Bezhan Salehy Tax policy specialist

Tax policy specialist
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Bezhan advises clients on the latest developments in UK and international tax policy and the implications for their businesses.

Bezhan joined Macfarlanes from HM Treasury, where as head of international corporate tax he was responsible for developing policy and advising ministers on cross-border corporation tax matters, most notably Pillars One and Two of the OECD’s BEPS 2.0 project. He also led work on base protection policy including transfer pricing and diverted profits tax, controlled foreign company rules, the offshore intangibles charge, the hybrid mismatch rules, and restrictions on interest deductibility.

Prior to that Bezhan worked for HMRC. Initially that was as a tax inspector in the large business directorate, leading enquiries into multinational businesses in the financial and energy sectors. He then spent several years in head office specialist roles covering areas including intangibles relief, the venture capital schemes and the taxation of partnerships.

Bezhan started his career in practice and is a Chartered Accountant and Chartered Tax Adviser.

Expertise

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In depth

Unpacking Pillar Two: US implementation

Sarah Ling, Ashley Greenbank, Bezhan Salehy 04 May 2022
The Build Back Better Act, the US legislation that would bring its existing minimum tax rules in line with the OECD’s BEPS 2.0 project, has stalled in the Senate, bringing into...
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Unpacking Pillar Two: treatment of flow-through entities

Rhiannon Kinghall Were, Bezhan Salehy 27 Apr 2022
The question of how transparent entities are treated within the GloBE rules is important in determining how profits are allocated. The model rules provide some guidelines but...
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Unpacking Pillar Two: transfer pricing

Bezhan Salehy, Rhiannon Kinghall Were 21 Apr 2022
Because the GloBE rules look at an MNE group’s effective tax rate (ETR) on a country-by-country basis, the question of how a group’s profits are allocated between countries is of...
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