Transfer Pricing Forum Editorial Board
Transfer Pricing Forum features Transfer Pricing experts from more than 20 countries and provides unique, country-specific solutions to complex technical Transfer Pricing problems. Below are the members of the Transfer Pricing Forum Editorial Board and country panelists:
Danny Beeton, Editor in Chief and Panelist for United Kingdom
Head of Transfer Pricing, Freshfields Bruckhaus Deringer, London
Danny was previously a partner and global head of transfer pricing in an international accounting firm. He is head of transfer pricing economics and advises on the pricing of all types of transactions and the valuation of intangible assets, with a particular focus on international tax planning and transfer pricing dispute resolution. He is well known as an international speaker and author on transfer pricing.
Danny is listed in Euromoney's Guide To The World's Leading Transfer Pricing Advisers 2010 and is a member of the CBI’s International Direct Taxes Sub-Committee and HMRC's Transfer Pricing Practitioner Group. Danny received his PhD in economics from Queen Mary College in 1985 and joined Freshfields as a Consultant in August 2009.
Murray Clayson – Editorial Board Member and Panelist for United KingdomTax Partner, Freshfields Bruckhaus Deringer, London
Murray Clayson is a partner in Freshfields’ tax practice group and is based in London. He specialises in international tax, finance and capital markets taxation, corporate structuring, transfer pricing, banking and securities tax, asset and project finance, derivatives and financial products, particularly cross-border.
Murray is listed in Chambers Europe, Chambers UK, The Legal 500 UK, Who’s Who Legal, PLC Which Lawyer? Yearbook, Tax Directors Handbook, Legal Experts and International Tax Review’s World Tax. He is a fellow of the Chartered Institute of Taxation, past-Chairman of the British branch of the International Fiscal Association (IFA) and a member of the CBI’s Taxation Committee and International Direct Taxes Sub-Committee.
Murray is a graduate of Sidney Sussex College, Cambridge. He joined the firm in 1983 and has been a partner since 1993.
Mike Heimert, Editorial Board Member
Managing Director, Transfer Pricing Services
Mike Heimert is a managing director and global leader of the Transfer Pricing Services practice. He has been named as one of the world’s leading transfer pricing professionals by Legal Media Group, underscoring his significant experience providing transfer pricing and valuation services for multinational companies across a wide range of industries – including pharmaceuticals, automotive, oil and gas, software, heavy manufacturing and retail. Mike has been retained as an expert witness on various transfer pricing matters, including the largest US Transfer Pricing case on record. He has also provided litigation support to attorneys and their clients in diverse matters involving tax issues.
Mayra Lucas Mas, Editorial Board Member Advisor, Tax Treaty, Transfer Pricing & Financial Transactions Division, Centre for Tax Policy and Administration, OECD, Paris
Mayra Lucas Mas has been an advisor at the Centre for Tax Policy and Administration Tax Treaty, Transfer Pricing and Financial Transactions Division since June 2008. She is responsible for chairing bilateral and multilateral transfer pricing events in non-OECD countries with her primary focus being the implementation of legislation in the transfer pricing area. In the past she has worked as a senior consultant for the transfer pricing group of a leading accounting firm and in the Taxation and Customs Union unit of the European Commission.
Mayra is a graduate of New York University School of Law (LLM), the University of Barcelona (Ph.D in Tax Law and Law Degree.)
Rahul Mitra - Editorial Board Member and Panelist for India
Partner and Head of Dispute Resolution & Litigation for Transfer Pricing, KPMG India
Rahul K Mitra is currently a partner in the tax & transfer pricing practice of KPMG India; and is the national leader of dispute resolution & litigation in the fields of transfer pricing & international taxation. Prior to joining KPMG India, Rahul was the national leader of PwC India’s transfer pricing practice between 2010 and 2014. Rahul was a partner in the tax & regulatory services practice of PwC India between April 1999 and February 2015.
