PERSBERICHT :: COMMUNIQUÉ DE PRESSE :: PRESS RELEASE

Brussels, 12 October 2015 TIVALOR: A new Challenger on the market of business and legal economics consulting

We are pleased to announce the launch of TIVALOR on 13 October 2015, a new professional service offering in the fields of Business & Legal Economics, focusing on Transfer Pricing, Valuations, Business Modeling and Legal Economics. TIVALOR is a joint venture between tax law firm Tiberghien and Andy Neuteleers, a seasoned transfer pricing and valuation professional. The creation of TIVALOR follows closely on the recent developments at G20/OECD and EC-level to alter the rules in international taxation drastically, leading to an ‘economization’ of the fiscal profession.

Andy Neuteleers (L), partner Tivalor, en Koen Morbée (R), partner Tiberghien

In close collaboration with Tiberghien, TIVALOR will offer solutions that integrate financialeconomic with tax legal and procedural expertise. Yet, TIVALOR will operate a distinct business model independent of Tiberghien, given deontological considerations, but also considering its unique business operations that go beyond taxation issues.

TIVALOR has the goal to provide a true alternative for the current professional services industry’s Push As Much As You Can - model, and therefore has developed its own distinct and measurable service approach enabling their clients to grow into a self-sustaining, lean and agile solution manager, where TIVALOR people can focus on what they truly are passionate about: being the coach of businesses and of people in business. TIVALOR’s mission is to inspire businesses and their people, seeking to bring them professional and personal HAPPINESS and COMFORT, creating EXPERIENCES enabling them to STAND OUT. TIVALOR’s main office is at Tour & Taxis Brussels, but will also be able to meet in Antwerp and Luxembourg, in collaboration with Tiberghien. TIVALOR will be aligned with the global WTS network, headquartered in Münich and with presence in over 100 countries. TIVALOR today has 4 dedicated professionals available, but has the ambition to grow to 12 professionals within We gladly refer to the following sources of additional information: the time frame of 2.5 years. •

Annex: Detailed info and commentary by Andy Neuteleers, partner Tivalor, and Koen Morbée, partner Tiberghien (in English)

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On 13 October 2015, we will launch our website www.tivalor.com

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In the meantime we have made available a full version preview for the press, which can be reached at www.tivalor.consulting

For further queries or interviews, please contact: •

Annex: Info en duiding door Andy Neuteleers, partner Tivalor, en Koen Morbée, partner Tiberghien (in English)

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Onze website www.tivalor.com

Voor bijkomende informatie of interviews kan u contact opnemen met: •

Anne De Vos | Marketing Manager | +32 495 916 680 | [email protected]

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Koen Morbée | Partner | +32 476 684 354 | [email protected]

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Andy Neuteleers |Partner |+32 471 892 316 | [email protected]

ANNEX

Detailed info and commentary by Andy Neuteleers, partner Tivalor, and Koen Morbée, partner Tiberghien

Organizational set-up Tivalor is a joint venture between the renowned Belgian tax lawyers of Tiberghien and Andy Neuteleers, a seasoned transfer pricing and valuation professional with Big4 experience in Belgium and abroad, as well as having founded more lately the first independent international tax, transfer pricing and valuations boutique in Belgium. Tivalor itself currently starts its offering with 3 dedicated economist professionals, supported with one dedicated legal counsel of Tiberghien, since the aim is to offer highly integrated economic-juridical solutions to the transfer pricing and tax valuation issues their clients face. Yet, notwithstanding the valuable synergies this joint venture aims to realize for the benefit of both entities’ clients, both companies will remain independently responsible for their respective business models and client service offerings (where one may be the contractor and the other party a subcontractor, or vice versa, or where both entities directly service the same client individual). Not only from a deontological perspective there is the requirement to strictly separate the responsibility of our deliverables, but in our view operating separate business models reflects the necessity to be able to offer distinct services and allow both entities to further grow their client base independently. Tivalor will in collaboration with Tiberghien be located in the Tour & Taxis building in Brussels, but also can make use of the meeting rooms and facilities of Tiberghien at their Antwerp and Luxembourg offices. Our main place of business, however, will be at our client’s premises to enable an efficient and effective transfer of our know-how and processes. Also, in alignment with Tiberghien’s service approach, Tivalor will form part (in a non-exclusive manner) of the global WTS network for being able to offer its transfer pricing solutions in relation to more than 100 jurisdictions across the world. On its turn Tivalor will contribute to the WTS network on an EMEA scale its expertise in Treasury Transfer Pricing (transfer pricing for financial transactions) and Tax Valuations, and therefore has the ambition to play a leading role outside of the BeLux market as well, in particular in respect of the two aforementioned domains of true expertise in transfer pricing and tax.

