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Corporate taxation in the global offshore shipping industry

Corporate taxation in the global offshore shipping industry 3

Contents

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Introduction 4

Executive Summary 6

Vessel types related to the oil & gas offshore industry 8

Vessel types related to the offshore wind farm and offshore construction industry 10

Vessel types related to other services provided offshore 12

Other tax incentives for shipping entities 14

Final remark 15

Territory contacts 16

4 Corporate taxation in the global offshore shipping industry

Introduction

In this paper, we focus specifically on shipping companies that are part of the value chain within the offshore industry (wind farms, oil rigs etc.). While offshore activities may be more commonly seen as part of the energy businesses, the shipping industry actually performs a number of critical services using highly specialised vessels. These include wind farm construction vessels, accommodation and support vessels, FPSO’s (Floating Production Storage and offloading vessels), anchor handling and drill ships.

The shipping industry has undergone significant developments over the last 15 years, since shipping tax regimes started to be introduced. In addition, the financial crisis put pressure on companies to get more efficient, but that’s not the only way shipping has changed. The industry has also made significant technological advances – and so have the industries shipping companies serve.

The offshore industry is a good example. Traditional fossil energy extraction, green energy and offshore construction have all made significant advances to keep pace with growing demand. That’s led to an increased demand for specialised offshore vessels and for the development of offshore support services around the globe. There has been a significant increase in both the number of market players and in the types and designs of the specialised vessels servicing the sector. And companies have also developed a wider range of shipping services that are offered to the offshore industries within oil & gas, wind farms, and offshore construction projects.

But legal frameworks have not always kept up with this rapid pace of change. For example, recent surveys show that more than 18 vessel types are now being operated during an offshore wind project life cycle — far more than what was anticipated when applicable laws and regulations were drafted for this sector.

1 We have excluded Russia and Brazil from this analysis because our research shows that these countries do not have special tonnage tax incentives aimed towards the offshore shipping industry. For more information on shipping tax incentives in Russia and Brazil, please see our related report Choosing your course - Corporate taxation of the shipping industry around the globe

Shipping companies that are part of the offshore value chain need to understand how differences in tax treatments can affect their business in key territories. This paper, Corporate taxation in the global offshore industry, takes a detailed look at how relevant vessels are handled. It is a supplement to our longer report, “Choosing your course - Corporate taxation of the shipping industry around the globe” , which focuses more broadly on how the shipping industry is taxed. Both papers focus on the countries around the world that are most important for the shipping industry.1

The offshore shipping industry has changed dramatically in recent years, but legal frameworks have not always kept up.

Corporate taxation in the global offshore shipping industry 5

And while a number of countries throughout the world, that act as key centres for shipping services, offer special incentives targeted towards traditional shipping companies operating container, tanker, dry bulk, and passenger vessels, far fewer provide the same beneficial regimes or incentives to offshore shipping players. For example, within the EU, the EU Commission has sanctioned state aid measures such as tonnage tax and net salary/salary tax refund schemes, which member countries can implement in their national legislation. Similar tax incentives are available in numerous countries in Asia, America etc. But these types of regulations haven’t yet kept up with the increasing specialisation of the offshore shipping industry.

Competition in the shipping industry is fierce, and where you locate operations matters. To stay competitive in the offshore environment, companies will need to look for both a competitive regulatory framework and high quality specialised resources that are dedicated to the sector.

This report reviews the tax regimes applicable to shipping companies operating in the offshore sector in a number of key jurisdictions around the globe. Our comparative analysis can help companies evaluate their options when establishing new services and operations or considering relocation of existing operations.

We hope you find it useful reading.

Best Regards

To stay competitive in the offshore environment, companies will need to look for both a competitive regulatory framework and high quality specialised resources that are dedicated to the sector.

Socrates Leptos-BourgiGlobal Shipping & Ports Coordinator Transportation & Logistics Leader Greece

Bo Schou-JacobsenTransportation & Logistics Leader Denmark

Lars Koch VintherTax Leader Shipping Denmark

6 Corporate taxation in the global offshore shipping industry

Executive summary In this report, we provide a condensed overview of the special tax regimes available for shipping companies in certain key jurisdictions around the globe, with a particular view to those that may benefit shipping companies operating in the offshore sector.

