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John
Neighbour
Director, Bank Tax Ps and As
KPMG in the UK
John is a Special Advisor in KPMG’s London office and for many years was the Deputy Global Lead for GTPS and lead of the Global Financial Services TP practice.
Immediately before joining KPMG LLP (UK), John worked at HMRC as the leader of financial services transfer pricing, arbitrage, private equity and thin capitalisation. John was also the Competent Authority for all financial services transfer pricing and permanent establishment issues (including APAs).
Prior to his time at HMRC, John was with the OECD where he was Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division. One of his main responsibilities at OECD was the work on revising the OECD Transfer Pricing Guidelines, especially the work on attributing profits to PEs. John was also responsible for the major OECD project on improving dispute resolution (including use of arbitration) and for outreach work with non-OECD economies on transfer pricing and financial innovation.
At KPMG, John has used his extensive theoretical and practical experience to help clients with a wide range of TP problems, but with a special focus on clients in the financial services and energy sectors and on financial transactions and dispute resolution/APAs.
John has written many articles across a number of tax journals and has spoken widely at tax conferences, workshops and seminars. He has also led OECD missions and outreach activities to a number of non-OECD countries in Eastern Europe, Southern Africa, Latin America and Asia.