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How to assemble your team of tax adviser superheroes

Group Reorganisations

Intercompany Agreements

1 November 2017

This article appears in the November issue of our International Corporate Structures Newsletter.

I have often been asked what makes a good international tax adviser. My general response is that I ask one key question: whether that person has the overall potential to be an in house Head of Tax (‘’HOT’’).

In my dealings with global tax advisers in Europe, Asia and the US, I have always assessed them under two main criteria:

  1. The ’given’ features, which include:

  • Honesty
  • Integrity
  • Respectful
  • Personable
  • Technically strong

  1. The additional features, which include:

  • Strong commercial awareness
  • Looks beyond theory
  • Sees the broader picture
  • Makes a point of really understanding the client’s business
  • Listens and doesn’t preach
  • Doesn’t start the billing clock at every opportunity
  • Maintains regular contact
  • Talks ‘we’ not ‘I’ (i.e. a team player)

Before sharing some of my experiences of dealings with advisers, let me first make the point that this article is covering ongoing working relationships, rather than one off specific projects which may just require the help of specialist tax lawyers or other subject matter experts.

I have generally worked with global offices of the Big 4 accounting firms as, in recent years, this tended to be the policy adopted by the HQ tax senior management seeking consistent advice and support. However, as I was fortunate in having been around before such tax adviser policies were introduced, I used to select my advisers on a country by country basis using my HOT approach.

Sometimes I’d appoint a Big 4 office but without being tied to that particular firm in other countries. In other cases, I’d also speak with tax lawyers or specialist advisers and select the one who best fit my needs for the work involved and the country concerned. Following the introduction of the head office policies on appointing tax advisers, I had to justify any out-of-policy choice, but ‘grandfathering’ prevailed, as did being able to highlight quality and expertise issues in certain countries necessitating a non-standard appointment.

Although I understood the HQ desire for a single global tax advisory firm for planning and compliance, in practice this didn’t tend to work for all countries. For example, in one major country, the partner believed he should turn the billing clock on as soon as the phone rang or he received an e mail. Despite me telling him that we didn’t like working that way, he persisted. As he wouldn’t adapt his approach, he was replaced on our case.

Another area that disappointed me with a few advisers was an obsession to produce extensive theoretical presentation decks at meetings. This made me think they weren’t sure how to deal with our matter. Most of the time I just wanted to discuss the practical aspects of a project or issue.

Despite the occasional negative experience, during my career I’ve been lucky to work with some really terrific advisers from the Big 4/Big 10 as well as tax lawyers, transfer pricing advisers and other subject matter experts in various countries. We built mutual trust and respect and were able to talk openly with each other. I didn’t require voluminous justification papers; their word and short summary was more than sufficient. I’m fortunate to count them as friends too.

From that select band, do I have a no.1 adviser? Yes, a consultant in Italy who I’ve known for years who meets all my HOT criteria. He has exceptional knowledge of economics, accounting and tax plus he makes sure he keeps informed on EU, US and international tax developments.

It has been a pleasure and a privilege to work with them all. My sincere thanks, you know who you are.

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Article by
Ian Barron

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