Shipping companies operating in the offshore niche market are likely to operate specialised offshore service vessels such as AHTS (Anchor Handling Tug Supply vessels), PSV’s (platform supply vessels), FPSO’s (floating production storage and offloading vessels), wind farm construction vessels, drill ships, seismic vessels, crew transfer vessels, tugs etc. There are significant variations in how tax systems treat each vessel and service type. Our analysis covers 17 carefully selected countries around the globe and focuses on the types of vessels most commonly used in the oil and gas offshore industry, the offshore wind farm industry and various other offshore industries.

Our research shows that there is a broad spectrum of taxation approaches. Countries such as Singapore and Cyprus take a very liberal approach; in these countries, various offshore vessels can generally be covered by their beneficial shipping taxation regime. For instance, Singapore offers an outright tax exemption to income (application required for non-Singapore flagged vessels) derived from the operation of various vessels outside the limits of the port of Singapore regardless of the characteristics of the vessel in question.

Countries such as Malta, UK, Germany, Netherlands and Norway take what we regard as a fairly liberal approach to the applicability of their special taxation of shipping activities to offshore vessels. These countries have more detailed requirements that need to be met in order for offshore activities to benefit from their systems. A number of specific vessels/service types may be or probably are covered by their advantageous taxation of shipping income regimes, assuming that requirements are met. However, a minority of types of vessels might not be or are probably not covered.

In contrast, countries such as Denmark, Ireland, Italy and France take a more restrictive approach to the applicability of their tax regimes to offshore vessels. In these countries vessels are required, either by law or by generally accepted common practice, to exercise some kind of transportation of goods or passengers. That creates a more restrictive environment and impacts the ability of offshore market players situated in these countries to compete over the long term.

In some cases the situation differs by type of vessel. AHTS, PSV’s and tugs can be included in the system in Denmark, whilst other vessels such as drill ships, seismic vessels, and wind farm installation vessels are specifically excluded. That may change, though. The Danish Ministry of Taxation recently announced that it intends to broaden the scope of the Danish tonnage tax scheme so that e.g. wind farm construction vessels, support and construction vessels, ice breaking vessels etc. will be covered as well. No schedule for changes has been announced yet, so this plan is still in the proposal stage.

Corporate taxation in the global offshore shipping industry 7

More detailed information on tax and other incentives offered by these countries to shipping companies can be found in our longer analysis, Choosing your course - Corporate taxation of the shipping industry around the globe.

The countries covered in this report fall under three categories of shipping tax regimes:

1) Tonnage tax regimes - Tax regimes under which the tax payable is based on the tonnage of the vessels.

2) Shipping incentives tax regimes - Tax regimes with beneficial tax provisions specifically aimed at the shipping industry.

3) Tax efficient regimes - Tax regimes characterised by low effective tax rate (no specific shipping incentives).

In countries that use tonnage tax regimes or shipping incentives tax regimes, these don’t necessarily apply to every type of vessel. Our analysis suggests that various countries’ approaches can have a significant impact on both individual businesses and the countries’ competitive position. We take a separate look at vessels and activities in the following areas: oil & gas offshore industry, offshore wind farm and offshore construction industry, and activities related to other services provided offshore.

Key shipping countries’ approach to allowing offshore vessels/services to be covered by their shipping tax incentives.

Very liberal approach Fairly liberal approach Fairly restrictive approach Very restrictive approach

Singapore Germany Denmark1 Finland

Hong Kong UK France USA

Cyprus Greece India

UAE Norway Italy

Netherlands Ireland

1) Please note that the Danish Government has announced to widen the scope of tonnage tax to a number of offshore vessels/activities, thus wind farm installation vessels, accomodation vessels, security and patrol vessels, Icebreaking and other offshore vessels might be included during 2015 or late 2014. This could potentially move Denmark from a fairly restrictive to a fairly liberal approach depending on how the changes will be implemented and whether or not the changes will also cover seafarer incentives.

8 Corporate taxation in the global offshore shipping industry

Vessel types related to the oil & gas offshore industryMany countries exclude vessels related to the oil & gas industry from their shipping taxation regime. The reasons vary, but drill ships/drilling rigs are mainly excluded due to the fact that transportation is not their main activity; in some cases, their design means they cannot transport goods or passengers at all. Still, many vessel types are in a grey area, where it is not clear whether or not they are covered by the shipping tax regime of the countries in question.

Most attractive: Hong Kong, Singapore and the UAE.

