AstraZeneca’s Ian Brimicombe addresses BEPS and US inversion transactions

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 TPWeekto read Ian Brimicombe’s comments in full.

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