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Tax Controversy Leaders
November 2025
London, UK

Diane Hay
Former UK Competent Authority & Advisor at INDEPENDENT EXPERT
Speaker

Profile

Until 2009 Diane was the Deputy Director at HM Revenue & Customs with responsibility for international corporate tax, including heading up HMRC’s transfer pricing team and acting as the UK Competent Authority with responsibility for Advance Pricing Agreements and Mutual Agreement Procedures.After leaving HMRC, Diane joined PwC as a Special Advisor on international corporate tax where she specialised in helping clients to successfully resolve long-running and difficult enquiries with HMRC and other tax authorities, alongside developing her deep expertise in APAs and MAP cases.Diane was selected as one of the 10 Outstanding Women in Tax globally in the first list prepared by Tax Analysts in 2016.She is now an independent consultant working with a number of large businesses offering advice on MAPs and APAs and strategy for dealing with large enquiries.

Agenda Sessions

  • Latest Policy Makers’ and Tax Authority Approaches to Tax Controversies & Litigation

    09:25
  • Dissecting Apple - Getting to the Core of Attribution of Profits to PEs - Main Hall

    16:40