Argentina

Bouchard 557

C1106ABG, Buenos Aires

Argentina

Tel: +54 11 4850 6712

Fax: +54 11 4850 6100

Email: juan.carlos.ferreiro@ar.pwc.com

Website: pwc.com/taxcontroversy

Juan Carlos Ferreiro is a PwC partner within the transfer pricing group based in Buenos Aires. He is the regional leader for the PwC transfer pricing group in South America, involved in projects in Brazil, the US, Mexico, Spain, Colombia, Ecuador, Chile and Uruguay.

Juan Carlos became a PwC partner in 2005. Among his clients you will find the most significant Argentine exporters both for agricultural or petrochemical industries. He also advises a broad range of clients in industries including telecommunications, automotive, pharma, retail and manufacturing.

Many of these sectors have been heavily audited by the Argentine tax authorities on transfer pricing issues. His experience includes dispute processes within the administrative stage (negotiating settlements or preparing for next stages) or discussions with the National Tax Court, where he also was designated as an expert witness for disputes involving the pharma and automotive industries.

He graduated as a certified public accountant (CPA) from the University of Buenos Aires. He has frequently lectured and participated in several courses and seminars on tax subjects organised by public and private professional organisations, both in Argentina as well as abroad.

He has authored different articles on this specialty, which have been published in business newspapers and technical publications in several countries. He also acts as the vice-president of the International Tax and Transfer Pricing Commission within the Professional Association of Certified Accountants in Buenos Aires.

Bouchard 557

C1106ABG – City of Buenos Aires

Argentina

Tel: +54 11 4850-6728

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

Website: pwc.com/taxcontroversy

He is lawyer graduated from Universidad de Buenos Aires (1996) and a public accountant graduated from Universidad de Belgrano (1992). He joined the firm in 1993. In 2008 he was appointed as partner in charge of the tax and legal department of PricewaterhouseCoopers.

He has taken postgraduate courses in both Argentina (Universidad de Buenos Aires, magister in law and economics) and Spain (Instituto de Estudios Fiscales, Madrid, tax criminal law).

In the academic field, he is head professor of Universidad de Ciencias Empresariales y Sociales (UCES) as well as in Universidad de Belgrano.

He is a member of the Argentine Association of Tax Studies.

He has written several articles on tax issues in both local and international media.

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 PricewaterhouseCoopers.

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

Eduardo has a broad experience in the design and management of legal strategies for highly-complex tax cases and has acted in many leading cases the decisions of which were rendered by 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). The cases resolved by the Tax Court include: deduction of interest on loan (Swift), transfer pricing relating to financial transactions (Ericsson), transfer pricing relating to exports (Laboratorios Bago, Nobleza Piccardo and Toyota), among many others.