Albert is a Director in KPMG UK’s transfer pricing practice with over 12 years of experience in transfer pricing. He advises multinational groups on complex transfer pricing matters across policy design, technical advisory, implementation and tax authority risk management.
Albert is a specialist in financial services transfer pricing, with a particular focus on the insurance sector. His work combines deep transfer pricing expertise with detailed knowledge of the insurance industry, the Lloyd’s market and their operational and regulatory environment. His experience includes:
- Reinsurance arrangements - advising on the design and pricing of cross-border intragroup reinsurance transactions, with regard to the transaction’s economic substance and the relevant capital requirements.
- Intermediary remuneration – designing and assessing arm’s length remuneration for a wide range of insurance intermediary arrangements.
- Attribution of profits to branches – advising insurers on the attribution of profits to permanent establishments under UK rules and OECD principles.
- Transfer Pricing Risk management – supporting on transfer pricing risk management, including the UK’s Diverted Profits Tax (DPT) and Unassessed Transfer Pricing Profits (UTPP) regimes.
- IP and Insurtech models – advising on the transfer pricing of technology-driven insurance models, including the remuneration of data, platforms and other intangible assets.
Albert’s wider financial services experience includes advising banks, asset managers, fintech businesses and commodity traders.