One minute with Ian Brimicombe, head of group tax and treasury, AstraZeneca
How did you end up in tax?
I trained in audit and then transferred to corporate tax for a more value adding experience.
Who in tax do you most admire?
I have been very fortunate to work with some exceptional people in tax over the years. I have always admired Graham Aaronson for sheer technical ability and his articulation of complex matters in simple terms.
Is there a common problem you come across time and again in tax?
Our key concern is resolving transfer pricing matters usually bilaterally and with relevant governments. It’s a constant challenge to reconcile a global operating model of a highly integrated multinational company like AstraZeneca to local tax bases. The process requires deep functional understanding and clear communication.
What advice would give to someone entering the profession?
Go for it! You will not lack for intellectual challenge that test all aspects of your professional training and the reward that comes from solving business issues that add significant value to any company’s bottom line.
Is there a recent development in tax that concerns you?
I am slightly concerned about the potential for divergence between the OECD and UN in terms of the identification, ownership and valuation of intangibles. Absence of agreement will lead to disputes and double taxation and it is incumbent on all stakeholders to reconcile any differences for a common understanding to prevail.
Name a memorable moment in your career
There have been so many in AstraZeneca including deals done, settlements achieved, APA’s etc but if I had to pick one if was the opening of the Oxford Centre for Business Taxation led by Mike Devereux. There was a lot or preparation work by a small group of us and it was great to witness the opening and continuing success of the Centre in making a significant contribution to the development of UK tax policy.
What has HMRC got right? What has it got wrong?
HMRC is a key asset in the overall competitiveness of the UK economy. Getting the right tax regime is one thing, administering it effectively and fairly is equally important. It’s right that the Chancellor has spared HMRC from further cuts as their role to collect, monitor and enforce is ever increasing not only in the UK but in dealing with overseas taxpayers and governments to ensure effective administration of cross border trade. HMRC represents the UK around the world in setting high standards for tax administration and it should continue to invest in this activity to enhance prospects for British business.
HMRC needs to address its approach to medium-sized and smaller business to ensure the service is accessible, consistent and efficient. I understand HMRC are focused on this aspect.
If you could make one change to UK tax law, what would it be?
It’s clear to all that this government has driven a very pro-business agenda and made significant improvements to the UK tax regime to assist economic recovery. Recent incentives for investment are also welcome and I would add specific support for the UK’s biotechnology business sector, which has all but disappeared in recent years.
What did you think of the Autumn Statement?
It was disappointing to hear that progress is slow in managing the deficit but it’s clear if you go to Europe and the US and even in some emerging markets that no one is having an easy time. In a globalised economy the UK cannot be expected to recover in isolation. That said the Chancellor used all the room he had to stimulate growth without sacrificing the longer term goal of deficit reduction and increasing interest costs. Business in turn must keep looking for opportunities and remain positive in order to succeed.
Where do you stand on the GAAR?
I am in favour. It was clear to business that the nature of some planning particularly in the HNWI sector was well beyond the intention of the law and could not necessarily be countered by small step changes to the law. DOTAS does not seem to have prevented the proliferation of schemes and a GAAR is a natural step to take to deal with the gap at the extreme end of abusive planning. We will of course have to see how the panel operates the new measure.
How do you see the rules on corporate taxes evolving over the next ten years?
I see less emphasis on corporate tax in the future and more on indirect taxes as governments aim to improve efficiency and predictability of tax collection. This will require a mindset shift in the electorate but the fact is that global companies do have choices for location of investment in funding and substance. In the meantime corporate tax remains an important source of funds and the battleground is set for an alternative tax base for corporates – away from profits and toward sales and substance. Governments should be very wary of allowing this choice to be promoted without serious debate and business must play its part in explaining the basis of its contribution.
What skills do you need to be a good Tax Director?
It’s an ever broadening set of skills required these days – not only technical but to communicate and influence are equally important capabilities to ensure tax risks can be identified and managed.
What, if anything, can the UK tax authority learn from its overseas counterparts?
As noted above HMRC really does set the standard for tax administration around the world but the IRS also has its plus points in terms of its central teams who are well coordinated and delivery focused.
You might not know this but …
My outside interests have dwindled with age, greater work responsibility and kids. Of course I operate with total transparency so have no secrets.
