Simon Wood

Simon is an international tax partner specialising in transfer pricing. His primary focus is compliance including documentation, risk management and operational transfer pricing. He also helps groups work through business change and international expansion, designing and adapting transfer pricing policies to suit the specific needs of the business. Part of what he loves about transfer pricing is that it revolves around the business and its people, which shape the facts and tax analysis, and the satisfaction that comes from getting to know his clients. His goal is to help his clients navigate the requirements, understand risks and expectations and balance their competing priorities. He likes to try and keep things as simple as possible, focusing on what really matters.

He has significant experience working with groups of all sizes and across many sectors, with 15 years prior experience working in a Big 4 firm and, more recently, nearly 4 years of experience leading on large and complex transfer enquiries as an HMRC senior international tax specialist. During that time, He was also a member of HMRC’s ‘Guidelines for Compliance’ technical drafting team and an international regional governance group member.

He is well placed to assist clients with the following:

• Documentation and benchmarking
• Business restructurings analysis and related documentation, including intragroup ‘inward’ and ‘outward’ intangible asset or business disposals
• Designing new transfer pricing policies e.g., in response to international expansion and business change
• Complex technical analyses, including ‘risk control’, ‘DEMPE’ analysis and pricing where there are no comparables
• Cost contribution arrangements/cost share agreements (with significant US Inbound experience)
• Attribution of profits to permanent establishments and the pricing of ‘internal dealings’
• Transfer pricing dispute resolution and enquiry management (with experience both sides of the fence)
• Profit Diversion Compliance Facility (PDCF) risk working (including experience of handling and concluding them while at HMRC)
• Advanced Pricing Agreements and Advanced Thin Cap Agreements
• Sector specific analysis and insights including in particular Pharmaceutical, Media, Platform Operators, IT, eCommerce, Gambling, FMCGs and Luxury goods.