Next up: Cyprus, Germany, Greece, India, Malta, Netherlands, Norway and UK.These countries also have a fairly liberal approach. A number of activities can still be eligible for their systems, as long as specific requirements are met. These countries might still be attractive alternatives to the very liberal jurisdictions.

Less attractive: Denmark, Finland, France, Ireland, Italy and USA.These countries all operate with a more restrictive approach regarding the eligibility of these types of vessels for their shipping tax regimes either specifically by law or by the administrative practice carried out by the local tax authorities. Only very few vessel or activity types can be covered. In our view, companies in these countries run a real risk of losing business to competitors located in more liberal jurisdictions. Eventually that could have significant consequences for the local shipping industries.

Corporate taxation in the global offshore shipping industry 9

Vessel / Activity Type

Cyprus Denmark1 Finland France Germany Greece Hong Kong India Ireland

Drill ships and/or drilling rigs

X XX XX X √ √√ √ √ X

Anchor handling tug vessels and platform

supply vessels√√ √√ √ √ √ √ √ ? √

Seismic vessels √√ XX XX X √ ? √ ? √

Floating production storage and

offloading vessels (FPSO’s)

√ XX XX X X ? √ ? X

Vessel / Activity Type

Italy Malta Netherlands Norway Singapore UAE UK USA

Drill ships and/or drilling rigs

X X X XX √√2 ◊ XX XX

Anchor handling tug vessels and platform

supply vessels√ √ √ √√ √√2 ◊ √√ XX

Seismic vessels X √ √ √√ √√2 ◊ √ XX

Floating production storage and

offloading vessels (FPSO’s)

X ? ? XX √√2 ◊ XX XX

1 The Danish Government has announced to widen the scope of tonnage tax to a number of offshore vessels/activities, thus wind farm installation vessels, accommodation vessels, security and patrol vessels, icebreaking and other offshore vessels might be included during 2015 or late 2014. However, at the time of writing these proposals did not include any of the oil industry vessels listed above. 2 if operations are carried out outside the limits of the port of Singapore.

√√: definitely qualifies √: likely to qualify ◊: not subject to taxation

?: might qualify X: likely not to qualify XX: does not qualify

■ Very liberal regime ■ Fairly liberal regime ■ Fairly restrictive regime ■ Very restrictive regime

10 Corporate taxation in the global offshore shipping industry

Vessel types related to the offshore wind farm and offshore construction industryThe offshore wind farm and construction industry is booming and double-digit growth rates are expected to continue over the next 5-10 years. This has led to the formation of highly specialised niche shipping companies fighting a fierce battle in the market place to win lucrative projects building wind farms and other offshore installations around the globe. How selected countries treat the operation of such vessels for tax purposes can have a profound impact on these companies’ competitiveness.

Most attractive: Cyprus, Netherlands, Singapore and UAE.Most vessels/activities are included in their shipping tax schemes.

Next up: Cyprus, Germany, Greece, India, Hong Kong and Norway.These countries have fairly liberal policies, where a number of the vessel types might qualify, if certain specific criteria are met.

Borderline: Denmark, France, Germany, Ireland, Italy, Malta and UK.These countries specifically exclude a number of these vessel types/activities. In the case of Denmark, the UK and Germany, authorities take a more case by case approach on deciding whether the actual activities performed by a specific offshore vessels makes them eligible. That makes it difficult to place vessels in such locations as there is uncertainty to how the vessel will be taxed.

In these jurisdictions, the transportation element of the service provided by the vessels is crucial for the eligibility of tonnage tax. In some cases, it can lead to part of the activity being subject to normal taxation and part being subject to tonnage tax, which brings uncertainty and increased administrative burdens and costs. Wind farm construction vessels, for instance, might be covered to the extent there is a transportation element included in the service. Purely construction-related activities might be taxed normally, while deliveries are eligible for tax incentives. To comply with these tax codes, companies need to manage contracts and costs closely, which make it more burdensome for enterprises located in these territories compared to their competitors in the very liberal or fairly liberal jurisdictions.

Less attractive: Finland and USA.These countries offer no incentives.

Corporate taxation in the global offshore shipping industry 11

Vessel Type Cyprus Denmark1 Finland France Germany Greece Hong Kong India Ireland

Wind farm construction vessels

√ X XX X ? ? √ ? X

Accommodation and support vessels (e.g. flotels and crew

transfer vessels)

Crew trans-fer vessels:

√

Flotels and accom-

modation vessels: ?