Koen Morbée, partner with Tiberghien: “Tiberghien has more than 75 years of experience in delivering tax legal advice and procedural solutions with outstanding quality as key proposition. We have found in Andy Neuteleers a trusted partner to also deliver high quality outputs in the fields we have identified as critical to develop economic competencies and capabilities in the fields of transfer pricing and tax valuations for our clients in alignment with our tax legal advice. Indeed, we have noticed an ‘economization’ of the tax legal profession, in particular in the field of international taxation and certain estate domains where tax valuations are critical next to the more juridical counseling required.” Andy Neuteleers, managing partner of Tivalor: “I can echo that such substance-over-form approach in tax practice is increasingly prevailing. Indeed, in the more traditional professional service firms I have been active in, the pendulum even swung completely the other way in the sense that a typical transfer pricing team consists of mostly economists, if not entirely. The tax legal professional’s advice was provided aside of the transfer pricing advice, whilst procedural aspects were often only treated when harm was already done. After my time in such traditional setting, early 2014, I opted to resign from my position as Big4 director for reasons of having greatly different views on how clients should be serviced, but early on in my independent existence, by working for and together with tax and other lawyers I found out that whilst in transfer pricing and tax valuations the focus may be on the financial and economic sides of things, a solid legal consideration is indispensable in many cases, and given the fact that nothing is black or white, it should be best practice to base economic estimates on the procedural consequences of the options chosen. Therefore, I am glad we can combine our knowledge to give integrated advices with solid economics and risk-calibrated delivery modes.” Next to the integrated solutions both offer in support of each other, Tivalor will strategize and operationalize its business around its other clients. Andy Neuteleers: “In practice this means two things: First of all, we also provide services beyond the scope of transfer pricing and tax valuations, such as valuations for other purposes (such as in support of deals) and legal economics (economic analyses in support of legal counseling and legal procedures, such as assisting with IP infringement claims). Secondly, as we can work independently of Tiberghien (our collaboration is only established through a contract with the consent of the client), we also provide our transfer pricing and tax valuation services to colleague firms: small and larger accounting and tax law firms that do not have the transfer pricing or tax valuation expertise themselves, in general or for specialty matters such as financial transactions for which we have developed expertise and many tools.” Koen Morbée adds: “At both Tiberghien and Tivalor we believe in our joint future, as well as in our future as independent firms. Therefore, we both run an open business model, meaning we do not set exclusivities, but can collaborate with anyone in the best interest of the client served as long as there is a common understanding of the values all participants stand for, and the work delivered is of the highest quality.”

Tivalor’s Mission, Vision and Values Tivalor’s mission is to inspire people and businesses by sharing: •

its people’s COMPETENCIES,

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its organization’s CAPABILITIES, and

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its community’s CAPACITY, in order to establish full CONSENT: o

with the required stakeholders of our clients,

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on the value-add of our offered solutions to any of their economic problems, in the fields of:


TRANSFER PRICING,




VALUATIONS,




BUSINESS MODELING, and/or




LEGAL ECONOMICS

Hereby, Tivalor aims to contribute positively to the professional and personal HAPPINESS & COMFORT of all people involved – its own and those of its clients and partners. Tivalor exists to create EXPERIENCES for people and businesses, enabling them to STAND OUT; Hereto we keep on dotting the i’s and crossing the t’s, and placing value and valor central in our service offerings. Andy Neuteleers clarifies that “above mission statement reflects who we are today. It can be found in each of our actions and service deliveries consistently, as it reflects our engaging, unique service approach, the type of problems we solve, and most of all why we are in business, not only to serve companies or the high net worth individuals, but also the serve the people that they represent. For instance, we do not stop at developing an innovative solution that is beneficial for the company we serve, but also want to bring value to the CFO or tax director within the company by sharing our experiences enabling his or hers success (and as such professional and personal happiness). We also want to ensure that our solutions are sustainable, again both for the comfort of the company as well as the represented people, so that they can have a good night sleep…”

