17-18 OCTOBER 2019 FRANKFURT, GERMANY

6th ANNUAL CORPORATE SUMMIT LARS VON JESCHE STANISLAVA MANOLOVA DONATA KOREN Partner, International Corporate Tax Tax Manager Senior Lead of Tax Team BDO PORR AG Zalando

EDUARDO R. FLÖRING JR. LUIS CARRILLO MARK JOHNSON Head of Transfer Pricing Senior Director – Tax & Transfer Pricing Solutions Co-Head of Unit, Tax Certainty / CbC Reporting CHAIRMEN Theo Müller Group Bureau Van Dijk – A Moody’s Analytics OECD Company

RAFFAELE PETRUZZI HARM J OORTWIJN BRIGITTE BAUMGARTNER Managing Director Senior Tax Structuring, Reporting and Compliance Independent Transfer Pricing Expert WU Transfer Pricing Center Whirlpool TP Baumgartner

KSENIJA CIPEK ANDREAS RIEDL MARIA GRIGORYEVA Head of Tax Risk Analysis Partner Transfer Pricing & Head of TP Technology Senior Manager Ministry of Finance Croatia WTS TPA GlobaI

XAVIER CAMPS MARK HOUTZAGER PHILIP DE HOMONT Senior Tax Manager EMEA Tax Leader Associate Director Electronic Arts (EA) Starbucks NERA Economic Consulting

MARC MOKRAB FURHERR GEBHARD ÓSCAR BERTRÁN Global Head of Tax Auditor and Tax Advisor Partner Technicolor LeitnerLeitner GmbH Cuatrecasas SPEAKERS KATE BUSHBY XAVIER XIVILLE YVES HERVE International Tax Lead Partner, Lawyer, Economist Managing Director TransferWise Cuatrecasas NERA Economic Consulting

SOPHIA REISMANN EMINE CONSTANTIN PAUL DALY Senior Tax Expert – Global Transfer Pricing Global Head of & Tax Partner, Head of Transfer Pricing OMV TMF Group BDO

DIRK ELBERT WOLFGANG KLOSTER Partner Partner BDO BDO

• Transfer Pricing, User Participation, and Attribution of Profits • Aligning tax KPIs/targets with the overall corporate to Virtual Permanent Establishments • Tax function automation • CbCR, SAF-T, e-invoicing – exploring digital initiatives • A detailed look into BEPS and MLI • International tax disputes – MAP, Arbitration, APAs

KEY TOPICS • Staff turnover and education – building an effective tax team for the future • Recent developments in ICAP pilot

