Germany

PwC

Friedrich-List-Straße 20

D-45128 Essen

Germany

Tel: +49 (0)201 438 1970

Email: andreas.kempf@de.pwc.com

Website: pwc.com/taxcontroversy

In 1983, Andreas Kempf joined a predecessor firm of PwC in Düsseldorf, moving to the Essen office in 2010. He was seconded to the London office for six months and was on a tour-of-duty to the Paris office in 1991. He is presently a member of the PwC Germany internal partner committee dealing with difficult tax technical questions of general interest.

He has served a wide range of different clients with a focus on inbound investments into Germany from the US, the UK, France, Denmark, Italy and the Netherlands. Apart from serving clients on a regular basis, Andreas advised clients on M&A transactions as well as on group restructurings with an international focus.

In recent years, the German tax authorities have shown a more aggressive approach in the course of their regular tax audits and Andreas has therefore concentrated on defending clients in tax audits, on negotiating tax audit findings as well as on tax litigation at various German tax courts and the German Supreme Tax Court. His court cases have covered a wide range of technical questions such as international tax questions, tax accounting, the German participation exemption, the credit of German trade tax against the personal income tax, specific trade tax questions and even salary withholding tax.

Andreas has published a number of articles on corporate and international tax questions.

After his professional education with a bank in Germany and France, Andreas obtained a business degree from the Duisburg University. Andreas is a certified tax advisor (steuerberater).

PwC

Moskauer Straße 19

D-40227 Düsseldorf

Germany

Tel: +49 211 981 -1966

Email: heinz-klaus.kroppen@de.pwc.com

Website: pwc.com/taxcontroversy

Before joining PwC in June 2014, Heinz-Klaus gained more than 25 years of professional experience in a Big 4 firm, where he led the German tax function as well as the EMEA tax practice during his final years. His client work concentrates exclusively on international matters, mainly cross-border transactions, acquisitions and multinational corporations' tax issues with a strong focus on transfer pricing and controversy. His recognition as a leading German tax and transfer pricing expert has led to his consistent selection for inclusion in Euromoney's Guide to the World's Leading Tax Advisers and the Guide to the World's Leading Transfer Pricing Advisers.

Heinz-Klaus' clients include several DAX 30 multinationals, as well as other European, US and Japanese corporations representing a wide range of industries. In recent years he led a number of tax audits, competent authority procedures and court proceedings including representation of his clients in the German tax courts and Supreme Tax Court in the area of transfer pricing and international tax. Heinz-Klaus regularly negotiates APAs for large multinational clients. In 2011 Heinz-Klaus was a general reporter on Subject 1 'Cross-border business restructuring' at the 65th Congress of the International Fiscal Association (IFA) in Paris.

Heinz-Klaus is editor and co-author of the leading German publication on transfer pricing, Handbuch Internationale Verrechnungspreise, and editor and co-author of Gosch/Kroppen/Grotherr, DBA-Kommentar, a leading commentary on double tax treaties. He also co-authored the German chapter of the IBFD's Global Transfer Pricing Explorer. He has published a number of articles on international tax and transfer pricing matters. Heinz-Klaus is a member of the tax board of the American Chamber of Commerce in Germany as well as a board member of the German branch of IFA. He is also a professor of international tax law at the Ruhr University in Bochum.

Heinz-Klaus studied law at the universities of Kiel, Hamburg, Cologne and later clerked at the German Tax Court in Düsseldorf and at the German/Korean Chamber of Commerce and Industry in Seoul. During this time, he wrote a dissertation on company and tax law problems for which he was awarded his PhD in law. Heinz-Klaus later attended Georgetown University Law School (Washington DC) for postgraduate studies, receiving an LLM in international law. He is a certified tax adviser (steuerberater).

Deloitte Germany

Kurfuerstendamm 23 Neues Kranzler Eck

Berlin, 10719

Germany

Tel: +49 30 2546 8116

Email: mmassbaum@deloitte.de

Michael Massbaum is tax partner in the tax and legal practice of Deloitte Germany and has more than 24 years of experience serving national and multinational clients. He is the leader of the Private Company Services tax service line, and is experienced in tax structuring and tax controversy work.