Rahul has over 22 years of experience in handling taxation & regulatory matters in India. He specializes in transfer pricing, particularly inbound & outbound planning assignments, and advises on profit/cash repatriation planning; value chain transformation or supply chain management projects; profit attribution to permanent establishments, etc. Rahul independently handles litigation for top companies at the level of the Income Tax Tribunals. At least 50 of the cases independently argued by Rahul have been reported in leading tax journals of India. Some of the major wins of Rahul before the Tax Tribunals in transfer pricing matters have set precedents, both in India and globally.
Rahul has been consistently rated as amongst the leading transfer pricing professionals & tax litigators in the world, by Euromoney and International Tax Review, since 2010.
In his personal capacity, Rahul has handled several APAs in India, involving clients from across industries; and also covering complex transactions, e.g. industrial franchise fees/variable royalties under non-integrated principal structures; contract R&D service provider model; distribution models, with related marketing intangible issues; financial transactions; profit split models for royalties; etc.
Rahul is a Member of the Global Editorial Board of the Magazine, “Transfer Pricing Forum”, published by Bloomberg BNA. He has been a visiting faculty of the National Law School in the subject of transfer pricing & international tax treaties.
Rahul was the country reporter on the topic, “Non Discrimination in international tax matters”, for the IFA Congress held in Brussels in 2008. Rahul was invited by the OECD to speak in the 2012 Paris roundtable conference on developing countries’ perspective on APAs.
Dirk van Stappen - Editorial Board Member and Panelist for Belgium
Partner, KPMG, Belgium and member of the EU Joint Transfer Pricing Forum
Dirk Van Stappen is a Partner with KPMG in Belgium. He joined KPMG in 1988 and has over 20 years of experience in advising multinational companies on corporate tax (both domestic and international) and transfer pricing issues. He leads KPMG’s transfer pricing practice in Belgium. Dirk Van Stappen has also been appointed in 2002 (and reappointed in 2007) as one of the 10 (15 as from 2007) European business representatives of the EU Joint Transfer Pricing Forum of the European Commission.
Dirk has been named in International Tax Review’s “World Tax –The comprehensive guide to the world’s leading tax firms”, Euromoney’s (Legal Media Group)“Guide to the World’s Leading Transfer Pricing Advisers” and Euromoney’s “Guide to the World’s Leading Tax Advisers”.
He is a certified tax adviser and member of the Belgian Institute for Accountants and Tax Advisers (IAB) and of the International Fiscal Association (IFA).
Cristian Rosso AlbaMitrani, Caballero, Rosso Alba, Francia, Ojam & Ruiz Moreno Abogados, Buenos Aires
Cristian Rosso Alba has a well recognised experience in Tax Law, with particular emphasis in domestic and international tax planning, restructurings, reorganisations and international business transactions. He leads the Tax Law practice of Mitrani, Caballero, Rosso Alba, Francia, Ojam & Ruiz Moreno Abogados.
Additionally, Mr. Rosso Alba has been a regular lecturer in the United States and speaker in domestic and international tax conferences and is the author of more than eighty articles appearing in specialised publications. Cristian Rosso Alba is a member of the American Bar Association (ABA), Harvard Club of Argentina, the Canadian Tax Foundation and the Advisory Board of the Argentine Chamber of Commerce. Mr. Rosso Alba has been recommended as one of the “Leaders in their Field” (Tax - Argentina) by Chambers Latin America.
Global Partner for Asia Pacific, Transfer Pricing Associates, Sydney
Douglas Fone has a long background in Big 4 firms, providing international tax and transfer pricing services since 1987 in London, Hong Kong, Singapore and Sydney. He has been devoted exclusively to Asia Pacific international tax and transfer pricing consultancy since 1991. Doug joined the global independent specialist firm Transfer Pricing Associates (TPA) in 2005 to lead the development of the business in the Asia Pacific region, and is now a partner of the global firm. TPA has grown to become the leading independent specialist transfer pricing firm in Asia, and has coverage in over 30 countries around the world.