Crew trans-fer vessels:

√

Flotels and accom-

modation vessels: XX

XXCrew trans-fer vessels:

?? ? ?

Crew trans-fer vessels:

?

Flotels and accom-

modation vessels: X

Crew trans-fer vessels:

?

Flotels and accom-

modation vessels: X

Support and construction vessels (floating cranes, dive vessels, construction jack-up rigs, dredging

etc.)

√ X XX X ? ? X

Dredgers: ?

Other types of vessels: X

X

Offshore installation vessels of other kind

(e.g. MCV’s)√ ? XX ? ? ? √ ? X

Vessel Type Italy Malta Netherlands Norway Singapore UAE UK USA

Wind farm construction vessels

? √ √ √ √√2 ◊ ? XX

Accommodation and support vessels (e.g. flotels and crew

transfer vessels)

Crew trans-fer vessels:?

Other types of vessels: X

Flotels:. XX

Other ves-sels ?

Accom-modation vessels: ?

Crew trans-fer vessels:

√

Support vessels √

? √√2 ◊

Crew trans-fer vessels:

√

Flotels and accom-

modation vessels: XX

XX

Support and construction vessels (floating cranes, dive vessels, construction jack-up rigs, dredging

etc.)

X X √

Yes, √√:

if support and con-struction vessels

within oil & gas sector.

√√:

Other types might qualify

√√2 ◊ ? XX

Offshore installation vessels of other kind

(e.g. MCV’s)? ? √

Likely to qualify if

within the oil & gas sector

?

√√2 ◊ XX XX

1 The Danish Government has announced to widen the scope of tonnage tax to a number of offshore vessels/activities, thus wind farm installation vessels, accomodation vessels, security and patrol vessels, icebreaking and other offshore vessels might be included during 2015 or late 2014. 2 if operations are carried out outside the limits of the port of Singapore.

√√: definitely qualifies √: likely to qualify ◊: not subject to taxation

?: might qualify X: likely not to qualify XX: definitely does not qualify

■ Very liberal regime ■ Fairly liberal regime ■ Fairly restrictive regime ■ Very restrictive regime

12 Corporate taxation in the global offshore shipping industry

Vessel types related to other services provided offshoreThe remaining vessels do not share any defining characteristics. These are vessels used in specific niche segments, providing very specific and specialised shipping services.

Most attractive: Cyprus, Hong Kong, Ireland, Norway, Singapore, UK and UAE.These countries operate with a more liberal approach to these vessels, and will be able to attract more investments in these areas.

Next up: Germany, Greece, Italy, India and Malta.In these countries, a majority of these services are eligible for tax benefits, if certain requirements are met. Often the eligibility of vessels such as standby vessels and offshore patrol vessels depends on a very case by case assessment, including whether or not there is a transportation element in the services provided.

Less attractive: Denmark, Finland and USA.These countries are generally very reluctant to grant these types of vessels/activities access to the benefits of their shipping tax regimes.

Corporate taxation in the global offshore shipping industry 13

Vessel Type Cyprus Denmark1 Finland France Germany Greece Hong Kong India Ireland

Lightering/ship-to-ship transfers (e.g.

tanker vessels used for transfers at sea

and subsequent transportation of oil

products to and from harbor

√√ ?3 √ √ √ ? √ ? ?

Ice breaking / ice management vessels

√ XX XX X XX ? ? ? √

Standby vessels √ X XX ? ? ? ? ? √

Offshore patrol vessels (OPV’s)

√ X XX X ? ? √ ? √

Vessel Type Italy Malta Netherlands Norway Singapore UAE UK USA

Lightering/ship-to-ship transfers (e.g.

tanker vessels used for transfers at sea

and subsequent transportation of oil

products to and from harbor

? √ √ √ √√2 ◊ √ XX

Ice breaking / ice management vessels

? ? X ? √√2 ◊ √√ XX

Standby vessels ? √ X √√ √√2 ◊ √√ XX

Offshore patrol vessels (OPV’s)

? ? X ? √√2 ◊ ? XX

1 The Danish Government has announced to widen the scope of tonnage tax to a number of offshore vessels/activities, thus wind farm installation vessels, accomodation vessels, security and patrol vessels, icebreaking and other offshore vessels might be included during 2015 or late 2014. 2 If and not if operations are carried out outside the limits of the port of Singapore.3 There is a pending tax case in Denmark on the use of tonnage tax on vessels operated in STS and lightering services, based on the wording of the Danish tonnage tax law it should be covered but it is currently subject to a tax case before the national tax court.

