John Neighbour and Richard Iferenta launch new FS TP & Indirect Tax team at KPMG UK

KPMG has formed a new Financial Services Transfer Pricing and Indirect Tax team in response to how the practical consequences of regulatory changes and the ever-increasing globalisation of the financial services sector affect these specific areas of tax.

The new Financial Services Transfer Pricing and Indirect Tax team comprises around 50 people drawn from KPMG’s existing transfer pricing and indirect tax teams in the UK.  The team is being led jointly by John Neighbour, a transfer pricing partner and Richard Iferenta, an indirect tax partner, both from KPMG in the UK and both with extensive financial services experience.

According to KPMG in the UK, many businesses in the financial services sector are now reconsidering fundamental issues of business and legal entity organisation as a result of the considerable regulatory change in the industry that has ensued since the financial crisis began in 2007. 

Such changes include moving to a model where business is conducted through a subsidiary rather than a branch system, hiving off key trading operations to insulate retail depositors from higher risk investment banking activity and producing “living wills” to ensure greater transparency of operation and more easily recoverable operating structures among others.

These reorganisations and associated transactions trigger a number of transfer pricing and indirect tax issues which need to be dealt with in a co-ordinated manner, according to KPMG in the UK.

John Neighbour, transfer pricing partner and joint leader of the new team, commented: “Just last week George Osborne called for ‘a completely new culture of regulation’ and an agreed set of international rules in his ‘Mansion House’ speech at the Lord Mayor’s dinner.  This new regulatory framework has significant ‘on the ground effects’ such as triggering fundamental, structural changes often leading to transfer pricing and indirect tax issues which need to be tackled together.  It can often be the case that an approach which makes sense from a transfer pricing perspective may cause problems on an indirect tax front.  And complying with the rules is also a challenge with both areas being subject to many and varied rules and requiring extensive documentation.”