Claus StaringerPrincipal Consultant at Freshfields Bruckhaus Deringer, Vienna
Claus Staringer has been a Principal Consultant of Freshfields Bruckhaus Deringer since 2001 and works in the Vienna office. He is a member of Freshfield’s ITG – International Tax Practice Group and specialises in corporate tax planning, M&A transactions, structured finance, estate planning, and tax litigation. He advises industrial enterprises, banks and insurance companies, international investment banks and private equity funds.
He received his legal education at the University of Vienna and at the Vienna University of Economics and Business Administration, where he is also a professor of tax law. He is the author of a number of articles and publications. In 1997 he was admitted as tax adviser (Steuerberater).
Ana Cláudia Akie Utumi
Head of Tax, TozziniFreire Advogados, São Paolo
Ana Cláudia Akie Utumi is Head of the Tax Practice Group at TozziniFreire in Sao Paolo. She has a large experience in Brazilian and international tax practice. Ana has been working in the Tax Area since 1992, starting my career in the tax department of one of the former Big Six auditing company. Ana also has a strong academic background with a Ph.D in Economic Financial Law, a Masters in Tax Law and both law and business administration degrees. Since 2008,Ana has been one of the Directors of Brazilian Association of Financial Law ("ABDF"), which is the Brazilian branch of IFA.
Dale HillPartner, Gowlings LLP, Ottawa
Dale Hill is a partner in Gowlings' Ottawa office and is the national leader of the Gowlings Transfer Pricing and Competent Authority team. Prior to joining Gowlings in 2005, Dale was involved in international transfer pricing with the Canada Revenue Agency ("CRA") for 16 years. During his tenure as a senior manager with the CRA's International Tax Directorate, he participated in more than 40 Advanced Pricing Agreements ("APAs") with numerous countries, as well as hundreds of Competent Authority requests relating to international transfer pricing adjustments involving a vast array of issues.
He acquired his CMA and CFP designations in 1991 and 1995, respectively, and completed the CICA in-depth tax course in 1999.
Cheng ChiPartner-in-Charge for China and the Hong Kong SAR, KPMG, Shanghai
Based in Shanghai, Cheng Chi is the partner-in-charge of KPMG’s Global Transfer Pricing Services for China and Hong Kong S.A.R. Mr. Chi has led many transfer pricing and tax efficient supply chain projects in Asia and Europe, involving advance pricing arrangement negotiations, cost contribution arrangements, Pan-Asia documentation, controversy resolution, global procurement structuring, and headquarters services recharges for clients in the industrial market including automobile, chemical, and machinery industries, as well as the consumer market, logistic, communication, electronics and financial services industries .
In addition to lecturing at many national and local training events organised by the Chinese tax authorities, Mr. Chi has provided technical advice on a number of recent transfer pricing legislative initiatives in China. A frequent speaker on transfer pricing and other matters, his analyses are regularly featured in tax and transfer pricing publications around the world （i.e. International Tax Review). Mr. Chi has been recommended as a leading transfer pricing advisor in China by the Legal Media Group.
Mr. Chi started his transfer pricing career in Europe with another leading accounting firm covering many of Europe’s major jurisdictions while based in Amsterdam until returning to China in 2004.
Ho Yin LeungPartner in Global Transfer Pricing Services at KPMG China
Ho-Yin has significant experience across transfer pricing, tax advisory, dispute and compliance services, advising corporations across a broad spectrum of transfer pricing and tax issues, and regularly manages transfer pricing-led projects involving China corporate tax and Customs issues. He provides transfer pricing services to multinational clients in various industries such as diversified industrial manufacturing, automotive, pharmaceuticals, healthcare, consumer goods, food and beverages, chemicals, oil and gas, alternative energy and electronics. He has frequently published articles in leading tax and transfer pricing publications around the world, including a chapter in IBFD International Transfer Pricing Journal, BNA Transfer Pricing Forum, International Tax Review, Asia Pacific Journal of Taxation, HKICPA monthly journal, and others.
