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The LCN Transfer Pricing Interview: Sam Cicogna


Intercompany Agreements

8 June 2017

We are delighted to feature an interview with Sam Cicogna, Vice President and Head of Onesource Transfer Pricing at Thomson Reuters.

How did you get into transfer pricing?

I started my career in a traditional tax role then later on moved into technology focused role, first internally in a corporate tax department then with Thomson Reuters. I spent years in that capacity, working with our customers to define their problems, figuring out solutions to those problems and teaching people the benefits of technology. I’m very passionate about finding ways to provide efficiencies for our customers. After some point in time I wanted to take on more, and the idea of running a business appealed to me. The role as the head of Transfer Pricing allows me to both run a business and to set the direction for our products and work with clients to understand their needs, so it was a great fit!

Who has been the most influential role model for your professional life?

It’s hard to pick just one person. I have been fortunate to work with some outstanding leaders and talented people at Thomson Reuters. I learned a lot along the way on how to conduct myself in a professional setting in my prior roles in both public accounting and corporate tax. If I had to pick one person I would pick my father, who started and ran a small business which he grew and then eventually sold off after it put three sons through college. He taught me the benefits of working hard and treating people with respect. He also taught me that no matter how hard you work, you need to make time for your family along the way.

What do you see as the biggest challenge affecting the transfer pricing functions of multinational corporates over the next 10 years?

The field in general is undergoing a large amount of change as the BEPS action items are being implemented. With new filings due, additional requests for information and continued need for transparency, many of the MNCs I have talked to are not increasing headcount. All of these challenges will contribute to the new normal of increased visibility and scrutiny for the function. The transfer pricing function will need to take a hard look at everything they do and find a way to become more efficient in order to get the compliance pieces done and spend their time on value-added activities. That’s where technology can be a great enabler and a best friend!

How would you change the OECD’s approach in relation to BEPS?

I think the OECD tried hard to collaborate with taxpayers and service providers in relation to the BEPS framework. They had multiple subgroups, requests for comments and meetings with various parties. I think what they underestimated was the cost of compliance and the level of effort that many taxpayers would need to undertake in order to comply, specifically related to Action 13. It’s hard to second guess, but I would have liked to see some more practical thinking related to how difficult the process would be for taxpayers, more standard definitions earlier in the process (e.g. the definition of revenues for Country by Country reporting), and recommendations as to the changes a taxpayer could make on second-year filing if they need to change. I believe their view was that more options (local STAT vs. GAAP, bottom-up vs. top-down, etc.) gave more options for simplicity. In reality I think it created more complexity and more scenarios for MNCs to test in evaluating how their positions would be viewed once filed.

In a movie of your life story, which actor would you like to play you?

This is a great question. I’m thinking Jon Stewart. His humorous take on life fits in pretty well with my personality. I ran this question by my wife, and her answer was Adam Sandler. So you get the trend! Eventually she agreed with Jon Stewart… but “without the beard!”

What would be your dream job if you didn’t work in transfer pricing?

I’ve always been kind of drawn to academia (university level), so I think I would continue my education and look to teach.

What is your biggest extravagance?

I like to travel. Typically a few times a year I will take a trip somewhere with my family. Most of those trips are domestically within the US – to the beach or see friends who live in other cities, although I also enjoy seeing cities outside the US as well. I have great memories of family vacations when I was young. My hope is to provide those kind of memories for my kids (and enjoy the trip myself as well!).

What do you do to relax?

I try to work out several times each week. It’s a really good stress relief and I can tell a difference on long days when I didn’t get to the gym that morning. Other than that, I like to read, spend time with my family and hang around with my friends.

What is your favourite holiday destination?

There are several US beaches that I particularly enjoy. They are all on the gulf coast side of Florida, where it’s a bit quieter and the beach itself is nicer. When my kids were younger, we used to go to pretty secluded beaches to just unwind. We went to one place, Casey Key Beach for a few years. It was great because it was not very touristy. There are very few places to rent, and the time of the year we went was not a time where locals were there. So it was very secluded and relaxing. When my kids got older they got bored so that was the end of that. I also love London. I have had the opportunity to add some time on to work trips and take my wife or my family with me. There’s so much history and so much to do in the city, and visiting other parts of the UK outside of London has been fun, too!

What piece of advice would you give your 18-year-old self?

It seems very cliché, but I would say to trust your judgment, be true to yourself and always treat others with respect. When I think about decisions I have made in my life that didn’t work out well, I always went against an instinct and reflected on it later. Also, I’m a firm believer that people succeed partially because of their own talents and work ethics and partially because they have great people around them. I would tell my younger self to NEVER forget that principle, to work hard, and to try and pass on lessons to your kids.

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Article by
Paul Sutton
LCN Legal Co-Founder

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