Stuart Duff Email & Phone Number

Lossiemouth, Scotland, United Kingdom

SD Operations Limited is the legal vehicle for me to flexibly provide transfer pricing and management support services on an ad-hoc basis to a variety of clients based on my wide-ranging international professional experience.Incorporated, insured, VAT registered

Elgin, Scotland, United Kingdom

Lossiemouth

Lossiemouth, Scotland, United Kingdom

Lossiemouth, Scotland, United Kingdom

Düsseldorf, North Rhine-Westphalia, Germany

In Germany‘s largest corporate spin-off, Uniper launched with approx. 8 bn. EUR worth of E.ON assets in conventional electricity generation and energy trading.My unique role involved proactively setting up groupwide internal structures, filling structural gaps primarily from a transfer pricing perspective.Key Achievements• Development and introduction of Uniper‘s fundamental transfer pricing structures following spin-off from E.ON• Legal implementation of Uniper… Show more In Germany‘s largest corporate spin-off, Uniper launched with approx. 8 bn. EUR worth of E.ON assets in conventional electricity generation and energy trading.My unique role involved proactively setting up groupwide internal structures, filling structural gaps primarily from a transfer pricing perspective.Key Achievements• Development and introduction of Uniper‘s fundamental transfer pricing structures following spin-off from E.ON• Legal implementation of Uniper Group‘s functional steering model via dedicated Delegations of Authority concept• Establishment and submission of Uniper‘s Country-by-Country Reporting according to OECD GuidelinesAdditional Tasks• Initial investigation of Uniper‘s cross-border transfer pricing requirements across all groupwide functions (commercial, operations, trading and group management divisions)• Analysis of functions and risks profiles (inter alia financing loans and guarantees, electricity and gas trading, engineering, outsourced IT, HR and Accounting, permanent establishments)• Determination of coherent arm‘s length remuneration models (Comparable uncontrolled/market prices, cost-plus, cost pooling)• Legal structuring and contractual definition of transactions• OECD compliant transfer pricing documentation• Introduction of worldwide Uniper Transfer Pricing Community Show less

Essen, North Rhine-Westphalia, Germany

At E.ON I was part of a small team responsible for groupwide transfer pricing.We actively ensured compliance with the arm‘s length principle across all intragroup cross- border transactions such as loans, services and energy trading.Key Achievements• Successful defence of E.ON brand transfer pricing in German tax audit• Preparation of Uniper SE spin-off as part of 1-2-2 project Additional Tasks• Preparation of transfer pricing documentation for E.ON SE and… Show more At E.ON I was part of a small team responsible for groupwide transfer pricing.We actively ensured compliance with the arm‘s length principle across all intragroup cross- border transactions such as loans, services and energy trading.Key Achievements• Successful defence of E.ON brand transfer pricing in German tax audit• Preparation of Uniper SE spin-off as part of 1-2-2 project Additional Tasks• Preparation of transfer pricing documentation for E.ON SE and finance companiesincluding intragroup loans totalling approx. 30 bn. EUR• Tax treatment of bond buybacks• Proactive transfer price monitoring in accordance to E.ON group guidelines Show less

Cologne, North Rhine-Westphalia, Germany

Key Achievement• Consultancy with concurrent study of bilingual Executive Masters degree• Consultant work for diverse multinationals primarily from a transfer pricingperspective covering compliance, structure and business model analysis• Tax efficiency and transfer of functions planning

Frankfurt Am Main, Hesse, Germany

Key Achievement• Consultancy with concurrent study of bilingual Executive Masters degree• Consultant work for UK-headquartered multinationals from an international taxperspective with a focus on tax groupings, corporate, trade- and withholding tax• Participation in onsite VAT tax audit defence

Masters Emat, Executive Master Of Accounting And Taxation

Erasmus/Socrates Year, German Law

Llb Law And German Law (Hons.) With Options In Economics, Law And Economics, 2/1