Arne Møllin Ottosen
Partner and Head of Tax Law, Kromann Reumert, Copenhagen
Arne Møllin Ottosen is Head of Kromann Reumert’s tax law group. He specialises in contentious tax including transfer pricing, tax litigation and business taxation advisory work. Arne is the author of numerous Danish and international articles on tax and company law.
Arne is listed in the International Tax Review, European legal 500 and Chambers. He holds a Law degree, Aarhus University (cand.jur. 1993). LL.M., King’s College, University of London (1999).
Julien MonsenegoPartner in Tax Law, Olswang LLP, Paris
Julien Monsenego specialises in international taxation, tax treatment of M&A and restructurings. He assists French and foreign companies in their international investments as well as in the course of their tax audits and litigations. He particularly focuses on Life Science and R&D-intensive industries. He has extended practice of transfer pricing and has intervened for French and non-French groups in setting-up intra-group flows, IP companies and business restructurings.
Before joining Olswang, Julien Monsenego previously worked at Arthur Andersen International, Ernst & Young, Coudert Brothers and Dechert LLP. Mr. Monsenego is a member of the Paris Bar.
Senior Consultant, NERA, Paris
Mr. Gonnet has supervised several large French and pan-European transfer pricing documentation and planning projects in a range of industries, including consumer products, pharmaceuticals, and electronics. Prior to joining NERA, Mr. Gonnet was a transfer pricing specialist within the KPMG tax network in Paris.
Mr. Gonnet obtained a Masters in science of business and administration from HEC (Ecole des Hautes Etudes Commerciales) in Paris, and holds a Masters in tax law (with a specialisation in international taxation) from the Paris II Law University.
Alexander VoegeleChairman, NERA Economic Consulting, Frankfurt
During more than 25 years advising international corporations and leading law firms on transfer pricing issues, Alexander Voegele has specialised in the development of innovative economic structures for transfer pricing strategies and for the defense of major international transfer pricing cases. He has led hundreds of large transfer pricing projects and defense cases for a variety of clients in a range of industries. Prior to joining NERA, Dr Voegele was a partner with PriceWaterhouse and KPMG, where he was in charge of their German transfer pricing practice.
He holds a doctorate in economics and a Master of tax and business administration from the University of Mannheim. He is a certified German auditor and tax adviser and is a French Commissaire aux Comptes.
He has received numerous awards as a transfer pricing adviser and has frequently been ranked as a leading tax and transfer pricing professional.
Philip de HomontConsultant, NERA Economic Consulting, Frankfurt
Philip de Homont specializes in complicated transfer pricing audits and the valuation of intellectual property for international corporations and law firms. He has defended major transfer pricing cases throughout Europe and the Americas in a wide range of industries from consumer goods to financial services.
He holds a MSc in Economics from the University of Warwick and a Masters-equivalent in Physics from the Technische Universität München.
Philip de Homont is the co-author of dozens of articles and two books on transfer pricing and intellectual property valuation. He has participated in various transfer pricing conferences.
Kari PahlmanPrincipal, KPMG, Hong Kong
Kari Pahlman leads more than 500 KPMG transfer pricing professionals across the Asia Pacific region and has over twelve years of experience in tax and financial advisory in relation to international taxation, transfer pricing and valuations. He specialises in various economic advisory assignments in relation to transfer pricing, tax effective supply chain management and asset valuations and has served as an engagement leader for numerous regional and global projects in these areas.
Kari's industry experience in transfer pricing work spans across industrial and consumer markets, financial services as well as information and communications industries. His recent engagements in Asia include regional transfer pricing and supply chain management work, both from compliance and planning perspectives, for global consumer product manufactures, industrial product suppliers, banking and insurance institutions, asset management corporations as well as IT and media companies.
