With a global business like ours, transfer pricing is always high on the agenda. We want to be sure our intercompany transactions are conducted on an arm’s length basis, our documentation is current and keeps pace with legislative requirements and business change, and we want to be prepared to defend our positions if challenged. We’re seeing more tax authorities looking at the end to end value chain in the business and wanting to understand the business in their territory within that broader context.
The current proposals on the taxation of the digital economy are very much front of mind, and we are monitoring developments here closely, whether they be at OECD, the EU or local territory level. The suggestion that the market territory is creating value that should be rewarded independently of functions, assets and risks in that territory is a fundamental shift in the arm’s length standard, and it is going to be very interesting to see how that develops.
In general, the pace of change in the global tax arena is the most rapid it has been in my entire career. Keeping up with the new regimes and navigating our business through the complexities will continue to be a challenge in coming years.
What do you know now that you wish you’d known at the start of your career?
It is important to let people know that you are keen to develop and expand your role and not assume that interesting projects will come to you. Demonstrate an interest in the business, and in what is going on within your team that is not necessarily within your direct responsibility. Leaders want people who can think strategically and make a broader contribution to the team.
Alongside this, I think building relationships and effective networking is really important – both with business colleagues (to get better understanding of commercial imperatives and opportunities, so that you can put your advice in context and add real value to the commercial decision making), and within the tax community (so you stay connected to new developments and ways of working).
If you could make one change to tax, what would it be?
Streamline legislation. In the desire to ‘abuse-proof’ rules, governments enact legislation that is extremely complicated – to the point where it is difficult for both taxpayers and tax authorities to manage. Also, adopt more common rules globally to ensure that disputes between jurisdictions can be minimised and double tax can be avoided.
How do you seen the tax landscape evolving over the next five to ten years?
I think whilst there is high level agreement on some of the issues that need to be tackled, there is little consensus on how those issues should be addressed. Organisations such as the OECD and EU are trying to reach compromise amongst a membership which holds widely divergent views. However hard this compromise is to find, it has to be done to avoid fragmentation and widely varying approaches being adopted, which can only lead to more controversy and a greater risk of double taxation.
And finally, you might not know this about me but…
You can’t work for a Japanese company without getting roped in to karaoke. My signature tune is ‘Twist and Shout’ by The Beatles, but I also do a mean Dolly Parton.
With a global business like ours, transfer pricing is always high on the agenda. We want to be sure our intercompany transactions are conducted on an arm’s length basis, our documentation is current and keeps pace with legislative requirements and business change, and we want to be prepared to defend our positions if challenged. We’re seeing more tax authorities looking at the end to end value chain in the business and wanting to understand the business in their territory within that broader context.
The current proposals on the taxation of the digital economy are very much front of mind, and we are monitoring developments here closely, whether they be at OECD, the EU or local territory level. The suggestion that the market territory is creating value that should be rewarded independently of functions, assets and risks in that territory is a fundamental shift in the arm’s length standard, and it is going to be very interesting to see how that develops.
In general, the pace of change in the global tax arena is the most rapid it has been in my entire career. Keeping up with the new regimes and navigating our business through the complexities will continue to be a challenge in coming years.
What do you know now that you wish you’d known at the start of your career?
It is important to let people know that you are keen to develop and expand your role and not assume that interesting projects will come to you. Demonstrate an interest in the business, and in what is going on within your team that is not necessarily within your direct responsibility. Leaders want people who can think strategically and make a broader contribution to the team.
Alongside this, I think building relationships and effective networking is really important – both with business colleagues (to get better understanding of commercial imperatives and opportunities, so that you can put your advice in context and add real value to the commercial decision making), and within the tax community (so you stay connected to new developments and ways of working).
If you could make one change to tax, what would it be?
Streamline legislation. In the desire to ‘abuse-proof’ rules, governments enact legislation that is extremely complicated – to the point where it is difficult for both taxpayers and tax authorities to manage. Also, adopt more common rules globally to ensure that disputes between jurisdictions can be minimised and double tax can be avoided.
How do you seen the tax landscape evolving over the next five to ten years?
I think whilst there is high level agreement on some of the issues that need to be tackled, there is little consensus on how those issues should be addressed. Organisations such as the OECD and EU are trying to reach compromise amongst a membership which holds widely divergent views. However hard this compromise is to find, it has to be done to avoid fragmentation and widely varying approaches being adopted, which can only lead to more controversy and a greater risk of double taxation.
And finally, you might not know this about me but…
You can’t work for a Japanese company without getting roped in to karaoke. My signature tune is ‘Twist and Shout’ by The Beatles, but I also do a mean Dolly Parton.