√√: definitely qualifies √: likely to qualify ◊: not subject to taxation

?: might qualify X: likely not to qualify XX: definitely does not qualify

■ Very liberal regime ■ Fairly liberal regime ■ Fairly restrictive regime ■ Very restrictive regime

14 Corporate taxation in the global offshore shipping industry

Other tax incentives for shipping entitiesBelow we provide a brief overview on whether or not the selected countries offer other tax incentives, e.g. net salary schemes for the seafarers performing work on the vessels in question.

Does the country have other beneficial tax incentives for shipping entities?

Cyprus • No tax on salaries and benefits of crew on board of Cypriot flagged vessel

Denmark • Net salary scheme for seafarers working on vessels that qualify for tonnage tax

Finland • Net salary scheme for seafarers primarily in international traffic

France• Employer contributions and employee dues from seamen are based on the flat-rate

salaries

Germany • Wage tax subsidy system for seafarers working on a German flagged vessels

Greece• Reduced income tax rates for seafarers of the commercial marine

• Various tax exemption and benefits apply for ship-owning companies, ship-owners and shareholders in shipping companies

Hong Kong• Seafarers salaries are exempt from tax if absent from Hong Kong for a substantial por-

tion of the year

India• In certain circumstances salary paid to a non-resident seafarer as remuneration for ser-

vice rendered on a foreign ship will be exempt from taxation in India.

Ireland

• Seafarers allowance available to Irish resident individuals who spend at least 161 days on voyages that either begin or end in a foreign port. Allowance is EUR 6,350 at the marginal rate of tax and a number of conditions need to be satisfied. It also applies to seafarers on vessels which service drilling rigs.

Italy• Tax credit equal to individual income tax due to employment income paid by company to

the crew on the vessel. Must be deducted from the payment of WHT on such income

Malta

• Nothing specific within shipping.

• In certain circumstances, the salary received by non-Maltese resident seafarers is likely to be not chargeable to income tax in Malta, where the employment activities are carried on outside of Malta.

• Zero VAT-rate for delivery and provisioning of seagoing vessels

Netherlands

• Wage cost deduction for seafarers

• Accelerated depreciation of seagoing vessels

• Zero VAT-rate for delivery and provisioning of seagoing vessels

Norway • Net salary scheme for seafarers

Singapore

• Tax exemption on qualifying leasing income and concessionary tax rate on qualifying management income or income from provision of qualifying approved shipping related support services

• Tax exemption of income derived from employment exercised on board a Singapore flagged ship if employment exercised substantially outside Singapore.

UAE• No specific benefits.

• Currently there is no individual income tax.

UK • “Seafarers Earning deduction”

USA • No

Corporate taxation in the global offshore shipping industry 15

Final remark

Your decision on which tax regime is most suitable for your company, how to structure your business and where to locate your offshore shipping activities will depend on the circumstances and your activities. You’ll need to take into account a broad range of factors. How well you can manage and control your business is critical. But other factors including the effectiveness of the tax system for the specific offshore shipping activities your enterprise is engaged in, ship financing, freight taxes, wage cost deduction for seafarers, and taxes at source can also make a big difference to your business.

Our PwC network of highly experienced and dedicated offshore shipping experts can assist you in deciding how to structure your offshore shipping business. Contact us for an informal discussion about your individual situation and considerations. You can find the contact details of our global offshore shipping experts and our global Transportation & Logistics network below.

16 Corporate taxation in the global offshore shipping industry

Territory contacts

PwC has established a Global Offshore and Shipping Network of industry specialists. Within this network, a dedicated team of assurance, tax and advisory professionals provide advice and support to businesses like yours. Through our network of local specialists PwC can offer the solutions needed to manage your business on a local and global basis. The Offshore and Shipping Network has strengthened its commitment to exchange experience through our global databases and regular meetings, allowing all members to share knowledge and find solutions that fit your needs. No matter where you are navigating, PwC has a Offshore and Shipping Team ready.

