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WTS Global Company Profile 2017 WTS Global: The leading independent tax network Founded in 2003 by WTS Germany More than 130 countries Over 3,500 tax professionals Fully fledged tax service portfolio No audit, free from


  1. WTS Global Company Profile 2017

  2. WTS Global: The leading independent tax network » Founded in 2003 by WTS Germany » More than 130 countries » Over 3,500 tax professionals » Fully fledged tax service portfolio » No audit, free from conflict » Stringent quality reviews » Centrally managed organisation » Broad client base: From multinationals to private clients WTS Global - Company Profile 2

  3. Connecting the world„s leading tax experts » Over 100 hand-picked partner firms » Recent tax awards within WTS Global include (inter alia) › Chambers and Partners • Tier 1 ranked global network 2017 • WTS Global (continuously since 2012) International Tax Review › • European Indirect Tax Firm of the Year 2017 • WTS Global • Germany Tax Firm of the Year 2017 • WTS Germany • India Tax Firm of the Year 2017 • Dhruva Advisors • Uruguay Tax Firm of the Year 2017 • Ferrere WTS Global - Company Profile 3

  4. Global key values - our corporate DNA Innovative Excellent » Open-minded: Having an entrepreneurial spirit » Technical competence of the highest standards » Keen-spirited: Always curious about new » Top quality services developments and trends » Highly efficient, customised implementation of » Inquisitive challengers: Creating inventive practical solutions solutions for ever-changing challenges » Unique expertise based on multiyear » Forward thinkers: Pioneering digitisation and experience in industry, financial management the development of IT tax tools and consultancy Passionate Reliable » Working with pleasure and enthusiasm » Loyal partners, keeping our promises » Taking responsibilities and objectives with a » Quick response times and needs-based high degree of personal commitment solutions » Fully dedicated and people-focused: supportive » Responsible conduct and long-term strategy of and caring cooperation WTS Global - Company Profile 4

  5. Our global client portfolio: Supporting a broad range of clients from all industries » Multinational companies » Non-profit organisations » Small and medium-sized companies » Private clients & family offices WTS Global - Company Profile 5

  6. Offering a fully-fledged tax service portfolio globally Global services » Corporate Tax » Private Clients & Family Office Services » Mergers & Acquisitions » Global Mobility » Transfer Pricing & Valuation Services » Tax Controversy » Indirect Tax » International Tax and Permanent Establishments (ITP) » Customs Additional cross-cutting services » Financial Services » Real Estate » Tax Technology WTS Global - Company Profile 6

  7. Shaping the future by anticipating trends Digitisation Business Partnering EU Audit Reform Tax Control US Tax Reform Framework BEPS – Litigation VAT in the GCC and Arbitration WTS Global - Company Profile 7

  8. Global trend: Business Partnering Pioneering innovative tax partnerships » WTS Experience » Client benefits » < 15 years (WTS Germany) » Increaseing quality and flexibility » 50% of WTS Germany„s turnover » Reducing overall costs » Retaining in-house expertise and gaining permanent access to specialists around the world » Keeping governance and control in-house » Choice of tailored scope of services “A pioneered deal” by International Tax Review » Saving resources for strategic activities (Feb 8, 2017) WTS Global - Company Profile 8

  9. Global trend: Digitisation Designing digitisation proactively Tax sector is changing Opportunities for companies WTS develops individual, future-proof solutions » Tax processes are re-defined » Increased process and cost » Many years of experience in and largely automated efficiency digital process consulting worldwide » Increased compliance safety, » In-house tax tool experts » Integration of mass data, minimisation of liability risks » Validated set of IT tax tools artificial intelligence (AI) and » Evaluation of innovative IT tools concepts in cooperation with top researchers » Establishment of solutions which closely link tax functions and business processes WTS Global - Company Profile 9

  10. Global trend: BEPS (Base Erosion and Profit Shifting) BEPS: Generating benefits from obligations A total of 15 action items of the OECD against aggressive tax planning ! Need for action Opportunities 7: Business premises Smart use of process-supporting tools: » Checking existing structures and projects for » Minimising tax risks undetected business premises » Fulfilling reporting requirements in a reliable 13: Documenting transfer prices and efficient way » Introducing Master File » Using data in parallel with optimisation of the (revenue ≥ € 100m) existing transfer pricing system » Preparing a country-by-country report (consolidated revenue ≥ € 750m) WTS Global - Company Profile 10

