Swarnalee Naskar

Throughout her career, Swarnalee has specialised in transfer pricing, both in the United Kingdom and Germany. Having previously worked in Big 4 accounting firms in Germany, she has comprehensive experience in advising clients across all areas of the transfer pricing lifecycle, with a particular focus on resolving transfer pricing disputes and controversy. Her work includes undertaking comprehensive technical analysis and negotiating settlements with HMRC in the context of tax audits related to diverted profits and general transfer pricing matters as well as supporting clients in navigating Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA) processes with the tax authorities.

Additionally, she provides strategic advice in relation to operating model design, implementation, and defence of complex cross border restructurings to multinational clients across various industries, most notably, Technology, Media, Telecommunications (TMT), Pharmaceuticals, Automotive, Fragrance & Flavours, Oil & Gas and Energy.

Swarnalee has provided strategic advice to numerous multinational organizations on a diverse array of transfer pricing matters, with a particular emphasis on the design and defense of transfer pricing policies.

• Leveraging her extensive experience in transfer pricing disputes, Swarnalee has co-led negotiations with HMRC, successfully resolving several high-value, high-profile audits for clients in the Pharmaceutical, TMT, Fragrance & Flavours and Oil & Gas industries. Her work includes drafting advocacy letters in response to HMRC’s propositions, undertaking complex financial modelling including corroborative profit split analysis as well as participating in meetings with HMRC to negotiate the settlement.
  
  
  • Assisting an industry-leading automotive multinational company with their transfer pricing audit in the UK and supporting an Oil and Gas company through HMRC’s HRCP enquiry process.
  
  
  • Supporting a Fortune 50 company in the Energy sector through negotiations with tax authorities concerning a MAP process.
  
  
  • Advising a multinational TMT company on successfully navigating HMRC’s PDCF process, undertaking comprehensive transfer pricing technical analysis and engaging in strategic discussions with HMRC defending the client’s proposal and ultimately, securing a favourable outcome for the client.
  
  
• Swarnalee has also played a pivotal role in supporting major multinationals with the implementation of business restructuring initiatives, incorporating tax effective transfer pricing designs.
  
  
  • Advising one of the top ranking contract research organisations in design and implementation of their new transfer pricing business model followed by a comprehensive value chain analysis. She is assisting the client through a bilateral APA process and is involved in the negotiations with the relevant competent authorities.
  
  
  • Assisting an FMCG multinational company on IP planning and migration by advising on the technical aspects of the planning strategy including a comprehensive DEMPE analysis, preparing relevant documentation and collaborating with the client’s tax and planning team to implement practical business focused solution.