Koen Morbée: “Being assured of that the (tax) legal consequences of business (trans)actions have been appropriately considered will increasingly be important in today’s environment of stricter regulations and increasing disputes. It is very easy to do aggressive tax planning today, to think of zero taxation schemes, but in our view, they will not be sustainable. We also see the pressure increase that not only the company will be held liable for their business actions, but also for instance the directors of the company that were involved. Therefore, only through the integration of economic, business model, tax legal and procedural expertise put into action in an anticipative manner, the company and its people can truly make an informed decision on the course of action and navigate through the storms that may lie ahead.” Tivalor is also quite ambitious. Where it today starts as from its launch with 4 dedicated professionals, its intentions are to grow to a team of 12 professionals in a time span that reaches until the end of its second financial year. Tivalor clearly has a vision on who they want to become: •

Tivalor wants to become recognized as a leading professional services firm, however, not measured in size, but in terms of its:

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Expertise and thought leadership,

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Creative and innovative problem solving capacity, and

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Ability to stir emotions

Also, Tivalor thinks of itself to become a true challenger in the market place, with disruptive innovations to service approaches high on its agenda: o

By continuing to invest in the Creativity, Commitment, Courage and Connectivity of its people,

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By being genuinely honest when something is complex and when not, trying to solve for

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But foremost by listening genuinely to the people in the market place, across generations,

the latter by investing in digitalization of best practice solutions, discovering how to best address the real needs of them and of the business they represent •

Subsequently, Tivalor wants to become a hub for facilitating the sharing of experiences through sounding boards: o

Between like-minded professionals – by running a business model that is open for partnering with anyone that shares our vision, as well as

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Between the people in business we serve - by putting our connections and experiences at the disposal of any who may benefit from that

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Finally, Tivalor wishes to create an environment where our people and partners can become true inspirers and game changers

Koen Morbée: “At Tiberghien we are with more than 70 lawyers and in total 100 people across 3 offices, in Brussels, Antwerp and Luxembourg. In Belgium we are by far the largest independent law firm focusing on tax solely. But with more than 75 years of history, the growth ambition of Tivalor in terms of speed seems quite a challenge at first sight, yet not unachievable in our view, considering that they are already well solicited in the market place for starting some turnkey projects”. Andy Neuteleers adds: “During the time I worked as independent consultant I had the time and opportunity to test certain of my assumptions on how clients want to be deserved by talking with many functional business leaders of all sorts of companies, and by doing projects using the service philosophy on which that of Tivalor is based and now fine-tuned. Hence, we are confident that we can offer a fresh way of being of assistance, and looking at my agenda for the coming weeks, such new way of being of assistance apparently was awaited for. Off course is up to us to live up to the service approach we propose, and not let it evolve into a mere fancy business model design. I will need to constantly manage our people (that come from a more traditional setting, and hence were used to cross-selling credo’s), as they have the obligation to constantly remind me that it is ok for clients to do plenty of the work themselves, that it is ok that we transfer know-how and tools, that it is ok to finalize a project without having tried to start a new one… As I experienced that consulting life is much more enjoyable if you look at things differently, without the constant need to cross-sell and without living in fear to give away too much information so that you become in fact superfluous, I have no doubt that everyone at Tivalor, will just as I discover it is enrichening to become a coach to businesses and people in business rather than being considered an overly expensive B2B service provider. I also have no doubts that in current times we can make a viable business of this notwithstanding we will not strive to optimize our per client revenue.” An aspect extremely important for Tivalor is that its people and partners share the core of its values. It all begins with the name Ti’valor, where: •

“Ti” stands for our commitment to go all the way for our clients to come to solutions, by dotting the i’s, crossing the t’s where needed, but “Ti” also highlights our privileged relationship with the renowned tax lawyers of Tiberghien; and

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“Valor” stands for bravery, courage and moxie, which often needed to get the required consent for solving problems and pushing through innovative changes to the game “Valor” also refers to our service lines where the concept of “value” is of increasing importance; Moreover, correct value-for-money is undoubtedly also of importance to our clients served…

Secondly, our values are also comprised in our company’s tagline EXPERIENCE STANDING OUT, and can be subdivided in the following philosophies we adhere to: •

We are in the business of numbers, letters & people

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We are pursuing happiness & comfort for people in business

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We deliver experiences, and stir emotions

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We seek and convey inspiration

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We seek to grow a lean and agile community

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We want our people to stand out from the crowd

