John Hayes
John is a Chartered Accountant with over 40 years of experience in UK and International Tax Structuring. After graduating with a BSc Hons in Mathematics from the University of Liverpool, began his career at Chalmers Impey and Co. in Liverpool, specializing in statutory audit and financial reporting. John qualified as a Chartered Accountant and was admitted to membership of the ICAEW in 1980, where he has been a fellow member (FCA) since 1990.
In 1981, he joined Price Waterhouse in Manchester to help build their tax practice, with a focus on corporate and expatriate tax, and US profit repatriation. In 1987 he moved to their London office as a Senior Manager in the International Tax group, and was admitted as a Partner at Price Waterhouse in January 1989.
Following the 1998 merger of Price Waterhouse and Coopers and Lybrand, John led PwC’s combined inbound International Tax Structuring practice based in London, working with large multinationals and UHNW family offices, as well as developing global tax strategies for a wide range of the firm’s clients across the US and Europe.
As in house Tax Consultant at AGP, John is able to advise clients on a broad range of cross border tax issues for individuals and companies based in the UK and elsewhere. These include:
- exit strategies – including pre departure planning
- individual tax residence and double tax treaty claims
- corporate tax residence and permanent establishment issues
- place of effective management “POEM” test in double tax treaties
- transfer pricing – including benchmarking and documentation requirements
- financing structures and interest expense limitation
- profit repatriation including dividends, interest and royalties
- Intellectual Property and Holding Company structures
- Tax investigations, controversy, and litigation strategies
John’s specialist skills enable him to work closely with AGP’s clients to ensure that the cross border tax aspects are properly coordinated, and any opportunities to improve their position can be taken into account. He is skilled in assessing the effects of the ever-changing landscape of the international tax system, including the ongoing focus by the OECD and UN on global tax avoidance following BEPS Actions, as well as SARBOX compliance. This expertise makes John perfectly placed to help clients navigate complex international tax regimes and their associated regulatory provisions.