13 years of experience in conceptualizing and implementing complex transfer pricing solutions in a UK and pan-European context
Specializes in all aspects of debt pricing and thin capitalization analyses
Advised numerous clients on transfer pricing audits and controversy
London
@alvarezmarsal
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Deyan Mollov is a Senior Director with Alvarez & Marsal Tax U.K. He brings more than 13 years of experience in transfer pricing.
He has supported clients across a wide range of industries including oil and gas, commodities trading, energy, real estate, specialty chemicals, pharmaceuticals, financial services, consumer business, and automotive sectors.
Mr. Mollov has experience assisting clients on a wide range of complex transfer pricing issues including planning and implementation of business restructurings, debt pricing and thin capitalization analyses, valuation of intangible assets, analysis and implementation of inter-company management charges, risk pricing, and the preparation of three-tier transfer pricing documentation (master file, entity file, review of the Country-by-Country reporting).
Prior to joining A&M, Mr. Mollov spent twelve years with Deloitte in London and Paris. Over the past several years, Mr. Mollov has specialised in all aspects of thin capitalization and debt pricing arrangements, in the context of U.K., French and pan-European transfer pricing projects. He has also led the audit defence in a number of tax controversy cases specifically focused on debt pricing arrangements for real estate funds and industrial companies.
Mr. Mollov earned a bachelor’s degree in International Finance and Economics from the American University of Paris and is fluent in French, English and Bulgarian.
In March this year, HM Revenue & Customs (HMRC) opened a consultation on the U.K.’s transfer pricing documentation requirements. The consultation seeks input for updating the U.K.’s transfer pricing documentation requirements and requests possible options and design ideas that could benefit U.K. business and HMRC.
The main change of CbCR requirements that will impact the reporting and compliance burden on U.K. companies relates to the additional notification requirement. This change is in line with the OECD Model and the EU Directive on Administrative Cooperation (2011/16/ EU, or DAC4) on mandatory exchange of information. It will possibly not be welcomed by companies as it creates an additional deadline outside the annual selfassessment return process, even though the actual notification will probably be identical for later years for most companies.
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