Catherine GalvinTax Principal, Matheson Ormsby Prentice, Dublin
Catherine practises corporate tax and advises on inward investment, cross border tax planning and transfer pricing issues. She advises many of the leading international corporations and financial institutions doing business in and through Ireland.
Catherine has been recommended in Tax: Chambers Global 2010 and2008, Tax: Chambers Europe 2009 and has been recognized as a leading lawyer by international legal directories such as World Tax 2008, PLC Which Lawyer and Euromoney Expert Guides. She is a member of the Institute of Chartered accountants in Ireland.
Yariv Ben-DovFounding Partner, Bar-Zvi & Ben-Dov Law Offices, Ramat Gan
Yariv Ben-Dov is one of the founding partners of Bar-Zvi & Ben-Dov Law Offices. Prior to this he was the Head of the Transfer Pricing Unit of the global Teva Pharmaceuticals group. Yariv has advised the Israeli Tax Authorities on matters relating to local transfer pricing legislation and has also advised many international conglomerates in various fields of industry assisting them in facilitating and implementing complex transfer pricing matters.
Yariv is an Adjunct Professor in transfer pricing at the University of Haifa, Israel and is a seasoned speaker in both national and international transfer pricing conferences.
Associate Maisto & Associati, Italy
Aurelio Massimiano is associate of Maisto e Associati since 2005, after having worked for the International Tax Office of the Italian Revenue Agency. His areas of expertise are international taxation and transfer pricing. He is the permanent assistant of Professor Guglielmo Maisto at the EU Joint Transfer Pricing Forum.
Cosmos International Management Co., Ltd
Takuma Mimura is Managing Director of Cosmos-International Management, a transfer pricing boutique consulting firm in Japan. He has more than 14 years of transfer pricing experience, including 6 years at Deloitte Touche Tohmatsu (both Tokyo and New York), and international banking experience prior to transfer pricing. He has worked extensively with transfer pricing issues worldwide and is especially experienced in Japan, U.S. and China TP matters. He has also worked with a broad range of clients in manufacturing, financial services and telecommunications and has assisted many taxpayers in negotiations with the Japanese tax authorities on transfer pricing audit examinations.
Takuma has authored articles for professional journals including BNA Transfer Pricing Report and Monthly International Taxation of Japan, and is a frequent speaker on transfer pricing topics.
Moises Curiel Garcia
Principal-Director of the Latin American Transfer Pricing Practice, Baker & McKenzie, Mexico City
Moisés Curiel is a member of the Firm’s Transfer Pricing Practice Group. He is recognised by International Tax Review as one of Mexico’s top tax advisers, and has served as the Transfer Pricing Audits and Resolutions administrator of Mexico’s Ministry of Finance and Public Credit for seven years. Mr. Curiel helped prepare and implement various tax transfer pricing rules in Mexico, including the Income Tax Law, the Omnibus Tax Ruling and the Federal Tax Code. He also led the Advance Pricing Agreements Program in Mexico, where he negotiated over 300 unilateral agreements and 34 bilateral agreements. His impressive track record also includes proposing amendments to legislation on various matters for Latin American countries, and representing Mexico before the OECD for the transfer pricing party (WP6).
Monique van Herksen
Partner, Ernst & Young/Holland van Gijzen Amsterdam and Head EMEIA Transfer Pricing Controversy for Ernst & Young.
Monique Van Herksen is qualified both as civil law lawyer and common law lawyer and specialises in international tax law with an emphasis on transfer pricing, exchange of information, cross-border transactions, treaties, litigation and competent authority issues. She is experienced in legal and tax law matters between the US, the Netherlands and the Netherlands Antilles.
She has been involved in a great variety of transfer pricing issues and APAs including recently the planning/implementing of a CDM structure under the Kyoto Protocol.
