Graeme Webster

• Joined KPMG in April 2018 having spent the previous 17 years at HM Revenue & Customs, with the last 10 years specialising in international tax policy and operations.
• Transfer pricing policy lead for the banking and asset management sectors at HMRC, and a Delegated Competent Authority heading negotiations for HMRC with major treaty partners.
• Took part in HMRC governance at the highest level sitting on the Transfer Pricing Board, advising and determining outcomes on HMRC’s largest financial services audit enquiries.
• As an HMRC OECD delegate, led policy discussions with trade sector representative groups and other public bodies including the Prudential Regulatory Authority.
• At KPMG leads transfer pricing relationship with a number of the firm’s largest banking clients. Continues to be heavily involved in the firm’s interaction with HMRC and the OECD.

Relevant Experience

• Resolving double taxation disputes under the Mutual Agreement Procedure and negotiating Advance Pricing Agreements with leading economies including Japan, the USA and Germany covering the application of the AOA for attributing profits to the permanent establishments of banks.
• Led for HMRC on Irish Bank Resolution Corporation Ltd and another v Revenue and Customs [2019] UKUT 277 (TCC) covering issues of branch capital attribution
• Advisory panel member for the UK’s first case to be resolved by panel under the EU Arbitration Convention.
• UK Delegate to the OECD contributing to BEPS actions 7 and 8 to 10, including UK response to 2018 paper Additional Guidance on the Attribution of Profits to a Permanent Establishment
• Advising on a number of Brexit restructurings projects involving structuring through branches and subsidiaries, including bilateral engagement with tax authorities.
• Supporting UK bank branch clients on a number of HMRC enquiries, including enquiry with £150m+ tax risk