Bezhan Salehy Senior Associate

Bezhan helps clients answer difficult tax questions and manage their relationship with HMRC.

His advisory practice is focused on helping corporate clients navigate the complex international tax rules that they face including transfer pricing and diverted profits tax, controlled foreign company rules, hybrid mismatch rules, and restrictions on interest deductibility. A significant part of his work involves advising on recent and ongoing policy changes in these and other areas, including supporting clients in engaging with policymakers and responding to public consultations. His sector experience includes the investment management, energy, technology, and consumer goods industries.

He 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. Prior to HM Treasury Bezhan worked for HMRC, initially as an inspector in the Large Business directorate and then in several head office specialist roles covering areas including intangibles relief, venture capital reliefs and the taxation of partnerships. Having led and resolved high-value enquiries covering a multitude of issues he has a detailed understanding of how HMRC approaches large business tax compliance in practice, which he uses to support clients to work constructively with HMRC, and to manage and resolve disputes when they arise.

Bezhan regularly writes for specialist tax publications. He is both a Fellow of the Institute of Chartered Accountants in England and Wales and a Chartered Tax Adviser.