  11. Global trend: Tax Control Framework Tax Control Framework: Minimising error rates and liability risks » Prevention » Analysis » Control » Timely company audit » Data analytics / mass » Internal revision data » Tax control framework » Tax audit (incl. joint audit) » Tax audit simulation » Checking processes and » Audit › systems through tax Profit tax audit › Sales tax » Use of tax technology › Income tax › Customs duties Cooperative Compliance WTS Global - Company Profile 11

  12. Trend: EU Audit Reform EU Audit Reform: Consulting without conflict – only with WTS Many companies are affected, especially capital market-oriented companies, ! banks and insurance companies » Germany » Other EU countries » Prohibited non-audit services during cooling- » Increased complexity with transnational in phase (1 year) and auditing activities: activities › Customs, income tax, tax control » Due to stronger regulations by numerous EU framework, tax asset management countries, it is necessary to frequently change advisors abroad, e.g. › Tax advisory services with considerable › reduction of the tax base or with transfer Basic prohibition of tax advisory services, of profits to foreign countries, e.g. group e.g. in France structure, transfer pricing, › Expansion of affected companies, e.g. Luxembourg/Ireland Model* Italy, Spain » Fee cap: Permissive non-audit services of › Longer cooling-in periods, e.g. France**, max. 70% of the average total fees of the Portugal, The Netherlands past three years * Affects, for example, US investors ** Cooling- in phase is 6 years; joint audit is obligatory if company is a PIE, i.e. basically two auditing companies are „conflicted“ WTS Global - Company Profile 12

  13. Global trend: US Tax Reform US Tax Reform: Increasing global competitiveness » Intended to encourage domestic growth and » Timing delayed due to Administration decision make the US Tax Regime more competitive to repeal Obamacare as first priority globally » 2017 enactment questionable » No tax legislation currently in progress True tax reform vs. Tax rate reduction? Revenue neutrality vs. Increase to the deficit? Possible components of corporate tax reform » Reduced corporate income tax rate (various » One-time tax on existing offshore deferred profits rates from 15% to 20% have been proposed) » Eliminating a number of corporate deductions » Move from worldwide tax to a territorial tax » Immediate deductibility of cost of certain capital system investments » Reduction or elimination of interest expense » Potential changes in Net Operating Loss rules deduction » Repeal of Medical Device Tax separately through » Eliminating various “special interest” deductions Healthcare legislation and credits WTS Global - Company Profile 13

  14. Global trend: VAT in the GCC VAT in the Golf Cooperation Council: Introducing 5% VAT » Introduction of 5% VAT in GCC covering the UAE, Bahrain, Saudi Arabia, Oman and Kuwait » Anticipated implementation in 2018 » Need for action » Opportunities » Awareness » Training » Business impact » Impact assessment and diagnostic reviews » Systems & documentation » Tax advisory and strategy » Compliance » Implementation assistance and redesigning business processes » VAT audit, compliance support and outsourcing WTS Global - Company Profile 14

  15. Our global service lines and regions: Ensuring seamless project progress Organised as a matrix structure TP Indirect M&A ITP* Global Private Digital Tax Mobility Clients Solutions Americas Asia Pacific Africa Europe *International Tax & Permanent Establishments WTS Global - Company Profile 15

  16. Service line: TP Transfer Pricing (TP) Scope of Services: Maik Heggmair Partner » Planning and implementation of TP systems and TP WTS (Munich) policies +49 (0) 89 28646-212 » OECD BEPS-compliant TP documentation and maik.heggmair@wts.de economic analyses Jared Walls » TP advice in business restructurings Partner » Defense in TP tax audit and litigation matters Economic Partners (Morristown, NJ) » Advice and assistance in APAs and MAPs +1 (0) 530 301-1818 » Valuation for TP purposes, including IP and exit jared.walls@econpartners.com taxation matters Areas of Focus / USPs: IT-Tools: » IT-supported solutions for transfer pricing » TPmanager » Combined expertise from former in-house tax » CbCR Manager departments, consulting and tax administration » CbCR-2-XML Manager » Interdisciplinary team of certified tax advisers » Economists and lawyers WTS Global - Company Profile 16

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