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08:15 REGISTRATION & MORNING COFFEE 13:00 INTERACTIVE LUNCH TABLE DISCUSSION Participant will be discussing pre-selected topics in small groups during 08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON lunch. Each table is assigned with a moderator to keep the discussion energetic and interesting 09:00 Transfer Pricing, User Participation, and Attribution of Profits to Virtual Permanent Establishments SUMMARY OF THE TABLE DISCUSSION • The changing environment Continued in the conference room, a short summary of the discussion will • Case study be shared by table moderators • What will the future bring 14:20 International tax disputes – MAP, APAs, arbitration RAFFAELE PETRUZZI • Recent developments and practical cases Managing Director • Challenges in negotiation WU Transfer Pricing Center • Reducing the time of resolution 09:30 Data security • Disputes involving two or more territories • In-house guidelines EDUARDO R. FLÖRING JR. • Data Protection Directive Head of Transfer Pricing • Exchange of information, joint audits Theo Müller Group • Providing data to third partie 14:50 Recent developments in ICAP pilot BRIGITTE BAUMGARTNER • Current status Independent Transfer Pricing Expert • What are the drivers? TP Baumgartner • Covered risks • The process 10:00 PANEL DISCUSSION Topic: Tax Proposals MARK JOHNSON • Common Consolidated Corporate Tax Base (CCCTB) Co-Head of Unit, Tax Certainty / CbC Reporting OECD • VAT Definitive Regime • Digital Services Tax 15:30 PANEL DISCUSSION Moderator: Topic: Working together – improving communication between enterprises LARS VON JESCHE | BDO and policymakers What are the issues facing MNEs on recent tax laws? How to improve Panelists: communication between MNEs and tax administrators? Overview of CHRISTINA LEOMY-VOIGT | ATOZ Tax Advisers globalization and market consolidation EMINE CONSTANTIN | TMF Group Moderator: RAFFAELE PETRUZZI | WU Transfer Pricing Center KSENIJA CIPEK | Ministry of Finance Croatia, Tax Administration 10:40 COFFEE & NETWORKING BREAK Panelists: KATE BUSHBY | TransferWise 11:10 Global Mobility – Managing International Tax Risk ÓSCAR BERTRÁN | Cuatrecasas • Why is it important • Trends VIOLA BOGNAR | Vienna Insurance Group • The Bigger Tax Impact • Key considerations 16:10 COFFEE & NETWORKING BREAK PAUL DALY WOLFGANG KLOSTER Partner, Head of Transfer Pricing Partner 16:40 Thema Structural procedure for DEMPE analysis • DEMPE Analysis embedded in value contribution analysis BDO BDO AG • Slicing DEMPE methodological procedure 11:30 Exploring digital initiatives (SAF-T vs. Live Reporting) • Identifying routine DEMPE contributions • The evolution of digitization within tax world YVES HERVE • Challenges and benefits of digitization Managing Director • Digitization trends in EMEA, APAC, and LATAM NERA Economic Consulting • What is next? EMINE CONSTANTIN 17:10 Building an effective tax team for the future Global Head of Accounting & Tax • Evolving focus of the tax team TMF Group • Tax in a mission driven start up • High performance in a hyper growth environment 12:00 New horizontal monitoring-programme in Austria KATE BUSHBY • Co-operative procedure between taxpayer & tax administration International Tax Lead (replaces tax audit) TransferWise • Prerequisites for participation (i.e. Tax Compliance Management System) • Benefits for taxpayers & tax administrators 17:40 Aligning tax KPIs/targets with the overall corporate KPIs • Lessons learned • Are managed properly? • Does Tax operate in the most efficient way possible? FURHERR GEBHARD • Job satisfaction and recognition measures Auditor and Tax Advisor • Outsourcing compliance LeitnerLeitner GmbH MARC MOKRAB 12:30 Compliance Risk Management: Prevention vs. Repression Group Head of Tax • Legislation and CRM System Technicolor • Managing data • Prevention of Tax Fraud 18:10 CHAIRPERSON’S CLOSING REMARKS, END OF DAY 1 • Possibilities of New Technologies in Tax Administrations KSENIJA CIPEK Head of Tax Risk Analysis Ministry of Finance Croatia, Tax Administration

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu AGENDA FRIDAY, DAY 2 #UNGCTS