Leslie Prescott-HaarCeteris, Auckland
Leading the New Zealand office, Leslie joined Ceteris with nearly 15 years of international transfer pricing experience in Australia, New Zealand and the United States. Prior to joining Ceteris, Leslie was the national leader for Ernst & Young’s New Zealand Transfer Pricing practice as well as providing expertise on tax integrated supply chain services. Leslie has considerable experience across an extensive range of industries.
She was the lead advisor in relation to the first bilateral APAs executed in respect of New Zealand-based multinational organizations for Australia, Japan, and the United States. Leslie has more APA experience and general transfer pricing experience than any other transfer pricing specialist in New Zealand.
Managing Partner, Deloitte, Warsaw
Iwona Georgijew is a managing partner of Deloitte’s Transfer Pricing National Practice in Poland and Deloitte’s regional Transfer Pricing Group for Central and Eastern Europe. She supervises projects on structuring, documenting, auditing and defending intercompany transactions for both local and international clients. In the Guide to the World’s Leading Transfer Pricing Advisors (by Euromoney Magazine) she was appointed a leading Polish transfer pricing advisor in 2006/2007 and 2008/2009.
Patrícia MatosAssociate Partner at Deloitte & Associados SROC, S.A., Lisbon
Patrícia Matos is currently Associate Partner in Deloitte’s Lisbon office in the transfer pricing department.
Patrícia has a business degree and is a chartered accountant. She started her professional career in Arthur Andersen (Arthur Andersen, S.A., presently Deloitte & Touche as result of an effective association of both firms since April 2002) in 1997 and was promoted to Associate Partner in 2008.
Patrícia has extensive experience in tax planning, due diligence and tax compliance for Portuguese and Multinational companies. In 2002, she began working exclusively in transfer pricing. She advises clients in several aspects of transfer pricing, ranging from tax audits to comprehensive transfer pricing planning, structuring of intercompany transactions and defensive documentation.
Her experience spans a wide range of industries including communications, technology, media, financial services, automotive, consumer goods, tourism and pharmaceuticals.
Patrícia has been a speaker at several seminars and conferences on tax, economic and transfer pricing issues.
Republic of Korea
Dr. Tae-Hyung KimDeloitte, Korea
Dr. Tae-Hyung Kim is a senior partner and the national leader of the Global Transfer Pricing Group at Deloitte, Korea. Over more than 14 years, Dr. Kim has represented multinational corporations in various industries in transfer pricing audit defense, advance pricing agreement negotiations, mutual agreement procedures, and planning and documentation studies.
Prior to his current position, Dr. Kim headed the national transfer pricing practice at other Big Four firm in Korea and the Law and Economics Consulting Group in Korea. Before specializing in transfer pricing, Dr. Kim was a research fellow for the Korea Institute for International Economic Policy (KIEP). During his tenure at the KIEP, he advised the Ministry of Finance and Economy, the Ministry of Commerce, Industry, and Energy and the Ministry of Foreign Affairs in the area of international trade and investment policies.
Dr. Kim’ s recent publications appear in IBFD’s International Transfer Pricing Journal, BNA Tax Management’s Transfer Pricing Reports, and Euromoney’s Transfer Pricing Reviews. His economics publications also appear in Canadian Journal of Economics and Review of International Economics.
He holds a Ph.D. in economics from the University of Washington and is a graduate of Advanced Management Programs of both Harvard Business School and Seoul National University.
Evgenia VeterErnst & Young, Moscow
Evgenia joined the firm as a partner in March 2011. Before that she worked for more than 15 years with another Big Four company where she obtained extensive experience in providing advisory services to Russian and international companies on various areas of taxation and conducting business in Russia, structuring investments, and coordinating approaches to tax planning. Since 2007 Evgenia has been focusing on transfer pricing. She has led transfer pricing planning and documentation projects for multinational and Russian clients in various industry sectors, including structuring of entry/exit strategies of clients from the transfer pricing perspective, adaptation of global transfer pricing policies to Russian requirements, business restructuring, development of sustainable transfer pricing methodologies, etc. Evgenia specialises on serving companies working in retail, consumer products and life science industries. She is currently a Partner in the Transfer Pricing Group for Ernst & Young in Moscow.