Michael has wide industry expertise including manufacturing, energy, resources and real estate.

Michael is a lawyer and a member of the Berlin Bar. He is also a licensed tax adviser. Michael is a member of the International Fiscal Association, German Tax Law Society (Deutsche Steuerjuristische Gesellschaft) and Verein Berliner Kaufleute und Industrieller.

Michael is the author of several articles on national and international tax law. He is co-author of the DBA-Kommentar a leading publication on double tax treaties, and of the Hermann Heuer Raupach, Einkommensteuer und Körperschaftsteuer, a leading publication on income and corporate tax. Furthermore, he is a regular lecturer for corporate and international tax law.

Michael studied at the University of Osnabrück. He wrote a dissertation on international tax law for which he was awarded his PhD in law.

KPMG

Tersteegenstraße 19 – 31

40474 Düsseldorf

Germany

Tel: +49 211 475 7474

Email: anientimp@kpmg.com

Website: www.kpmg.com

Dr. Axel Nientimp is a tax and transfer pricing partner in KPMG's Düsseldorf office. He has more than 15 years of experience in international taxation and transfer pricing.

Over the years, he has delivered a broad range of transfer pricing solutions to companies in various industries. His projects cover all aspects of designing, implementing and documenting transfer pricing solutions including the attribution of profits to permanent establishments as well as large supply chain reorganisations. Axel has significant experience in defending multinationals in transfer pricing tax audits and mutual agreement procedures (MAPs) as well as negotiating bilateral and multilateral advance pricing agreements (APAs).

Axel holds a PhD in business taxation and a degree in economics (Diplom-Ökonom) from the University of Bochum. He is a certified tax adviser (steuerberater), a certified tax adviser for international taxation (fachberater für internationales steuerrecht) and a member of the Tax Advisors Association.

Axel has published a volume on the profit allocation of multinational enterprises and a broad range of articles on transfer pricing and international taxation for professional journals. He is the co-editor of Germany's leading compilation of transfer pricing laws and regulations and commentator of the transfer pricing regulations in Germany's Foreign Tax Code. He is a lecturer on international taxation at the University of Duisburg-Essen and a regular speaker at universities as well as at national and international conferences and seminars.

KPMG is a global network of professional service firms providing audit, tax and consulting services with more than 162,000 professionals in 155 countries. In Germany, KPMG belongs to the leading audit and consulting firms with about 8,700 professionals in more than 20 locations. About 100 transfer pricing specialists in Germany cover all aspects of transfer pricing from transfer pricing system design and planning to turnkey documentation solutions and controversy.

KPMG

Ludwig-Erhard-Straße 11-17

D-20459 Hamburg

Germany

Tel: +49 (0)40 32015-5312

Email: holgerpeters@kpmg.com

Website: www.kpmg.com

Holger M Peters is a transfer pricing partner of KPMG's office in Hamburg and heads KPMG's global transfer pricing services team in the Northern region of Germany. In addition, Holger is the national leader of KPMG's global transfer pricing dispute resolution practice in Germany. Before joining KPMG in 2004 Holger has gained professional experience in the tax and legal practice of another Big 4 firm in Düsseldorf.

Holger is a tax lawyer and business mediator. He is a member of the German Bar, International Fiscal Association, German Tax Law Society (Deutsche Steuerjuristische Gesellschaft) and the Association of Tax Lawyers (Arbeitsgemeinschaft der Fachanwälte für Steuerrecht).

Over the past 14 years Holger has helped multinational companies across a range of industries to effectively manage their transfer pricing risk exposure by setting up comprehensive transfer pricing systems and by helping them document and defend their transfer prices.

Holger's main focus lies on transfer pricing risk management and dispute resolution, including negotiating advance pricing agreements (APAs), mutual agreement procedures (MAPs) as well as tax settlements in local tax audits. His projects comprise dozens of bilateral and multilateral APAs (including renewals), MAPs, and EU arbitration procedures as well as pan-European documentation projects and numerous tax audits, including pre-audit strategic consulting, appeals and litigation before the German tax courts. His projects cover countries mainly in Europe, North America and Asia.