08:15 MORNING COFFEE 12:50 NETWORKING LUNCH 08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON 13:50 TP Technology implementation • Setting a TP digitalization strategy 09:00 Tax function automation • Effectively implementing TP technology: pitfalls & learnings • Technology = compliance + consistency • Use cases for data & analytics in TP • RPA, Tax ERP, AI • Improving audit efficiency and effectiveness SOPHIA REISMANN Senior Tax Expert – Global Transfer Pricing STANISLAVA MANOLOVA OMV Tax Manager PORR AG 14:20 Managing complexity in transfer pricing audit • How to reduce risk in the Transfer Pricing tax audit? 09:30 Transformation of the TP Function • Preemptive measures to avoid a tax audit • Trends regarding the digitization of the TP function • Anti-tax audit documentation • Standardization vs. Individualization • Managing multi-country tax audits • How to be prepared: process, data and personnel • Post-tax audit measures ANDREAS RIEDL XAVIER XIVILLE Partner Transfer Pricing & Head of TP Technology Partner, Lawyer, Economist WTS Cuatrecasas 10:00 Fit for future: A refined approach to tax risk management ÓSCAR BERTRÁN • Value chain analysis for risk monitoring and reporting Partner • Tax controversy decision-making Cuatrecasas • Tax technology for full risk control MARIA GRIGORYEVA 14:50 PANEL DISCUSSION Senior Manager Topic: ’Addressing the Tax Challenges of the Digitalization of the Economy’ TPA Global by OECD Moderator: 10:30 COFFEE & NETWORKING BREAK ROSS ROBERTSON | BDO 11:00 Taxation of the digital economy Panelists: • How to adapt the concept of value creation to the digital environment? • Digital Services Tax (DST) and other proposals YVES HERVEE | NERA Economic Consulting • Tackling BEPS in the digital economy BRIGITTE BAUMGARTNER | TP Baumgartner • Corporate taxation of Significant Digital Presence REINOUT DE BOER | Stibbe XAVIER CAMPS DONATA KOREN Senior Tax Manager Senior Lead of Tax Team 15:30 COFFEE & NETWORKING BREAK Electronic Arts Zalando 11:30 Integrating tax technologies 16:00 Solving Hard-to-Value Intangibles • Improve tax efficiency • Definition – is there any easy-to-value intangible? • Starbucks’s path towards a more efficient compliance process • BEPS-challenges: The issue of ex-post adjustments • Lessons learned • Methodological approaches to avoid adjustments MARK HOUTZAGER PHILLIP DE HOMONT EMEA Tax Leader Associate Director Starbucks NERA Economic Consulting 12:00 The New World of Cost Contribution Agreements 16:30 Management of the ETR to reduce ETR • Definition of Cost Contribution Agreements & Indirect Charge Method • Tax Risk monitoring • CCAs after BEPS • Backward and forward-looking ETR • The new German decree on CCAs • Tax policy parameters • Changes to be implemented before 2020 HARM J OORTWIJN Senior Tax Structuring, Reporting and Compliance DIRK ELBERT Whirlpool Partner BDO 17:00 CLOSING REMARKS & CHAIRPERSON’S SUMMARY 12:20 Under the Microscope: Big Data and Digitalization of Tax Administrations for Audit Case Selection 17:10 END OF THE SUMMIT • Big data • Sources of information • Current Digital landscape of tax administrators • Conclusions LUIS CARRILLO Senior Director – Tax & Transfer Pricing Solutions Bureau Van Dijk – A Moody’s Analytics Company

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu SPEAKERS BIOGRAPHIES

LARS VON JESCHE KSENIJA CIPEK Partner, International Corporate Tax Head of Tax Risk Analysis BDO Ministry of Finance Croatia, Tax Administration

CHAIRMAN Lars von Jesche is a Partner with the International Ksenija Cipek is based in Zagreb, Croatia and she is Tax Department of BDO AG in Frankfurt am Main a lecturer at the local University of Law, a Member of in Germany. He has 17 years of experience in European Law Institute, Contribute Member of the advising multinational companies in the field of Blockchain Chamber of Commerce (US), Member of transfer pricing. In addition to global transfer the Government Blockchain Association and Board pricing documentation projects and the conceptual Advisor of EUCED (European Network for Economic analysis and development of value chain analysis as Cooperation and Development). Ksenija has over 20 well as transfer pricing restructuring, his consulting years’ experience working at the Ministry of Finance expertise includes advising clients in formal tax law aspects and accompanying tax and the Tax Administration. She is a highly respected and recognized international tax audits. After several years working for “Big 4” companies, Lars has joined BDO in 2018. expert who has been heavily involved in lawmaking and was responsible for many tax His industry experience includes: Machinery and equipment; IT; Software; Network reforms. She participates at the Forums and working groups at the Council of the EU, Integration; Telecoms; Automotive incl. OEMs, Tier 1-3 suppliers, commercial vehicles; the OECD and IOTA and is speaker at international conferences. As a Project Leader, Consumer; Logistics. He studied law at the Justus Liebig-University in Gießen and tax she established Compliance Risk Analysis System and provided idea solution for law/financial science at the University of Osnabrück with the concluding degree of automatic VAT return based on Risk Analysis System in Croatian Tax Administration. LL.M. Taxation and since 2002 he bears the title specialist lawyer for tax law. Ksenija is also an author and books writer.

