- Transfer pricing advice for 2 large MNE’s
- Work on EU infringement complaints and an EU project
- Restructuring of a small Dutch group
- Assist MNE with Danish inward investment
- Give second opinions on big 4 tax planning proposals
- Test substance of accusations of unethical CSR in taxes
- 5 day in-house trainings on BEPS at multinationals
- 8 day Summer school on international taxation at UniAndes, Bogota
- See my newspage for publications, conference and other academic activities
Work at SKAT (Danish Competent Authority – Transfer Pricing). January 2012 - October 2014
- Work on different (multiple country) Mutual Agreement Procedures and Advance Pricing Agreements
- Develop software solutions for tracking international taxpayer info, using Orbis, Excel and Access
- Participate in various tax related projects in the hydro carbon industry
- Danish representative to WP6 (transfer pricing) at the OECD
- Ran various international tax training courses and transfer pricing courses within SKAT and the Nordics
Work at A.P. Moller – Maersk A/S. September 2006 – January 2012.
- Started as Manager; promoted to General Manager, Senior General Manager and then Director. Moved from individual contributor to head of tax risk management and then head of tax of Maersk Drilling.
- Separated business divisions into separate companies worldwide.
- Assisted with major tax disputes regarding transfer pricing, shipping, permanent establishments and capital gains. Met with tax authorities and tax ministries.
- Assisted with various tax audits and face to face negotiations with tax authorities in various countries.
- Created legally robust, tax efficient, and business friendly structures for complex business divisions.
- Set up a group wide tax risk management, monitor and tracking system.
- Developed software to enable reporting in Sharepoint, data extraction from Hyperion to Excel and presentation in Excel / Access.
- Ensured adequate substance and proper transfer pricing policies for foreign subsidiaries.
Worked as transfer pricing consultant at Carlsberg. May – August 2006
Prepared TP documentation. Focused on data quality and setting up automated procedures to minimize efforts for future updates by pulling data from SAP to Excel templates.
Ran own business, Dutchtax.net. August 2002 to April 2006
Participated in unwinding of synthetic lease structures. Elimination of free movement of capital discrimination against the International Red Cross. Worked on succession restructure of major Swiss multinational. Ran a subscriber based website on Dutch international tax law – big four and major Dutch law firms were subscribers.
Various Dutch law firms. June 1994 to August 2002 in Amsterdam, London & New York
Worked on hybrid entity structures between Germany and Holland. Migrated a non-UK company to London and listed on the FTSE 100. Set up a Dutch group financing company under. Successfully advocated for new Dutch rules on partnership qualification. Worked on US-Dutch and US-Luxembourg hybrid financing structures. Participated in Israeli/Japanese debt optimization program. Worked on several US/Dutch, US/Portugal & US/French cross border leasing structures.
Ernst & Young. June 1990 – June 1994
Work in the Dutch international ruling practice. Advised and prepared tax returns for international holding companies, finance companies and licensing companies. Worked on Dutch company with Swiss finance branch. UK company with Dutch shareholding PE, and cross border migration of companies.
- Born in Pretoria, South Africa, 26 August 1964.
- Dutch citizen
- Live in Denmark, Drosselvej 20, Frederiksberg 2000
- Speaks English, Afrikaans, Dutch, Danish (almost fluent, am learning), understands some German
- Mobile +45-6120 2911, Private email Johann.H.Muller@gmail.com
- Finished law degree (equivalent of LLM) at University of Amsterdam 1989, major in tax
- Completed various other legal courses at University of Amsterdam 1990 – 1994
- Completed Dutch tax advisers diploma in 1994 and passed Dutch bar exam in 1997
- Finished course in US International Taxation at Leiden University in 1996
- Passed ADIT exam (Advanced Diploma in International Taxation) in May 2007
- Completed various (management) courses at Maersk 2006 – 2011
- Was a member of the Dutch bar 1995 – 2006
- Am a member of the International Fiscal Association since 1996
- Was a member of the European American Tax Institute. Acted as country chapter president for the US and for the Netherlands 1999 - 2002. Was European Chapter President 2002 – 2006
- Was a member of the Tax Executives Institute since 2006. Was chairman of the European Direct Tax Committee 2007 till 2010
- Published a book, “The Netherlands in International Tax Planning” with the International Bureau of Fiscal Documentation in 2005, second edition 2007
- Published numerous articles on International tax law and direct taxation under EU law
- Taught various 1 & 2 day courses on Dutch tax law and EU direct tax law with different organizations
- Participated in various congresses from various organizations as speaker / chair person
- Participated in face to face meetings with the OECD on business reorganizations, the allocation of profits to permanent establishments, and Intangibles
- Attended annual UN Committee of Tax Experts from 2008 – 2011
- Published 2 articles on BEPS and Value Chain Analysis in transfer pricing in 2013
- Published a test booklet on the EC Parent Subsidiary Directive and case law on Kindle, December 2013
- Published A practical summary of the 2010 OECD Transfer Pricing Guidelines for Kindle, May 2014