If you are interested in this candidate, please contact Andrew Wilson via email awilson@cerfinancial.co.uk or call on 0207 626 6065.

Overview:

• 20+ years of transfer pricing experience across Big 4, in-house global leadership and senior interim roles, with deep expertise spanning financial services, private equity, banking and multinational corporate structures.
• Highly technical transfer pricing specialist with extensive experience leading complex TP audits, APAs, MAPs and ATCAs globally.
• Strong commercial and stakeholder management background advising CFOs, Heads of Tax and senior leadership team.

00317523

EDUCATION:

University

Postgraduate diploma in Finance

• BSc, upper second honours, Russell Group university

QUALIFICATIONS:

• Chartered Tax Advisor (CTA, Corporate specialist route)
• Financial Risk Manager (FRM)
• Chartered Accountant (ICAEW / ACA) – first time pass

TECHNICAL:

• SAP, Oracle Financials, Cognos and PeopleSoft user. Exceptional Excel and financial modelling skills, to VBA macro standard Bloomberg product certification, level 3

CAREER HISTORY:

2024 – Present

Hospitality

Head of Transfer Pricing (contract)

• The group has no formal transfer pricing policy in place. My brief was to review recommendations from TP advisors and develop an implementation plan to put in place transfer pricing policies for business services, support services and other issues.
• I revised the group’s transfer pricing policy on membership income, such that the UK subgroup’s profitability is ringfenced to minimise UK audit risk, but aggregate losses at overseas operating companies halved, leading to ETR efficiencies. I led this project from gaining internal business support to engaging a big4 firm with functional interviews and policy design, financial modelling, documentation, intercompany agreements transfer pricing operating manual to document the operational steps.
• I also drafted legal agreements for the Legal team’s review and developed an internal banking model to give the centre more oversight over transactions between Houses and that intercompany balances are settled on broadly commercial terms, as well as each House have a defined borrowing capacity and revolving credit agreement with the centre.

2023 - 2024

Retail

Head of Transfer Pricing (contract)

• I spent most of the time based in Hong Kong, dealing with a tax audit in Vietnam, and preparing for tax audits in Japan and Hong Kong. I documented the high level of economic substance and local decision-making and therefore, the local companies bear the entrepreneurial risk and reward, rather than earning a fixed rate of return on routine functions.
• I also developed a profit split model to reward key members of the group’s private label business, by identifying the key value-drivers and which legal entities are responsible for these key value-drivers.

2022 - 2023

Sabbatical / family bereavement leave

2021 - 2022

Industrial Technology and Engineering

Transfer Pricing senior manager (contract)

• I was recruited to take some of the workload off the incumbent Head of Transfer Pricing. In particular, I managed a major transfer pricing audit in Germany involving the Group’s regional, research and development and financing activities. This involved liaison with the German tax advisors, local teams and the central teams to provide information and explanations to the German tax auditors.
• I was also involved with updating the transfer pricing framework of the Group’s Detection and Interconnect Divisions, defending the Divisions’ product sales transfer pricing policy and strategic management fees, as well as working with the group’s Treasury team to ensure intercompany loan pricing was arm’s length.

2020 - 2021

Sabbatical / family bereavement leave

2019 - 2020

Banking

Vice President Transfer Pricing (maternity cover)

• My main responsibilities were to update the group’s transfer pricing policy to take into account of the new European banking company set up to manage the Group’s Brexit compliance issues. This involved updating the group’s management services and capital recharge models to reflect the regulatory changes and ensuring the transfer pricing documentation were consistent with regulatory filings and reflect the Group’s latest operational model.
• I was also involved in the UK/Japan MAP and bilateral APA negotiations, the UK/India bilateral APA and Ireland MAP claim in relation to Barclay’s group’s historic captive insurance business.

2015 - 2019

Professional Services

Global Head of Transfer Pricing

I was the senior transfer pricing specialist for a FTSE-100 listed group with 40,000 employees and operations in 100 countries, including China, India, Australia and Hong Kong. I was responsible for all aspects of transfer pricing, including the group’s transfer pricing design and implementation. My overall objective was to refresh the group’s disparate transfer pricing reports, bring these up to BEPS standard, assist with tax optimisation and provide transfer pricing advice across the group.

