Martin Walker

Martin Walker

Tax Consultant
Baker & McKenzie LLP
Not admitted to practice law in this jurisdiction


Martin was an Inspector of Taxes in HMRC for 33 years until 2019 with a primary focus on international tax issues. From 2006 he led transfer pricing teams and contributed to governance panels for both medium and large businesses. Martin had direct involvement in over 300 transfer pricing enquiries across a range of sectors, principally large tech and digital economy businesses in the latter 5 years.

In Baker McKenzie, Martin acts in both in depth and ad hoc advisory capacities on a range of TP and DPT enquiries and PDCF reviews in the tech and digital economies as well as in the pharma and oil industries.

Practice Focus

Martin focuses on transfer pricing, diverted profits, and permanent establishment disputes as well as contributing to PDCF reviews.

Martin ensures that HMRC's limited commercial awareness does not lead to onerous information requests and powers or protocols are not overstepped. Martin guides inexperienced HMRC case teams on the approach that HMRC has taken historically to settling similar issues.

Martin brings in his experiential knowledge advising clients on what is likely to be behind HMRC's current approach and what HMRC are likely to see as red lines, setting out what the enquiry looks like from an HMRC governance perspective and where client vulnerabilities may lie.

Representative Legal Matters

  • Annually reviewed and advised 80-100 cases in a wide range of business sectors as a member of the Transfer Pricing and Diverted Profits Tax Governance panels in medium and large business categories, while in HMRC 2006-2019.
  • Resolving enquires in the digital advertising and selling sectors, with emphasis on transfer pricing solutions arising from the presence of significant people functions and key economic risk takers in the UK and abroad.
  • Bringing pragmatism to the table while negotiating and convincing clients to keep the HMRC team on board through modest concessions in certain areas, to smooth the passage through governance while maintaining a firm defence on any question of profit split.
  • Finding ways to explain the key commercial drivers in a business to HMRC case teams, which have a limited commercial understanding and exposure, so they can appreciate and focus on just the key issues.
  • Advising clients on how best to phrase responses and present information so as to not set alarm bells ringing in HRMC.


  • University of Oxford (MA Chemistry) (1981)