AstraZeneca’s Ian Brimicombe addresses BEPS and US inversion transactions

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

AstraZeneca’s Ian Brimicombe addresses BEPS and US inversion transactions

Ian Brimicombe, VP of corporate finance at AstraZeneca, discusses the struggle between regional and global compliance in an interview with TPWeek, and provides his views on topical transfer pricing issues.

Brimicombe has expressed his views on some of the most important transfer pricing issues in the headlines, including concerns over BEPS and country-by-country reporting and the increasing amount of US companies attempting inversion transactions in the UK.

Brimicombe has also spoken in detail with TPWeek about the makeup of AstraZeneca’s tax department, day-to-day transfer pricing issues and the company’s strategy for mitigating tax disputes.

The interview reveals the inner workings of the AstraZeneca tax department including its organisational structure, key objectives and tax dispute strategies.

“Our key objective is to implement domestic and international rules in a compliant way. On occasion it can be a challenge to secure agreements between governments as to how to allocate profits between the various activities located around the world,” Brimicombe said.

Brimicombe also addresses the issue of commercial sensitivity in relation to BEPS documentation requirements and gives an insight into what he thinks has motivated US companies’ desires to relocate to the UK.

“There is a clear tax motivation in such “inversion” transactions. If you look at the US tax system right now, for US based MNCs investing outside the US, there is a classic arrangement that permits minimal tax on overseas profits and deferral of US tax provided these profits remain offshore from the US.”

The full interview will be available on TPWeek.

Register for a free trial on TPWeek to read Ian Brimicombe’s comments in full.

more across site & shared bottom lb ros

More from across our site

The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
Gift this article