Jonathan Pilcher is a Managing Director in FTI Consulting’s European Tax Advisory practice who leads the Large and Complex Corporate Tax Advisory service line. Jonathan has a wealth of experience advising multinational groups and private equity funds on complex international tax issues including legislative changes arising as part of the OECD’s Base Erosion and Profiting Shifting (“BEPS”) initiative.
Jonathan has advised several multinationals regarding cross-border transactions involving both debt instruments and intellectual property. He has also assisted clients in understanding the implications of changes arising out of the BEPS reports published in 2015.
Currently, Jonathan is monitoring developments on the BEPS 2.0 initiative and the UK implementation of those recommendations to help multinational groups prepare for global minimum taxation.
Jonathan has worked on transactions where comparing the tax attributes of a number of holding company and intellectual property regimes has been crucial. Through these projects, he has developed an understanding of the factors which influence the attractiveness of a tax regime and the characteristics of the tax regimes of a number of key jurisdictions. Jonathan has assisted large corporates on significant cross-border transactions including divestment of subsidiaries to both existing shareholders and third parties.
Prior to joining FTI Consulting, Jonathan spent nine years at EY and Grant Thornton providing specialist international tax advice.
- Acted as an expert witness in an international arbitration case relating to double tax treaty shopping and cross-border financing concerning a global telecommunications company
- Resolved double taxation matters, including transfer pricing and residence, through Mutual Agreement Procedures involving tax authorities in the UK, India, Ireland and the U.S.
- Advised a U.S.-parented multinational hotel group with the spin-off of their real estate into a publicly held Real Estate Investment Trust (“REIT”)
- Advised a global activewear brand with divesting a number of their brands
- Restructured investments of asset management firms to mitigate the impact of global tax changes including BEPS
- Advising lenders on restructuring options in respect of lending to a distressed hospitality group