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Director, NM Corp Tax North 1
KPMG in the UK
John is an experienced transfer pricing professional, with over 7 years’ experience advising clients on their transfer pricing arrangements and documentation requirements.
John provides advice across all aspects of transfer pricing (goods, services, IP and financing), however his specific area of expertise is in the area of assessing and documenting the arm’s length nature of related party financial transactions.
He works with a range of large corporates advising them on the transfer pricing aspects of their group financing policies. He also works closely with UK entities that wish to enter into formal Advance Thin Cap Agreements (‘ATCAs’) with HMRC assisting them with preparing submissions and in their subsequent discussions with HMRC.
Recent projects include:
Leading the design and implementation of a new transfer pricing model for related party financing across a global travel and leisure provider. This included establishing both short term and long term financing policies.
Advising on the financing arrangements for a number of UK infrastructure, energy and renewable assets providing detailed transfer pricing advice at both the transaction and ATCA/documentation stages.
Assisting a large car manufacturer in reaching an agreement with HMRC in relation to the arm’s length nature of its intra-group financing arrangements and the role of its ‘in house bank’ entity.
Preparing transfer pricing documentation (Masterfile and Local files covering all transactions for a MNE electronic component distribution business located across numerous locations; and
Managing detailed transfer pricing enquiries from HMRC in relation to both financial, services and IP licensing arrangements.
John has also led KPMG’s response to the UK HMT’s Action 4 consultation, liaising directly with HMT and HMRC to provide input on the development of the new UK rules. He has also authored articles for Tax Journal and presented at external events in relation to the proposed changes.