Weeghel is a tax partner with PwC Netherlands. Stef is PwC's global tax policy leader as well as member (and former chairman) of the Dutch AEX-Midkap Group. He is also professor of international tax law at the University of Amsterdam.

Stef's primary focus is on tax policy and his practice includes strategic tax advice and tax controversy. He was involved in major international transactions, structuring and tax controversy/litigation. He regularly renders advice and second opinions to clients and to other advisers, on corporate income tax and tax treaty matters and is also consulted by the Dutch government on a regular basis. On several occasions he has acted as expert witness in tax matters before Dutch and foreign courts and in BIT-arbitration.

Stef graduated from the University of Leiden in business law (1983) and tax law (1987) and obtained an LLM in taxation from New York University in 1990. In 1997 he received a doctorate in law from the University of Amsterdam (PhD thesis: 'Improper Use of Tax Treaties'); he was admitted to the Amsterdam Bar in 1987. In 2000 he was appointed as tenured professor of international tax law at the University of Amsterdam. He authored and co-authored several books and numerous articles on Dutch and international taxation and has lectured extensively in the Netherlands and internationally.

Before joining PwC, Stef was a partner at Linklaters (2007-2009) and a partner at Stibbe (1992-2007) where his roles included membership of the executive committee, head of tax and resident partner in the New York office.

He is a former chairman of the Dutch branch of the International Fiscal Association, and now chairman of IFA's Permanent Scientific Committee and chairman of the board of trustees of the International Bureau for Fiscal Documentation. In 2010 he was the general reporter for Subject 1 (Tax treaties and tax avoidance: Application of anti-avoidance provisions) at the IFA Congress in Rome.

In 2009 Stef was appointed by the Minister and Secretary of Finance as chairman of the Study Group Tax System, a committee that advised the Dutch government on comprehensive tax reform in 2010. In 2000 he was a member of the Van Rooy-Committee that advised the Dutch government on corporate income tax reform.

PwC Netherlands

Thomas R Malthusstraat 5

1066 JR

PO Box 90351

1006 BJ

Amsterdam

The Netherlands

Tel: +31 (0) 88 792 6577

Email: edwin.visser@nl.pwc.com

Website: pwc.com/taxcontroversy

Edwin has been a tax partner at PwC Netherlands since January 1 2015.He is the tax policy leader for the EMEA region, a member of the global tax policy core team, and leader of PwC's tax controversy and dispute resolution network for the Netherlands. He is based in the AEX-team in Amsterdam.

Edwin's practice includes boardroom consulting, strategic tax advice, tax controversy, tax administration consulting and representing PwC in tax policy matters.

Edwin graduated from Tilburg University in 1995. He is member of the editorial board of a renowned tax encyclopaedia in the Netherlands, author of a handbook on transfer pricing (published in 2005), and co-author of the Netherlands report to the IFA in 2007 on the treatment of intangibles. He has a broad experience in teaching (LLM in international tTaxation at Leiden University, IBFD and the Tax Assurance Academy at Nyenrode Business University)

Before joining PwC he was deputy director-general for tax and customs policy and legislation and director for direct taxes at the Dutch Ministry of Finance. He represented the Netherlands in the Bureau of the OECD's Committee on Fiscal Affairs from 2012 through 2014 and he co-chaired the OECD's informal task force on tax and development between 2010 and 2014.

Edwin was director for international tax policy and legislation from January 1 2009 to March 1 2012. In that capacity he also acted as competent authority. From 2004 through 2008 he was responsible for a coordination of the treatment of the 2000 largest companies in the Netherlands by the Netherlands' Tax and Customs Administration (NTCA). The main challenge was the implementation of the cooperative compliance approach. From 2000 to 2004 he was head of the transfer pricing division of the Dutch tax administration and in that capacity he was involved in many mutual agreement procedures.

PwC

Fascinatio Boulevard 350

3065 WB, Postbus 8800

3009 AV Rotterdam?

Netherlands

Tel: + 31 (0) 88 79 25 038

Mobile: + 31 (0) 6 13 48 12 42

Email: eric.vroemen@nl.pwc.com

Website: pwc.com/taxcontroversy

Eric Vroemen is a partner in PwC's Dutch tax and human resource services (HRS) practice with more than 20 years of relevant experience. He is specialised in transfer pricing.

From 1989 until 1996, Eric worked with the Dutch tax authorities as a state auditor and between 1996 and 2010, he worked with Deloitte in the Netherlands. In 2001, he was seconded to New York, and from 2003 until 2006 he was located in Chicago as the managing partner of Deloite's Dutch desks. He moved to PwC in November 2010. Since 1999, Eric has focused on transfer pricing and business restructurings, and was involved in planning and controversy management for a large number of well-known and complex multinationals. As such, Eric has obtained an in-depth understanding of business operations in a wide variety of industries as well as being familiar with the tax systems and the methods of working of the tax administrations and competent authorities in the main economies.

Eric is a frequent speaker on transfer pricing and a guest lecturer at the Leiden University, the IBFD and PwC Tax Academy.