Shiv Mahalingham

UK
Transfer Pricing

Shiv Mahalingham is the key UK member of Taxand’s global transfer pricing team. He is based in Taxand UK where he is a Managing Director with Alvarez & Marsal Taxand UK in London. He has many years of senior business experience as an international tax and transfer pricing adviser.

Shiv has assisted clients across several industry sectors, including financial services, investment management, real estate, fast moving consumer goods, entertainment, retail, pharmaceuticals, manufacturing, technology, telecommunications and energy. He has been called as an independent expert witness in a number of transfer pricing cases, and has concluded dispute resolutions and APAs in jurisdictions including the U.S., U.K., Australia, Singapore, France, the Netherlands and Germany.

Prior to joining the UK Taxand practice, Alvarez & Marsal Taxand UK, Shiv was with Ernst & Young, where he led a number of large projects such as tax effective value chain optimisation for FTSE 100 groups; thin capitalisation studies for high-profile, private equity backed buyouts; and transfer pricing risk/opportunity assessments for FTSE midcap and fledgling groups. Shiv also spent two years with a major fortune 500 company, establishing in-house transfer pricing risk controls, systems and planning structures.

Shiv brings a broad mix of academic skills, having studied economics and then taxation law before qualifying as a chartered accountant and a chartered tax advisor. He is a regular speaker at international transfer pricing conferences and has published more than 40 articles in international journals (including the International Tax Review, BNA Transfer Pricing, Taxation, Tax Adviser, Tax Journal, Tax Business, Tolleys Practical Tax, Finance Director, World Finance, and a case study in the Harvard Business Review). In addition, Shiv meets with U.K. tax authorities on a regular basis to consult on transfer pricing issues, and has been asked to assist HM Treasury to assess the commercial impact of proposed transfer pricing legislation.

Shiv is frequently quoted on international tax matters in the U.K. press, including mentions in the Financial Times, the Guardian, the Observer, the Times, the Telegraph, the Dow Jones Newswire and Accountancy Age. At the age of 26, Shiv was accepted as one of the youngest fellows in the history of the U.K.'s Chartered Institute of Taxation (CIOT) for his thesis on modernising U.K. tax legislation, while maintaining the competitiveness of the U.K. economy. He recently became an examiner for the CIOT and is charged with helping to maintain the standard of newly qualified tax advisors in the U.K.

Before embarking on a career in transfer pricing, Shiv played three seasons of professional basketball with the English Basketball League.

Areas of Expertise

• Transfer Pricing
• Tax Efficient Value Chain Optimisation
• Thin Capitalization Studies

www.alvarezandmarsal.com