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

Recent work

Pillar Two

Assisting a multinational technology group with its Pillar Two impact analysis, including advising on various issues concerning the application of the rules.

Treaty issues

Advising an international energy business on tax treaty issues including the applicability of non-discrimination provisions.

Sovereign investors

Advising a foreign government pension scheme on the UK’s proposals to reform sovereign immunity, and on its eligibility for pension scheme tax relief.