My responsibilities and achievements include:

• Prepared the group transfer pricing master file and local files for 60 countries
• Standardised the group’s transfer pricing policy, eliminating inconsistencies and conflicts and establish clear boundaries between various cost pools
• Amended the transfer pricing calculation framework simplifying calculations, fixed spreadsheet errors and removed certain inconsistencies
• Advise the Head of Tax and CFO of TP risks and opportunities around the group via monthly (with Head of Tax) and Quarterly (with CFO) meetings
• Simplified the group’s transfer pricing policy and began utilising UK’s brought forward tax losses
• Redrafted intercompany legal agreements to support transfer pricing framework
• Dealt with transfer pricing inquiries in Germany, Italy, and India.

2014 - 2015

Professional Services

Transfer Pricing Senior Manager

Headhunted by the financial services transfer pricing partner to act as her number 2 person in the Financial Services transfer pricing group, with responsibilities for the technical content of all projects and to coach junior staff. Rated as a Grade 1 performer (highest grade)

My projects include:

• Put in place a transfer pricing policy for a private banking group, with arm’s length fee reward for its marketing, administration, asset management and fund selection functions.
• Advised a multinational group on pricing its cash pool deposits and borrowing transactions, reflecting the recent Danish Bombardier transfer pricing case
• Defending a Swiss tax inquiry into a private bank with a large and very profitable fund management business operating out of Luxembourg. Devised a novel benchmarking framework to show that the Luxembourg company is receiving an arm’s length reward for the risks assumed.

2005 – 2014

Big 4

Transfer Pricing Senior Manager

Recognised within the transfer pricing group as best technical senior manager and the best problem solver, the go-to person for innovative and workable answers to complex transfer pricing problems. Rated as an “Exceptional Performer” or the top 20% of the population, for seven years.

Led complex transfer pricing advisory work relating to financial transactions and treasury structures and developed the “subordination economic adjustment” method to price shareholder debt relative to a company’s senior bank debt – this method was named by the Head of Department as the unique capability that differentiates KPMG from other big4 firms.

My transfer pricing experience:

Banking and Asset Management

• Assisted a major investment bank to allocate profits earned on its interest rate derivatives trading book managed on a global basis across its European, Asian and North American teams, and obtained HMRC’s agreement to the transfer pricing methodology, allocation keys and UK trading income
• Advised a major banking group on an appropriate fee for use of its capital by oversea branches used to support local derivatives trading positions
• Defended a German tax audit relating to the internal fee structure between the German parent and its London branch for the latter’s Medium Term Note (MTN) issuance activities
• Developed a tracker fund model and Bloomberg Fund Search (FSRC function) to support the fund management fee allocated to the overseas fund managers

Financial transactions

• Advised several infrastructure and property funds on the appropriate amount of subordinated debt capital that can be supported by the business, and negotiated Advance Thin Capitalisation Agreements with HMRC
• Priced a cross-guarantee for a European property fund, to neutralise the effects of a guarantee fee imposed by a European tax authority. The pricing methodology was based on an innovative portfolio analysis and a Monto Carlo simulation model
• Advised and defended a multinational group with major business interest in the USA that it does not have to charge a guarantee to its US subsidiary, based on an ambiguity in the OECD Guidelines.

Other projects

• Negotiated three APAs, a bilateral APA between South Korea and UK for a high-end fashion retailer, a unilateral APA for a European car manufacturer and US/UK bilateral APA for a UK pharmaceutical group
• Negotiated over 10 ATCAs with HMRC, covering infrastructure groups, property groups and private equity-backed businesses
• Assisted an Ireland headquartered group to implement a management services transfer pricing policy enabling the highly value-adding management function to capture a larger share of operating companies’ profits, using an innovative “fund management” model
• Performed a permanent establishment review for a large multinational group where several senior executives spend the majority of their time working in the UK

2003 – 2005

Government Office

Business Analyst

• Point of contact between the large business tax teams and HMRC’s research department, and provided analytical and economic research to assist with tax investigations
• Supported large business case teams with economic and financial analyses, in particular, on transfer pricing issues

Major projects

• Countered a retailer’s claim for logistics royalties deduction by modelling the benefits of logistics from published accounts to prove that royalty deduction claimed was well in excess of observed benefits
• Analysed a reinsurance transfer pricing report, based on a DCF model of revenue, underwriting losses, administration expenses and capital tied up in the business over 20 years and found that the model was not self-consistent and cannot be used to support the report’s conclusions

References Available Upon Request

If you are interested in this candidate, please contact Andrew Wilson via email awilson@cerfinancial.co.uk or call on 0207 626 6065.

To view other CV's please click here.