EDUARDO R. FLÖRING JR. MARK JOHNSON Head of Transfer Pricing Co-Head of Unit, Tax Certainty / CbC Report- Theo Müller Group ing OECD CHAIRMAN Eduardo currently leads the transfer pricing team Mark in Head of Unit at the OECD Centre for Tax of the Müller Group, a 6-billion EUR market-leading Policy & Administration, with responsibility for FMCG business headquartered in Luxembourg. He country-by-country reporting, tax risk assessment has twelve years’ experience working with TP and and dispute prevention, and the international international tax issues, having previously trained compliance assurance programme (ICAP). with PwC in and Germany. Previously at the OECD he also had responsibility Eduardo holds an LLM from Queen Mary, University for work on tax and crime, the Forum on Harmful of London and has acquired the ADIT qualification Tax Practices and aggressive tax planning, and he from the UK Chartered Institute of Taxation. Having joined Müller back in 2015, led the work on BEPS Action 4. Eduardo has triggered various initiatives to revamp the TP management lifecycle Prior to joining the OECD, Mark had a varied career in international tax including roles in during the BEPS project. He oversees all dispute resolution cases within the Group and large advisory firms, international banks and as a senior policy advisor at HM Revenue is a frequent speaker in TP workshops. & Customs.

BRIGITTE BAUMGARTNER SPEAKERS Independent Transfer Pricing Expert TP Baumgartner Brigitte Baumgartner is a transfer pricing expert with a law degree in Mexico, two Masters in RAFFAELE PETRUZZI international tax and European tax. She has years of Managing Director experience in the public and private sector and has WU Transfer Pricing Center been a member of the Joint Transfer Pricing Forum Dr. Raffaele Petruzzi, LL.M., is the Managing since 2015. Currently, Brigitte has started her PhD Director of the WU Transfer Pricing Center at the in Management, provides consultancy services in Institute for Austrian and International Tax Law at transfer pricing, and tax data protection. WU (Vienna University of Economics and Business) and an international tax advisor specializing in XAVIER CAMPS international corporate taxation and transfer Senior Tax Manager pricing at L&P Global (Vienna, Austria) and at Electronic Arts (EA) Ludovici Piccone & Partners (Milan, Italy). Since Xavier is a Spanish lawyer with 15 years of 2007, Raffaele has gained extensive experience in international tax experience, working in practice and dealing with topics related to international corporate taxation and transfer pricing, in-house in different EU countries and Switzerland. both from a professional and an academic perspective. He is a member of the In his current position, Xavier is responsible for United Nations Subcommittee on Article 9 (Associated enterprises: Transfer Pricing), the LATAM and Southern European territories at of the International Fiscal Association (IFA), and of Transfer Pricing Economists Electronic Arts (EA) in Geneva. Formerly, he had for Development (TPED). Raffaele holds a Master of Science degree in Business several roles, amongst others: senior advisor at Administration and Law (major: Corporate Taxation) at Bocconi University (Italy), PwC and tax function leader at the Pepe Jeans a Master of Laws degree (LL.M.) in International Tax Law at WU, and a Ph.D. in Group. International Business Taxation at WU.