One minute with Ian Brimicombe, head of group tax and treasury, AstraZeneca
How did you end up in tax?
I trained in audit and then transferred to corporate tax for a more value adding experience.
Who in tax do you most admire?
I have been very fortunate to work with some exceptional people in tax over the years. I have always admired Graham Aaronson for sheer technical ability and his articulation of complex matters in simple terms.
Is there a common problem you come across time and again in tax?
Our key concern is resolving transfer pricing matters usually bilaterally and with relevant governments. It’s a constant challenge to reconcile a global operating model of a highly integrated multinational company like AstraZeneca to local tax bases. The process requires deep functional understanding and clear communication.
What advice would give to someone entering the profession?
Go for it! You will not lack for intellectual challenge that test all aspects of your professional training and the reward that comes from solving business issues that add significant value to any company’s bottom line.
Is there a recent development in tax that concerns you?
I am slightly concerned about the potential for divergence between the OECD and UN in terms of the identification, ownership and valuation of intangibles. Absence of agreement will lead to disputes and double taxation and it is incumbent on all stakeholders to reconcile any differences for a common understanding to prevail.
Name a memorable moment in your career
There have been so many in AstraZeneca including deals done, settlements achieved, APA’s etc but if I had to pick one if was the opening of the Oxford Centre for Business Taxation led by Mike Devereux. There was a lot or preparation work by a small group of us and it was great to witness the opening and continuing success of the Centre in making a significant contribution to the development of UK tax policy.
What has HMRC got right? What has it got wrong?
HMRC is a key asset in the overall competitiveness of the UK economy. Getting the right tax regime is one thing, administering it effectively and fairly is equally important. It’s right that the Chancellor has spared HMRC from further cuts as their role to collect, monitor and enforce is ever increasing not only in the UK but in dealing with overseas taxpayers and governments to ensure effective administration of cross border trade. HMRC represents the UK around the world in setting high standards for tax administration and it should continue to invest in this activity to enhance prospects for British business.
HMRC needs to address its approach to medium-sized and smaller business to ensure the service is accessible, consistent and efficient. I understand HMRC are focused on this aspect.
If you could make one change to UK tax law, what would it be?
It’s clear to all that this government has driven a very pro-business agenda and made significant improvements to the UK tax regime to assist economic recovery. Recent incentives for investment are also welcome and I would add specific support for the UK’s biotechnology business sector, which has all but disappeared in recent years.
What did you think of the Autumn Statement?
It was disappointing to hear that progress is slow in managing the deficit but it’s clear if you go to Europe and the US and even in some emerging markets that no one is having an easy time. In a globalised economy the UK cannot be expected to recover in isolation. That said the Chancellor used all the room he had to stimulate growth without sacrificing the longer term goal of deficit reduction and increasing interest costs. Business in turn must keep looking for opportunities and remain positive in order to succeed.
Where do you stand on the GAAR?
I am in favour. It was clear to business that the nature of some planning particularly in the HNWI sector was well beyond the intention of the law and could not necessarily be countered by small step changes to the law. DOTAS does not seem to have prevented the proliferation of schemes and a GAAR is a natural step to take to deal with the gap at the extreme end of abusive planning. We will of course have to see how the panel operates the new measure.
How do you see the rules on corporate taxes evolving over the next ten years?
I see less emphasis on corporate tax in the future and more on indirect taxes as governments aim to improve efficiency and predictability of tax collection. This will require a mindset shift in the electorate but the fact is that global companies do have choices for location of investment in funding and substance. In the meantime corporate tax remains an important source of funds and the battleground is set for an alternative tax base for corporates – away from profits and toward sales and substance. Governments should be very wary of allowing this choice to be promoted without serious debate and business must play its part in explaining the basis of its contribution.
What skills do you need to be a good Tax Director?
It’s an ever broadening set of skills required these days – not only technical but to communicate and influence are equally important capabilities to ensure tax risks can be identified and managed.
What, if anything, can the UK tax authority learn from its overseas counterparts?
As noted above HMRC really does set the standard for tax administration around the world but the IRS also has its plus points in terms of its central teams who are well coordinated and delivery focused.
You might not know this but …
My outside interests have dwindled with age, greater work responsibility and kids. Of course I operate with total transparency so have no secrets.