Key contacts

Socrates Leptos-BourgiPartner - Global Shipping & Ports coordinator and T&L Leader Greece+30 210 428 4000socrates.leptos-bourgi@gr.pwc.com

Bo Schou-JacobsenPartner - T&L Leader Denmark+45 39 45 36 39bsj@pwc.dk

Lars Koch VintherPartner – Tax Leader Shipping Denmark+45 39 45 94 57lkc@pwc.dk

Global T&L Central Team

Global Transportation & Logistics LeaderJulian Smith+62 21 52890966smith.julian@id.pwc.com

Global Transportation & Logistics Business DevelopmentPeter Kauschke+49 211 981 2167peter.kauschke@de.pwc.com

Global Transportation & Logistics Knowledge ManagementUsha Bahl-Schneider+27 11 797 4787usha.x.bahl-schneider@za.pwc.com

Corporate taxation in the global offshore shipping industry 17

Country Shipping offshore expert Transportation & Logistics leader

Cyprus Cleo Papadopoulou +357 25 555 200cleo.papadopoulou@cy.pwc.com

Yiangos Kaponides+357 25 555 230yiangos.kaponides@cy.pwc.com

Denmark Lars Koch Vinther+45 39 4594 57lkc@pwc.dk

Bo Schou-Jacobsen +45 39 45 36 39bsj@pwc.dk

Bo Schou-Jacobsen +45 39 45 36 39bsj@pwc.dk

Finland Camilla Valtti+358 20 787 7455 camilla.valtti@fi.pwc.com

Mikko Nieminen+358 (0) 9 2280 1257 mikko.nieminen@fi.pwc.com

France Anne-Laure Bertho+33 (0) 4 91 99 29 85anne-laure.bertho@fr.landwellglobal.com

Vincent Gaide+33 1 56 57 8391vincent.gaide@fr.pwc.com

Germany Marcus Blömer+ 49 40 63 78 8435marcus.bloemer@de.pwc.com

Dietmar Prümm+49 211 981 2902dietmar.prümm@de.pwc.com

Greece Vassilios Vizas+30 210 687 4019vassilios.vizas@gr.pwc.com

Socrates Leptos-Bourgi+30 210 4284000socrates.leptos-bourgi@gr.pwc.com

Hong Kong Reynold Hung+852 2289 3604reynold.hung@hk.pwc.com

Alan Ng+852 2289 2828alan.ng.@hk.pwc.com

India Taral R Shah+91 (0) 22 6689 1498 taral.shah@in.pwc.com

Manish Sharma+91 124 330 6007manish.sharma@in.pwc.com

Italy Egidio Filetto+39 081 7161411egidio.filetto@it.pwc.com

Guido Sirolli+39 657 083 2125guido.sirolli@it.pwc.com

18 Corporate taxation in the global offshore shipping industry

Country Shipping offshore expert Transportation & Logistics leader

Malta Neville Gatt+356 25 64 67 11neville.gatt@mt.pwc.com

Neville Gatt+356 25 64 67 11neville.gatt@mt.pwc.com

Netherlands Jeroen Boonacker+31 6 51 04 56 53jeroen.boonacker@nl.pwc.com

Erwin van den Bree+31 88 792 3404erwin.van.den.bree@nl.pwc.com

Isis Bindels+31 88 792 3606isis.bindels@nl.pwc.com

Norway Svein T. Sønning +47 95 26 10 71Svein.t.sonning@no.pwc.com

Rita Granlund+47 95 26 02 37 rita.granlund@no.com

Singapore Elaine Ng+65 6236 3627 elaine.ng@sg.pwc.com

Siew Nam Tia +65 6236 3673Siew.nam.tia@sq.pwc.com

Kok Leong Soh+65 6236 3788 kok.leong.soh@sg.pwc.com

United Arab Emirates

Jochem Rossel+971 (0) 4 304 3445jochem.rossel@ae.pwc.com

Anil Khurana+1 (214) 754 5083anil.khurana@ae.pwc.com

United Kingdom

Andrew Norris+44 (0) 207 212 6545 andrew.norris@uk.pwc.com

John Ritchie+44 (0) 1224 25 3220 john.ritchie@uk.pwc.com

Coolin Desai+44 207 212 4113coolin.desai@uk.pwc.com

United States of America

Gary M. Pogharian+1 973 236 5696/+1 201 463 7977gary.m.pogharian@us.pwc.com

Jonathan Kletzel+312 298 6869jonathan.kletzel@us.pwc.com

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