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu SPEAKERS BIOGRAPHIES

MARC MOKRAB DONATA KOREN Global Head of Tax Senior Lead of Tax Team Technicolor Zalando Marc Mokrab serves as Global Head of Tax of Donata Koren leads the Tax Team at Zalando, one Technicolor. He has over 13 years of experience of the biggest online fashion platforms in Europe. in management of global tax departments. Prior Within the role, she is responsible among others for to joining Technicolor in 2019, he spent 8 years in the overall tax compliance for the group. Geneva and London working as Head of Tax for Prior to joining Zalando in 2016, Donata worked Lagardère Sports and Entertainment (a leading for Big4 in the Tax Management and Accounting global sports and entertainment agency), four Services team. She advised diverse multinationals years as Tax Manager of Yves Rocher (Paris) and comprehensively in the field of corporate taxation, three years as Tax consultant for various tax and VAT and transfer pricing. Within this role, she has accounting firms. His main areas of specialization include tax planning, mergers gained in-depth understanding of the tax reporting process with the financial reporting and acquisitions, restructurings, the design of transfer pricing policy and related framework. documentation, audits, dispute resolution and risk mitigation. Marc holds an MBA She is an ACCA member and a qualified tax advisor, with 13 years of tax consulting from Paris Business School, Master of Tax laws from the University of Paris II and a and compliance experience. Donata holds a Master of Laws degree in International Tax certificate in Transnational Law specialized in International and Swiss tax laws from Law and Master of Arts degree in Ethnolinguistics. the Law Faculty of the University of Geneva. ANDREAS RIEDL STANISLAVA MANOLOVA Partner Transfer Pricing & Head of TP Tax Manager Technology PORR AG WTS Stanislava is a certified tax advisor and a chartered Mr. Riedl is a part of WTS’s Global Transfer Pricing certified accountant. She had started her career and Valuation Practice, where he is leading the TP with one of the Big 4 advisory firms. Currently, technology team. He specializes in operational Stanislava holds and an in-house tax role with transfer pricing and transfer pricing process PORR AG – a multinational construction company planning cases as well as TP tool implementations. based in Austria. At her current role, Stanislava is In that regard, he focuses on providing practical a member of the newly established Digital Finance solutions to his clients that create quick wins. He Lab of the PORR Group and as such, is involved in frequently publishes articles on transfer pricing several automation and digitalization initiatives. developments. Mr. Riedl holds and MSc-equivalent in economics from Universitat She is keen to share her insights with us today. Augsburg, Germany.

HARM J OORTWIJN KATE BUSHBY Senior Tax Structuring, Reporting and International Tax Lead Compliance TransferWise Whirlpool I have been working for TransferWise just over a Harm is a Senior Tax Manager at Whirlpool year, growing the team from two to six people. EMEA, based in Pero, Italy. He has some 20 years TransferWise is a high growth start up and I am of international tax experience with a number tasked with helping set up operations in a large of multinational companies as both in-house number of jurisdictions worldwide, ownership of the professional and tax consulting. He graduated group structure and all cross-border transactions. with honor from United Business Institutes (UBI) Before this, I worked for Dow Jones and Grant in Brussels with a Masters degree in Global Tax Thornton where my work was largely centered Management. Tax reporting and tax technology on advising Tech companies expanding into new as his initial core background, he has been designing and implementing global tax markets. strategies to support the business in the changing BEPS and digitization driven tax landscape. MARK HOUTZAGER EMEA Tax Leader LUIS CARRILLO Starbucks Senior Director – Tax & Transfer Pricing Solutions Mark Houtzager’s background is in supporting Bureau Van Dijk – A Moody’s Analytics multinationals with managing their global indirect Company tax footprint. He authored an extensive portfolio of articles and other publications on VAT, and speaks Luis Carrillo is Bureau van Dijk’s global director for frequently on conferences. the tax and transfer pricing market, and he is the global practice group leader for tax and transfer Mark joined Coopers & Lybrand in 1991, shortly pricing. Luis joined Bureau van Dijk in London after graduating from law school in Leiden, The in 2008 as Senior Advisor. Prior to that, Luis . He founded US VAT, Inc. in August gained over 16 years of transfer pricing advisory 2010, after having spent 20 years as dedicated VAT expert at PwC and Deloitte. Mark experience at Big 4 firms. Luis’ expertise is in the has been living in Singapore, Connecticut and New York. areas of intangible valuations and global TP compliance with a focus on the high-tech In the U.S., Mark supported multinational companies with developing new overseas and software industries. business, supply chain structuring, M&A pre and post-deal structuring. A major focus was using tax technology to improve tax efficiency and reconciliations. In July 2017, Mark joined Starbucks as their London-based EMEA Tax Leader. His focus now reaches way beyond indirect taxes, and includes “everything that is tax, and beyond”. Building a technology driven, world-class tax department in EMEA is one of Mark’s top deliverables.

