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Work Background
EYDirector - Transfer Pricing - International Tax and Transaction Services
Mar. 2024Dubai, United Arab Emirates
MiQTransfer Pricing Specialist
Jun. 2022 - Mar. 2024London, England, United KingdomKey projects and achievements: ➢ Developed new transfer pricing model framework and optimised during PE investment process. ➢ Improved processes and quality assurance around end-to-end transfer pricing data collation, calculations and journal posting. Led project to automate TP through new ERP systems.
➢ Project manage full suite of TP documentation (UK, US, CAN, AUS, SIN, IND), refreshing core functional analysis and value chain analysis.
➢ Designed and delivered course of Excel training to central Finance team.
➢ Responsibilities extended to central tax provisioning and withholding tax calculations.
Mid-marketAssociate Director / Senior Manager - Transfer Pricing and International Tax
Jan. 2018 - Dec. 2022Birmingham and LondonKey projects and achievements: ➢ Policy change and transformation projects. Developed simple profit split model into refined hybrid profit split / target margin approach, for fast-growing technology client. Developed new charging map and supported proposed policy with margin modelling.
➢ Managed client response in two HMRC enquiries. Included preparation of explanatory TP policy summary slides, briefing client for HMRC full-day site visit, and written response to detailed HMRC questionnaires.
➢ Brexit planning project combining permanent establishment, corporate residence and transfer pricing management services analysis, for proposed new EU operational company.
➢ Interest deductibility projects combining thin capitalisation, anti-hybrids and corporate interest restriction analysis.
➢ Business restructuring projects analysing corporate tax impact of IP transfers out of UK. Performed ‘DEMPE’ analysis and calculated potential UK tax liability incorporating relieving provisions. ➢ Prepared, scripted and co-delivered transfer pricing webinar for Japanese clients. ➢ Co-delivered national transfer pricing roadshow for corporate tax staff. ➢ Managed creation of full-day training seminar in international tax and co-delivered to tax staff at junior/senior analyst grades.
➢ Coached junior corporate tax staff through first transfer pricing projects in multiple offices (Birmingham, Manchester, Milton Keynes, London). Developed strong relationships with TP colleagues in US, HU, DK.
Big 4Manager - Transfer Pricing
Jan. 2013 - Dec. 2018UK and JapanKey projects and achievements: ➢ Bilateral (Japan-Denmark) APA renewal application for Japanese healthcare distributor and unilateral Japan APA application for consumer electronics business. ➢ Inbound Japan local documentation reviews and documentation preparation across multiple sectors (e.g. chemicals, investment management) – worked on loss justification and brand analysis scenarios. ➢ Interest rate benchmarking for “TMK” real estate transactions in Japan. ➢ Thin capitalisation (debt capacity): primarily UK infrastructure lending. ➢ Line management responsibilities for two junior staff and regularly acted as a first round interviewer.
UK Civil ServiceSenior Scientific Officer - Operational Research
Jan. 2008 - Dec. 2013Birmingham and LondonKey projects and achievements: ➢ At Ministry of Justice, was Deputy Head of Business Intelligence with line management responsibility over a team of two senior analysts and two junior analysts.
➢ Delivered two new streamlined data collections in place of existing prison regime monitoring system, with potential multi-million pound savings to be realised. Produced written briefings to Chief Executive and ministers in relation to these new data collections, and managed a variety of Director-level operational and policy stakeholders.
➢ Project managed delivery of new monthly Management Information report into prison violence, and associated performance metric. Marketed report during auditorium presentation and regional meetings to extremely positive feedback from policy lead.
➢ Project managed forecast updates to UK visa income scenarios and presented options and recommendations to a ‘Resource Management Board’ comprising senior management. Chaired User Group to validate forecasts prior to them being presented to the Board.
DeloitteTransfer Pricing Senior Associate
Jan. 2005 - Dec. 2007Birmingham and London➢ Co-edited transfer pricing newsletter.
➢ Prepared pan-European transfer pricing documentation for major media conglomerate, including participation in functional interviews across Europe.
EYTransfer Pricing Director
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