Margaret Kayser

UK Competent Authority, Business, Assets & International at HMRC

Margaret Kayser has worked on international tax issues for 15 years, all of which have been within HM Revenue & Customs. Since July 2016 she has been a senior Competent Authority in the HMRC APA and MAP team. As a Competent Authority her role involves leading negotiations on APA and MAP cases with Fiscal Authorities from other jurisdictions. She has been involved in a number of arbitration cases as the representative of the UK Competent Authority on Advisory Commissions set up under the EU Arbitration Convention. Her APA and MAP work mainly involves non-financial transfer pricing transactions and arrangements and profit attributions to permanent establishments, and she has developed a particular area of expertise for cases involving intellectual property and business restructurings.

Margaret's prior career history, since joining HMRC’s head office Business, Assets, and International section in 2008 as a transfer pricing specialist included a variety of roles, not least as: The policy lead for the UK’s Anti-arbitrage legislation; UK expert on “hybrid” arrangements to the OECD’s Aggressive Tax Planning Steering group; The HMRC technical lead for applying the UK Transfer Pricing legislation to tax avoidance arrangements involving financial transactions; Policy advisor for the design of the UK Debt Cap legislation; Joint UK Branch reporter to the International Fiscal Association; An HMRC technical advisor on private equity funding structures. In March 2013 she became the UK Competent Authority based in Washington DC as a delegate to the Joint International Taskforce for Shared Intelligence and Collaboration (JITSIC); a post she held until July 2016. Based in the British Embassy, Margaret was responsible for enhanced Exchange of Information on complex tax avoidance cases with the United States and Canada. I also had responsibility for developing Enhanced Exchange of Information relationships with Latin American and Caribbean countries/territories.