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu SPEAKERS BIOGRAPHIES

MARIA GRIGORYEVA PHILIP DE HOMONT Senior Manager Associate Director TPA Global NERA Economic Consulting Maria Grigoryeva, Senior Manager with TPA Global. Mr. de Homont is an expert in NERA’s global Transfer TPA Global specializes in tax technology, tax and Pricing practice, where he provides transfer pricing transfer pricing consulting. advice to international corporations and law firms. Maria is an expert in transfer pricing. She is leading He specializes in the transfer pricing of in tax audits a TPA Global’s Tax Technology projects, working and litigation cases, as well as transfer pricing in closely with software providers and clients. She the digital economy. specializes in value chain analytics and TP/tax Mr. de Homont has extensive experience in the operating models. Maria has recently focused on defense of licensing and valuation arrangements for the financial services, apparel, pharmaceutical and intangibles. His recent cases covered transactions mining industries. from brand licenses, profit splits for local distribution and sales companies, to the valuation of user data and relocations of functions. In the digital economy, he has SOPHIA REISMANN introduced novel approaches to separate market and user intangibles from technical Senior Tax Expert – Global Transfer Pricing engineering and established methods to value platform intangibles. OMV YVES HERVE Sophia is responsible for Global Transfer Managing Director Pricing Governance within OMV Group. As part NERA Economic Consulting of OMV Group’s tax department, Sophia’s work covers areas such as the definition of pricing Dr. Yves Hervé is a Managing Director in NERA’s standards, intercompany commodity and financing Global Transfer Pricing Practice and is operating transactions as well as transfer pricing compliance in NERA’s Frankfurt office. Dr. Hervé has been related issues. One of her main tasks is currently a fully dedicated TP professional since 1999. the digitalization of the transfer pricing function. Prior to joining NERA, he was a Transfer Pricing Before joining OMV in 2015, Sophia worked at the Partner at one of the Big Four accounting firms, transfer pricing department of PwC (Austria) for over 5 years, providing a full range of then the German Tax Leader of the global Value services in the field of transfer pricing for clients in various industries. Chain & Digital Transformation practice at another Sophia holds a Master in International Business from the Vienna University of Big Four firm. In the course of his projects and as Economics and Business Administration, where she specialized in international responsible promoter of broader solution platforms, Dr. Hervé has been particularly taxation. active in designing innovative solutions for Value Chain Analysis (e.g., a solution approach to rank functional value contributions in a non-distortionary manner, as well FURHERR GEBHARD as a peer group based analytical approach), Risk Economics (e.g. quantification and Auditor and Tax Advisor risk adjustments solutions for business restructurings and hybrid value functions), LeitnerLeitner GmbH Profit Splits (e.g. solutions based on relative bargaining power), and TP andtax impact simulation. Dr. Hervé has provided expert opinion reports in relation to Gebhard Furherr, a partner at LeitnerLeitner since European tax audits and has assisted clients with economic analysis for advance 2009, is an auditor and tax advisor. After completing pricing agreements with local authorities. In litigation, he has been involved in cases his studies at Vienna University of Economics and considering intellectual property remuneration, related tax exit charges, and their Business, he worked for the International Bureau of underlying business valuations. He has also provided the economic analysis for Fiscal Documentation (IBFD) in the Netherlands, as international arbitrations. well as in the field of international tax law at two Big Four companies in Vienna. DIRK ELBERT He advises domestic and foreign clients on issues Partner concerning national and international tax law, more BDO specifically corporate and group tax law, reorganizations, M&A, and transfer pricing. Gebhard Furherr has authored a number of specialist publications and is in demand in Dr. Dirk Elbert is a Partner with the International his field as a lecturer at national and international seminars and symposiums. Tax Competence Center of BDO AG in Germany. He is a member of the executive committee of the EMINE CONSTANTIN Corporate International Tax Centre of Excellence of Global Head of Accounting & Tax the BDO network and the international tax working TMF Group party of the Institute of Public Auditors in Germany (IDW). Emine is EMEA Head of Accounting & Tax. Prior Dirk has been working in taxation since 1996. He to her present role within the TMF Group, Emine specializes in transfer pricing and cross-border was Managing Director of the TMF organization in tax planning. Dirk regularly speaks at seminars about a range of tax and legal issues, Romania leading the local practice comprised of particularly transfer pricing, and he is co-author of the leading German transfer pricing over 100 professionals. Emine has more than 20 commentary “Verrechnungspreise” published by C.H.Beck. years of international experience in the accounting Dirk joined BDO AG in 2005, after several years as a tax officer with the German tax & tax area and has been involved in setting up the authorities, as a consultant with a number of law firms and as an assistant at the outsourcing model for a number of international Institute of Finance and Tax Law of the University in Heidelberg. He studied finance clients in various industry fields, such as at the University of Applied Sciences in Ludwigsburg and law at the Law School of the pharmaceuticals, oil & gas, real estate. She holds a Business Administration Diploma University in Heidelberg; Dirk is a Doctor of Jurisprudence. from the University of Bucharest. She is also member of local accounting and tax professional organizations and a fellow member of ACCA (Association of Chartered Certified Accountants). Emine is also a qualified CFA (Chartered Financial Analyst).

