Mr Edward Morris, Deloitte UK, served as a Delegated Competent Authority for Mutual Agreement Procedures and Advance Pricing Agreements in the International Section of Her Majesty's Revenue and Customs (HMRC). He was seconded to the European Union (EU) Commission to work on APAs and the Arbitration Convention, and joined Deloitte in 2008. He has attended OECD for both the UK and the EU. He demonstrates a unique track record in the world of transfer pricing dispute resolution and dispute avoidance. Edward is a well-known figure to the competent authorities of many of the world's finance ministries.
Edward came to Deloitte after a 12-year career in the Head Office International section of HMRC. This work involved dispute resolution on MAPs, as well as dispute avoidance work on APAs with fiscal authorities around the world. Edward was also involved in a whole range of international tax issues and problems, but specialized in transfer pricing, PEs, and treaty matters. Edward also represented the UK and the EU Commission at OECD and was heavily involved in the OECD work on international dispute resolution (helping to draft the new arbitration clause in the Model Treaty) and business restructuring.
Building on his experience of APAs (including the largest multilateral APA entered into by the UK) while in government, Edward has led several APAs for Deloitte clients, including two pan-European multilateral procedures.
While in HMRC, Edward worked on all of the UK's MAP cases and achieved a 100 percent track record for eliminating double taxation. This record has been maintained during his time at Deloitte, where he has also advised on pan-European Arbitration Convention proceedings.
Edward led some of HMRC's most complex and major transfer pricing audits, including involvement in litigation work before the UK courts. This work has given Edward a great deal of insight into various industries, including information technology, telecommunications, pharmaceutical, motor, high technology, oil and gas, entertainment, distribution, manufacturing, and R&D.
While at HMRC, Edward enjoyed a two-and-a-half year secondment to Brussels, where he advised the EU Commission on APAs and transfer pricing matters. Edward was responsible for steering the EU APA Guidelines through the EU Council.
Edward's eminence in the wider international tax field was recognized by the OECD when he was asked to speak at the 50th anniversary celebration of the OECD model tax convention and by IFA at the 2011 Annual Congress when he participated in the opening panel on business restructuring issues.
Edward has a BA in Medieval and Renaissance history from Warwick University. He is happy to advise on the rise and fall of the Italian City States in the Quattrocento should the opportunity arise.