Daniel Hewera, LL.M. (GGU)

Professional Education

• Postgraduate studies in American and international tax laws at Golden Gate University/San Francisco (LL.M. in Taxation)
• Legal clerkship at the Higher Regional Court Dusseldorf
• Law studies at the universities of Bonn, Regensburg and Lausanne

Professional experience

• Manager (Tax/Transfer Pricing), PricewaterhouseCoopers AG WPG, Essen
• Staff member (Transfer Pricing), KPMG AG WPG, Essen

Key Areas of Expertise

• Analysis, structuring and implementation of transfer pricing systems
• Examination und drafting of (intra-group) sales and services under tax considerations
• Preparation of transfer pricing documentation and transfer pricing documentation guidelines
• Transfer pricing defense in tax audits
• Tax advice in connection with regard to transfer of functions under legal and economic considerations
• Legal assistance with regard to Advance Pricing Agreements (APA), Mutual Agreement Procedures (MAP) and Tax Court proceedings
• Tax and legal advice with regard to employee secondments and drafting of respective legal contracts
• Tax and legal advice in international tax matters (e.g. permanent establishments including the respective profit allocations, withholding taxes), focusing also on the mitigation of general tax risks

Industries

• Energy
• Trading companies
• Mechanical engineering companies
• Industrial goods

Further information

• Frequent speaker on external and internal seminars