Brexit: What does it mean for Transfer Pricing Recruitment?
05 July 2016

A very interesting question indeed. What impact does the recent and historically significant vote by the British people have on the present and future careers of transfer pricing professionals, both in the UK and internationally?

Well, for a start, possibly nothing. Until Article 50 of the Lisbon Treaty is triggered by a British government, the UK is still a fully paid, signed up member of the European Union. The vast sums of cash the UK pays to the EU each week that the “Leavers” claim is being wasted, is still being paid. The significant rebates the UK receives each week to offset against this funding to give the true, net position, are still being received. Until such time as the UK actually exits the EU (if that even happens in our lifetime!), nothing has actually changed.

Ah, but I hear you cry “what about all the uncertainty in the meantime”? Another very valid question. No-one really expected this result but what can this mean moving forward due to the uniqueness of the situation and lack of precedent?

Transfer Pricing professionals and Economists are used to dealing with this concept of uncertainty – whether it be with respect to ‘gaming’ scenarios around shifting functions, assets and risks, or business valuations, or critical assumptions not being met in an Advance Pricing Arrangement, dealing with and pricing/adjusting for uncertainty is part of the TP practitioners toolkit.

With respect to Transfer Pricing careers at the present time, the Brexit decision may result in an initial period of cautiousness from UK employers, however, in this period of unprecedented change to the international transfer pricing and international tax landscape caused by BEPS, Country by Country Reporting (“CbCR”) and Deferred Profits Tax (“DPT”), the Brexit vote has not caused the Arm’s Length Principle to disappear.  Without question, the rest of the world has paused, stopped to look at the disarray, had its sharp intake of breath but has generally moved on with their own lives and troubles.

The Arm’s Length Principle it is still the cornerstone of the international Transfer Pricing framework and it still applies in the UK. More countries are adopting CbCR by the day, compliance burdens have not decreased, audits have not stopped; so in the short to medium term, TP International does not see a slow down in Transfer Pricing related recruitment – certainly our clients in the UK have not stopped recruiting and we have mandates at all levels of seniority in more than 25 countries at present.

There has also been a considerable amount of talk about major Multinational Corporations (“MNCs”), particularly financial institutions and banks, moving significant functions or whole operations to favorable EU locations (Amsterdam seemed to win the latest straw poll of being the most suitable EU location with Dublin also featuring prominently. One wonders how these kinds of locations could cope with the influx of over 300,000 City workers in one fell swoop).

However, George Osbourne, somewhat predictably, has pulled the ‘lowering the Corporation Tax rate’ card from the deck to nullify the attractiveness of “Double Dutch Irish Sandwiches” or some other tax structuring concoctions that “clever accountants” can come up with.

Some are concerned that when the UK formally exits the EU, all current EU workers in the UK will have to leave. This seems highly unlikely on a couple of fronts: 1. Despite the “Leave” campaign advocating that ‘Brexit’ means the axing of Free Movement, it seems pretty clear from the 27 remaining EU members that Free Movement in some shape or form will have to continue if any meaningful trade negotiations are going to proceed; 2. The introduction or expansion of the current points based work permit system will surely apply and TP professionals from outside the EU have been coming to the UK to progress their TP careers for more than 20 years under this system. The education requirements, prior UK work experience and salary criteria under these arrangements will certainly ensure that EU TP professionals will easily jump these hurdles and be able to stay in the UK.

Unless international trade comes to a grinding halt because of ‘Brexit’, then Transfer Pricing will continue to be the number one international tax issue facing every MNC and they will need TP experts in-house and as external advisors to help them to solve their TP problems and to continue to be creative with structuring business operations in the post-BEPS environment.

As mentioned, TP International currently has mandates in over 20 countries including the UK, the Middle East, Australia, Switzerland, Luxembourg, Singapore, Belgium, The Netherlands, France, Germany – you get the idea. So for a confidential discussion, please do not hesitate to contact the team at TP International and see how we may be able to assist (www.tpi-search.com)

We have also recently revamped our website to make the candidate experience more interactive. You can now register your details and request a Login and password in order to manage your preferences and register for job alerts and updates.   For a confidential conversation on how Brexit may be impacting your career, please contact Aaron Leslie at al@tpi-search.com