Partner, PricewaterhouseCoopers Services LLP, Singapore
Gavin Helmer is a Partner in PricewaterhouseCoopers’ Singapore Financial Services Tax practice, where he is in charge of the Financial Services Transfer Pricing practice, providing transfer pricing advisory and compliance services to clients in the banking, asset management and insurance sectors.
Gavin has over 16 years of tax experience in the financial services industry, having worked as the Regional Tax Counsel for Europe, then as the Global Head of Transfer Pricing, for UBS, and later as the Head of International Tax for Standard Bank of South Africa. Given his industry experience, as well as running the Transfer Pricing practice Gavin is involved in advising clients on all aspects of international taxation, as well as tax department governance and tax risk management and control.
Michael HoniballPartner in the Tax Department of Webber Wentzel Attorneys
Michael Honiball is a Partner in the Tax Department of Webber Wentzel Attorneys, which is the leading law firm in South Africa.
Michael has substantial transfer pricing and tax advisory experience and has specialised in South African domestic and international corporate tax issues for over 20 years, advising many multinational corporations on a wide range of tax compliance, structuring and financing matters. Michael advises on a broad spectrum of transfer-pricing issues, from documentation and planning to dispute resolution, taking into account the unique circumstances of various African jurisdictions.
Michael is a visiting professor at the University of Johannesburg and is a regular speaker at professional conferences. He is also a co-author of the book International Tax: a South African Perspective 2008 (now in its fourth edition), together with Professor Lynette Olivier of the University of Pretoria, which contains a chapter on transfer pricing.
Michael is a well-known tax adviser in South Africa, being listed in The Guide to the World's Leading Tax Advisers and Who's Who of Southern Africa 2005.
Global Transfer Pricing Services, Partner, Tax Department, KPMG Abogados, Barcelona
Ms. Trapé joined KPMG in 2007 and has worked on numerous transfer pricing projects including transfer pricing policy design, documentation work, APA negotiations as well as audit defence and recourse in transfer pricing cases and international taxation. Her work has spanned the financial, consumer products, energy and pharmaceutical sectors.
Prior to joining KPMG, Montserrat Trapé worked at the Spanish Revenue Service. As Co-Director of International taxation she was responsible for negotiating several multilateral and bilateral APAs, judicial defence of TP assessments as well as actively participating in the new transfer pricing legislation. Ms Trapé was also Vice-Chair of the European Union Joint Transfer Pricing Forum for four years. During this period, the JTPF worked on recommendations for the effective implementation of the Arbitration Convention, on a transfer pricing model documentation to simplify documentation compliance requirements and on a report on best practices for APA within Europe.
Montserrat Trapé is also a Visiting Professor at ESADE Instituto de Estudios Fiscales, where she has conducted several training courses for Spanish & Latin American Tax Authorities in Madrid. She is a frequent public speaker and contributor to articles and books on transfer pricing, dispute resolution mechanisms and international taxation issues.
Ms Trapé has been included in the list of 2009 and 2010 "Best lawyers" in Spain.
Transfer Pricing Partner, PricewaterhouseCoopers, Zurich
Benjamin Koch is a transfer pricing partner in the tax and legal services practice of PricewaterhouseCoopers Switzerland. His experience includes advising multinational companies on the structuring of global manufacturing and distribution structures, migration of intangible property, establishing global trademark royalty schemes and the development of intra group service fee concepts. Furthermore, he has substantial experience assisting companies in preventing tax audits and managing international tax controversies through the use of advance pricing arrangements (APAs), tax rulings and mutual agreement procedures (MAPs).