30 Seconds With Alberto Bermejo, Head of Tax and Transfer Pricing, Ferrovial

Alberto Bermejo, Head of Tax and Transfer Pricing at Ferrovial shares his Transfer Pricing insights in our latest 30 Second interview.
What are you currently working on?
We are sailing the international group over the waters of current tax turmoil, trying to limit a negative impact to our stakeholders from various tax uncertainties. Growth requires certainty to make the best decisions and to set the path towards value generation.
What is the biggest challenge facing Transfer Pricing executives in your sector now?
The interaction of different jurisdictions with different cultures and approaches; each one eager for tax income ‘food’. The transition from the old model to the new model at a time when coordination between jurisdictions is generally the last item on the agenda requires flexibility from multinational corporations or acceptance of higher costs from tax inefficiencies.
What should a successful transfer pricing strategy look like?
Avoiding the appearance that the only rationale is tax driven. Alignment with true business drivers is the key to sustainable TP strategies, where logical and reasonable justifications fall naturally from the tree. However, classical international tax items careful need to be considered.
What in your view is the main practical challenge of BEPS for heads of TP?
Higher cost to the taxpayers with minimal legal certainty in return. Cost shall come in the form of burdensome formal obligations and the increasing amount of challenges from local tax authorities with no expectation of effective global coordination. This landscape is very positive to auditing firms.
Arm’s length or formulary apportionment?
While arm’s length is not perfect, the formulary apportionment requires further work from governments. Headlines are very useful for picturing an idea but apportionment requires decisions beyond just tax technical analysis.
What advice would you give an aspiring TP professional?
The basic approach is functional analysis and financial reasonability. When you do not consider assets, functions and risks or you do not reasonably compare your testing party. You are instead creating a new imaginary world.
Tell us a little known fact about yourself.
I’m a Latin spirit in a globalized world. Family, friends, joy and sun are essential parts of my life. Together with sport, this helps in balancing my soul from the stringent global professional world of today.