Koen Morbée: “One value that we would add to the list, but Andy assured us that for him this is an obvious prerequisite, is that the work we deliver should be of the highest quality standards. At Tiberghien we take pride at the quality of our work, and we firmly belief this also sets us apart. We welcomed Andy’s idea to add more business perspective to maybe the more traditional values we have as a law firm. For us, these accordingly are also exciting times. One thing we were sure of from the start, that Andy’s expertise in transfer pricing, business restructurings and tax valuations which demand a different type of mindset than valuations for other purposes is unrivalled. We worked on files together with other economic consultants before, amongst others with Andy’s previous venture, and there we concluded that he could add an extra dimension we did not spot earlier.” Andy Neuteleers: “The day that I could offer my services for Tiberghien, I remember, was also from my point of view a special day, in the sense that at my time with the larger accounting offices I had to consider aspects that I never had to consider before; The feeling of being able to work complimentary, even in the domains I considered myself an expert (and hence of the idea I was not in the highest need of a thorough legal substantiation and analysis next to my economic) truly was an eye-opener. I think on the quality ambition level, we have found each other very well. The mission, vision an values that I developed earlier and have fine-tuned together with my team are not intended to do something fancy, but are genuinely a consequence of our firm believe that in our practice areas the clients want and deserve a different approach”.

Our engaging 4C² Approach All the above views on mission, vision and values come together in what we call our 4C² Approach, which is our framework for running our business daily, reminding us of set objectives, and for operationalizing our projects in a measurable manner. In our view, any project requires the appropriate deployments of the following four components: •

Competencies – know-how and intelligence, knowing the transfer pricing regulations, valuation methods, how businesses work, having access to economic and financial data, understanding market dynamics, etc.

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Capabilities – processes and tools, enablers of putting into effect the above competencies in an efficient and effective manner, project management skills, etc.

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Capacity – time and budget, enablers of running a project in a timely and efficient manner

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Consent – approval and empowerment (without these any project executed with best use of the other 3C’s, the project would be virtually invaluable), as may be required from various types of stakeholders: tax authorities, people in other of parts of the companies that are affected by a change in business model, shareholders, buyers, judges, etc.

The parts linking these 4C’s, and equivalently req uired to make any project a success: •

Commitment – as success follows passion and perseverance

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Creativity – as sometimes new insights, perspectives and analytics are to be discovered and developed since hardly any of the projects will entirely have the same requirements (not meaning that we everything is complex and we cannot leverage from existing expertise)

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Courage – sometimes things need to be said and followed through in view of successful completion of a project, also when it may be sensitive – we are a genuine sounding board, and dare to say no; and

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Connectivity – we do not live on an island; we have plenty of aligned experts to virtually tackle any problem, and with whom we can seamlessly work together

The basic advantage of the 4C² Approach, and why this is genuinely beneficial for our clients, lies within the following two of our basic working assumptions: •

It would be stupid of us to imagine that on all components that make up a project Tivalor has greater competencies and capabilities than our clients themselves, and that therefore, we would be naturally entitled to do all of the work ourselves, from A to Z, unless the client would not have the Capacity to do so himself considering other competing priorities that may exist.

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Getting Consent is the joint responsibility of the joint project owners, at the client and at Tivalor.

Andy Neuteleers: “Taking into account above working assumptions, we acknowledge that perhaps and certainly for certain items the client has more competencies to bring to the table as us and/or may have adequate capabilities in place. A simple example in the field of transfer pricing is that it is required to identify and document effectively the working of the business: what is the industry’s and the business’ value chain, what are the critical success factors and key value drivers. Notwithstanding I have dealt with plenty of different industries and different types of businesses in those industries, and notwithstanding I have the tools and methods to analyse an industry, I genuinely believe that much more useful information can be produced by the client itself. Considering the client would have the capacity to provide this information, perhaps he or she does not have the capabilities to put the information in the correct perspective (one that leads a tax inspector to the appropriate conclusion). Our role for this part then could be limited to transfer our capabilities (tools such as template, guidance for storytelling required, etc.) to the client for enabling him to do so, and perhaps in the first year train him or her closely, and in subsequent years only perform a limited review, and act as a coach.” Each situation is different, but it all starts with our clear statement that not everything is complex, and that not everything is absolutely required to be performed by Tivalor. Andy Neuteleers: “Agreed, transfer pricing for instance is a hot topic. But not all aspects are complex; We specialize in the complex matters and are happy to share We rather add our 4C²s to those that can be made available by our clients, and offer a true sharing of experiences for them to grow organically in their ability to solve complex economic problems largely in-house; In such scenario, over time, Tivalor endeavors to assume the role of a business coach rather than that of an external service provider.” For any project, or part of a project or task, that has the feature of being reviewed or updated periodically, we ensure that our clients grow their internal 4C²s by transferring ours – e.g. to build an internal Transfer Pricing function. Accordingly, we propose an evolving service offering, not only looking at solving technical issues but also focusing on your internal processes and controls, on which basis we want to build an enduring relationship with our clients.