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu SPEAKERS BIOGRAPHIES

PAUL DALY Partner, Head of Transfer Pricing PDF Presentations BDO UK LLP Paul is a UK tax partner specializing in transfer pricing and international tax. He assists clients with transfer pricing studies and documentation exercises, design and implementation of value chain tax structures as well as dealing with HMRC and tax authorities internationally on inquiries and disputes, including supporting on MAPs and APAs. Paul assists clients on a range of international tax issues alongside transfer pricing including business restructuring pricing, permanent establishment profit attribution, R&D tax reliefs and Short URL: www.uni-global.eu/cts19 intellectual property tax incentives. Password has been sent to your email address. He works closely with his clients across a range of assignments from supporting those taking first steps in establishing overseas operations, through to helping global businesses outsource their worldwide transfer pricing compliance. He has in-house Sli.do Interactive Q&A platform experience and perspective from time in a transfer pricing role within a FTSE100 business and understands the importance of providing grounded, practical advice.

WOLFGANG KLOSTER Partner BDO AG Wirtschaftsprüfungsgesellschaft Wolfgang Kloster started to work with BDO January 1991. Over the years, he became a specialist in the taxation of individuals. Event code: Since 2000, he is the Head of the Centre of Excellence “Payroll and Global Expatriate Services” #UNGCTS which is located in Berlin and Frankfurt. The hashtag is used also for twitter, linkedin www.slido.com Beside his broad experience in expatriate tax and other social media services his other areas of competencies include payroll accounting, social security contribution, occupational pension scheme and innovative remuneration (e.g. stock options, benefit in kind). Petr Tsoy, Conference Producer Alexandra Belausava, Event Manager Wolfgang holds lectures and seminars for our clients regarding current developments tel. +420 226 220 465 tel. +420 226 220 408 in the wage tax law. email: [email protected] email: [email protected] Since 2008, he is Member of the “Global Expatriate Services” of BDO International.

