I work with multinational companies to ensure their intercompany transactions are at arm’s length, and compliant with regulations. This includes designing new transfer pricing policies, reviewing existing policies, drafting documentation, and assisting clients with tax authority enquiries, mutual agreement procedures, and advance pricing agreements. I tie this in with my knowledge and experience of other international tax aspects, including corporate residency, permanent establishments, and treaty analysis, to ensure all bases are covered.

I fell into transfer pricing completely by chance. When working at HMRC, a new tax professional training programme was released, and I was assigned to the competent authority team. I worked on the team whilst doing my qualification and training, and really enjoyed the technical aspects of the work, plus working closely with corporates, their advisors, and competent authorities from other countries.

I enjoy that transfer pricing is subjective, which makes it both interesting and complicated, and the fact I have to work closely with clients really understand their business and the issues they face. The continually changing international landscape and approach to transfer pricing by tax authorities and other bodies, such as the OECD, also keeps it interesting.

As well as the benefit of being compliant, and either avoiding enquiries from tax authorities or making them easier to defend if they do arise, the benefit to clients is ensuring their international operations are as efficient as possible. This ensures compliance with local regulations, and that there is no unnecessary cost or tax leakage. It also ensures that their finance department knows the transfer pricing policies for the Group, and can make the relevant adjustments, helping with end-of-year accounting, returns, and audits.