One minute with Ken Almand, head of transfer pricing at RSM UK.
What are you working on at the moment?
It is fair to say that we live in interesting times. Currently, I am helping clients to revisit their tax and transfer pricing strategies. This is against a background of well signposted tax regulatory developments, such as BEPS and EU anti-avoidance proposals; and less predictable political and economic changes, including Brexit, a Trump victory and state aid rulings. There has been a growing recognition in the market that compliance will be a priority in coming years and that the events of the last few months on both sides of the Atlantic potentially offer up risks and opportunities for business. Transfer pricing strategies need to reflect this evolving environment. Reputational risk is a key issue in some sectors and the proposals to require the publication of financial and tax data have caused alarm at board level, although the concern is typically around commercial sensitivities rather than tax issues.
Comment on a forthcoming change in tax.
The confirmed introduction of corporate interest and loss restriction rules plus the impending hybrids legislation may have a significant impact on corporate investment and structures and requires review by those affected. Let us hope that these measures do not have a disproportionately negative impact on the attractiveness of the UK.
Also the recent conclusion of negotiations to adopt a multilateral convention is a fundamental part of the BEPS project. The fact that over 100 countries have reached agreement on an instrument that will impact more than 2000 tax treaties is notable in itself. How it is implemented in practice will be the key issue for business.
Do you expect to see an increase or decrease in transfer pricing disputes in the coming years?
Given the increase in information available to tax administrations via country by country reports, masterfiles and information exchanges, I would expect to see a rise in the number of transfer pricing disputes. I would also expect businesses to attempt to reduce the risks associated with disputes by seeking advanced agreements with tax administrations. It is to be hoped that tax administrations apply the BEPS recommendations in a consistent and proportionate manner and that appropriate training is provided to staff administering transfer pricing disputes.
Aside from your immediate colleagues, who in tax do you most admire?
When I first started in international tax at what was then the International Division of the Inland Revenue, I learned a great deal from Tony Attwood. He made the complex seem simple, an ability that I respect and seek to emulate.
What is the most challenging tax problem you have faced recently?
Helping businesses with transfer pricing audits in certain countries can be challenging. Despite some often publicised shortcomings, it helps us to appreciate that we are fortunate to have HMRC as our tax administration.
What are the immediate tax concerns post Brexit?
Business craves certainty and so a delay or failure by the government to provide a clear direction on post Brexit tax strategy would be a concern. Also, failure to recognise that leaving the EU may provide the UK with tax policy advantages that could significantly benefit the economy would also be a disappointment.
Finally, you might not know this about me but…
Some readers may find this strange but I am rather happy sculling up the Thames at 6 a.m. on a winter’s morning with a bunch of fellow masochists.
One minute with Ken Almand, head of transfer pricing at RSM UK.
What are you working on at the moment?
It is fair to say that we live in interesting times. Currently, I am helping clients to revisit their tax and transfer pricing strategies. This is against a background of well signposted tax regulatory developments, such as BEPS and EU anti-avoidance proposals; and less predictable political and economic changes, including Brexit, a Trump victory and state aid rulings. There has been a growing recognition in the market that compliance will be a priority in coming years and that the events of the last few months on both sides of the Atlantic potentially offer up risks and opportunities for business. Transfer pricing strategies need to reflect this evolving environment. Reputational risk is a key issue in some sectors and the proposals to require the publication of financial and tax data have caused alarm at board level, although the concern is typically around commercial sensitivities rather than tax issues.
Comment on a forthcoming change in tax.
The confirmed introduction of corporate interest and loss restriction rules plus the impending hybrids legislation may have a significant impact on corporate investment and structures and requires review by those affected. Let us hope that these measures do not have a disproportionately negative impact on the attractiveness of the UK.
Also the recent conclusion of negotiations to adopt a multilateral convention is a fundamental part of the BEPS project. The fact that over 100 countries have reached agreement on an instrument that will impact more than 2000 tax treaties is notable in itself. How it is implemented in practice will be the key issue for business.
Do you expect to see an increase or decrease in transfer pricing disputes in the coming years?
Given the increase in information available to tax administrations via country by country reports, masterfiles and information exchanges, I would expect to see a rise in the number of transfer pricing disputes. I would also expect businesses to attempt to reduce the risks associated with disputes by seeking advanced agreements with tax administrations. It is to be hoped that tax administrations apply the BEPS recommendations in a consistent and proportionate manner and that appropriate training is provided to staff administering transfer pricing disputes.
Aside from your immediate colleagues, who in tax do you most admire?
When I first started in international tax at what was then the International Division of the Inland Revenue, I learned a great deal from Tony Attwood. He made the complex seem simple, an ability that I respect and seek to emulate.
What is the most challenging tax problem you have faced recently?
Helping businesses with transfer pricing audits in certain countries can be challenging. Despite some often publicised shortcomings, it helps us to appreciate that we are fortunate to have HMRC as our tax administration.
What are the immediate tax concerns post Brexit?
Business craves certainty and so a delay or failure by the government to provide a clear direction on post Brexit tax strategy would be a concern. Also, failure to recognise that leaving the EU may provide the UK with tax policy advantages that could significantly benefit the economy would also be a disappointment.
Finally, you might not know this about me but…
Some readers may find this strange but I am rather happy sculling up the Thames at 6 a.m. on a winter’s morning with a bunch of fellow masochists.
