- James advises multinational groups across a wide range of industries, but has a particular focus on US and Japanese inbound groups in the technology sector.
- James specialises in designing, documenting and implementing tax efficient transfer pricing policies and helping clients to successfully resolve HMRC transfer pricing enquiries, mitigate double taxation through Competent Authority I EU Arbitration claims and negotiate APAs.
- Recent projects include: preparing OECD-compliant Masterfile I Local File documentation for a FTSE 250 group; concluding a bilateral UK-Japan APA for a Japanese computer games group; and negotiating a settlement to a long¬ standing HMRC transfer pricing enquiry for a US technology group, including obtaining HMRC's approval that Diverted Profits Tax (DPT) would not apply.