XAVIER XIVILLE Partner, Lawyer, Economist Cuatrecasas Tax partner in the law firm Cuatrecasas in its Barcelona office. Broad experience in international tax advice, restructurings, tax audits and MAPs.

ÓSCAR BERTRÁN Partner Cuatrecasas Tax partner in the law firm Cuatrecasas in its Barcelona office. More than 15 years’ experience in tax audits and 13 years’ experience in transfer pricing, APAs and tax rulings.

UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu www.tmf-group.com Economic experts. Unmatched experience. Worldwide.

NERA’s Services in Transfer Pricing • Dispute Resolution and Economic Litigation Support • Value Contribution and DEMPE Analysis • Intangibles and Risk Pricing • Business Restructuring and Digital Transformation

Contacts Dr. Yves Hervé Philip de Homont Managing Director Associate Director +49 69 710 447 508 +49 69 710 447 502 [email protected] [email protected] www.nera.com/tp

UPCOMING EVENTS

12th Global Banking Innovation Forum & EXPO 23 & 24 April 2020, Prague, Czech Republic

The 12th Global Banking Innovation Forum & EXPO is a must-attend event for bankers from all over the world, with a strong educational program based on leading banks case studies, various networking opportunities: formal and informal, and a great EXPO hall with world’s most innovative existing FinTech solutions to date. In today’s demanding market situation, it is not only necessary for banks to comply, but also to retool and transform, to be innovative, new and fresh, in order to win the customer of the future. The Forum will uncover the newest trends in banking, the most innovative and effective strategies for improving customer experience and optimizing internal banking processes. It will offer its participants various solutions for reinforcing the position of banks in the financial services sector. Join us and 500+ brightest minds of banking industry to discuss and shape the future of financial sector in the heart of Europe on 23rd & 24th of April 2020. INTERACTIVE LUNCH TABLE DISCUSSIONS

1 Table 1 DAC6 Moderator: RICHARD WELLMANN | BDO

2 Table 2 How ready are you for the 2021 VAT changes? Moderator: EMINE CONSTANTIN | TMF Group Le Méridien Frankfurt Wiesenhüttenpl. 28-38, 60329 Frankfurt am Main, Germany 3 Table 3 Tel.: +49 69 26970 Guidance on the transfer pricing of intangibles Moderator: XAVIER XIVILLE | Cuatrecasas

4 Table 4 The Role and Development of Advance Pricing Agreement (APA) and Binding Rulings in the field of Transfer pricing Moderator: KSENIJA CIPEK | Ministry of Finance Croatia, Tax Administration

5 Table 5 Transfer Pricing Litigation: Experiences of Going to Court Moderator: PHILIP DE HOMONT | NERA Economic Consulting

6 Table 6 Defending TNMM solutions in a world of decentralized intangible DEMPE contributions Moderator: YVES HERVE | NERA Economic Consulting

7 Table 7 Cooperative compliance initiatives in the countries of the participants (from Horizontal Monitoring, SAF-T to the ICAP pilot) Moderator: FURHERR GEBHARD | LeitnerLeitner GmbH

8 Table 8 Quick wins when digitalizing the TP function of an MNE Moderator: ANDREAS RIEDL | WTS Follow us on social media: uniglobal uniglobalevents Uniglobal Events

Uniglobal is a leader in focused, tailor-made business events, serving a wide range of industries in the financial sector. We cooperate with decision makers and senior-level executives all across the globe. Uniglobal Our objectives are to inform, educate, train and entertain our customers in order to provide tel.: +420 226 220 400 a high degree of satisfaction and profitability. fax: +420 226 220 444 www.uni-global.eu Uniglobal strives to increase your company’s business intelligence through its unique, highly focused, industry and client driven international conferences. We would like to thank everyone who assisted with the research and organisation of this event, particularly the speakers for their support and commitment and we thank all of our sponsors and delegates and we hope to see you in one of our future events as well.