His wide industry experience includes projects in the consumer products and retail business, transportation and logistics sector, automotive industry, technology sector and the energy and resources industry.

Holger is a frequent speaker at conferences and also regularly publishes nationally and internationally about transfer pricing topics. He studied at the University of Münster, Saarbrücken and German University of Administrative Sciences Speyer. Holger received an executive MBA in accounting and controlling for his postgraduate studies.

Deloitte Legal

Aegidientorplatz 2a

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hramcke@deloitte.de

Heiko Ramcke is a partner of Deloitte Legal in Germany and the leader of the criminal tax law team for Deloitte Germany. Heiko has many years of experience in criminal tax law. He joined Deloitte in 2001.

With his team Heiko defends clients in criminal tax proceedings and prepares self-disclosures to gain impunity for the clients. He also advises clients in preliminary investigations. Heiko serves multinational organisations as well as the management of national medium size businesses and individuals.

Heiko is also specialised in procedural tax law and advises clients in all types of national disputes with tax authorities. Throughout his career, Heiko has represented businesses and individuals in all stages of litigation proceedings and has assisted many companies to litigate tax issues before the German tax authorities and the finance courts.

Heiko is an attorney-at-law and studied law at the University of Kiel.

Deloitte Germany

Rosenheimer Platz 6

81669 München

Germany

Tel: +49 (0)89 290368916

Fax: +49 (0)89 290368911

Email: alschemmel@deloitte.de

Website: www.deloitte.legal.de

Alexander Schemmel is a partner of Deloitte Germany/Deloitte Legal and joined the firm in 2015.

He is responsible for the white collar crime prevention and investigations service line, and his core areas are corporate defence and corporate compliance.

With his team, Alexander defends national and international companies as well as individuals in all areas of white collar and tax criminal law. He has extensive experience conducting internal investigations and in the field of public, regulatory and corporate compliance. Alexander has defended several officers of DAX companies and has advised major corporations in large-scale tax investigations.

In 2014 Alexander was ranked as one of the best consultants in the area of white collar crime by Chambers Europe and Best Lawyers.

Alexander has been an attorney-at-law since 2001. He studied law at the University of Passau.

Deloitte Legal / Raupach & Wollert-Elmendorff

Georgstrasse 52

30159 Hannover

Germany

Tel: +49 (0)511 3075593

Fax: +49 (0)511 30755950

Email: hstang@deloitte.de

Website: www.deloittelegal.de

Dr Harald Stang is an attorney-at-law, tax consultant and partner at Deloitte Legal. He joined the firm in 1998 and was appointed equity partner in 2002.

Harald has 16 years' experience in advising different clients in M&A transactions as well as in all respects of corporate law, in particular corporate restructurings. He also focuses on advising the shareholders of family owned companies in connection with the law of succession.

Harald is also specialised in procedural tax law and advises clients in all types of national disputes with tax authorities. Throughout his career, Harald has represented businesses and individuals in all stages of litigation proceedings and has assisted many companies to litigate tax issues before the German tax authorities and the finance courts.

Harald has studied law and economics at the University of Göttingen. He previously worked as an assistant auditor with a medium size firm of auditors and tax consultants.

NERA

Messeturm

60308 Frankfurt

Germany

Tel: +49 69 710 447 501

Fax: +49 69 710 447 550?

Email: alexander.voegele@nera.com

Website: www.nera.com

Alexander Voegele has more than 25 years of experience in transfer pricing. He has led hundreds of transfer pricing projects and provided economic advice on numerous defence cases for a variety of clients in a wide range of industries. His experience includes negotiating a multitude of mutual agreement procedures and arbitration cases.

He edits the two leading German handbooks on transfer pricing and intellectual property and is repeatedly listed among the 'Best of the Best' transfer pricing advisers by International Tax Review and Euromoney.

Before taking his position as chairman of the advisory board with NERA Frankfurt, he was a partner with both PwC and KPMG.

Alex is a certified German and French auditor and a German tax adviser and holds a doctoral degree in economics and a master's degree in tax from the University of Mannheim (Germany).