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The LCN Tax Interview: Brian Sturtz

Group Reorganisations


Intercompany Agreements

27 March 2014

We are delighted to feature an interview with Brian Sturtz, former Director of International Tax and Transfer Pricing at Walmart Stores, Inc., and former former Director of International Tax at Univar, the global chemicals distribution group. Brian passed away on August 13, 2015.

What are your top 3 likes when dealing with national tax administrations?

1) Transparency regarding the issues they are really wanting to look at. Let’s put it on the table and work through it. Tax examiners who take this approach make both our efforts more efficient.

2) I know I have to earn trust to get this kind of info, but I'd like to know the real story behind what is going on with our case. If person X just hates a particular method, for example, we can work around that person's preferences. I guess I’m asking to be treated as an ally here.

3) Be up front about what you think we can realistically achieve and how we can help achieve that right from the initial submission. I'd rather adjust our position up front to help the negotiation process than be surprised at a poor outcome later.

What are your top 3 dislikes when dealing with national tax administrations?

1) Stubborn advocacy of nonsensical positions when all of the facts and law are clearly against them.

2) Internal disputes or personal disagreements that affect my case, are obvious to everyone involved, yet management won't intervene.

3) Asking for large amounts of data that can't possibly have any relevance to the issues we are working through. I appreciate you have to do your due diligence, but asking me for every piece of data my company has ever generated is a pointless waste of time and a reason I won't pursue APAs with certain countries known for this behavior.

What has been one of your worst experiences when dealing with a national tax administration?

At our first (informal) meeting, the team leader gave me a three page list of improvements and enhancements he wanted to see in our APAs. He failed to tell me they had tried to get our company to make these changes before and most had been deemed impractical. I looked like a goof to my boss not knowing the history of this request when I asked for fees to do what we already knew was the impossible.

Who’s getting it right? – give an example of a tax administration or department which is getting it right.

HMRC! I love working with them! They are professional, helpful, pragmatic, provide honest assessments of situations. First rate all the way.

What would be your ideal job if you didn’t work in tax?


What is your favourite movie?

The World According to Garp.

Which actor should play you in a movie of your life story?

Christopher Reeve were he still alive. I've been told I look like him.

If you had to swap your life for that of a rock star, which rock star would that be?

John Lennon. He had his priorities right.

Who would be your ideal guests at a dinner party?

Ewan McGregor and Charlie Boorman, These guys have gone around the world (twice) on their motorbikes. I bet they have some great stories to tell.

The views expressed above are personal and do not necessarily represent those of the interviewee’s organization.

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Article by
Paul Sutton
LCN Legal Co-Founder

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