Dr. Emmanuel Llinares

Managing Director

Head of Global Transfer Pricing


Tel: +33 1 70 75 01 93
Fax: +33 1 45 02 30 01

Tel: +41 22 819 94 94
Fax: +41 22 819 19 90

Tel: +44 20 7659 8650
Fax: +44 20 7659 8501

Email: emmanuel.llinares@nera.com
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PhD in economics, University of Delaware
Doctorate in economics, University of Lyon


Dr. Llinares is an economist specializing in inter-company pricing, valuation, and intellectual property analyses. For a number of years, he has advised multinational companies on defining and implementing their intra-group pricing policies and has assisted them with design, documentation, and tax audit defense. Dr. Llinares also assists clients in the context of commercial or intellectual property-related litigations.

Dr. Llinares has managed scores of large intercompany pricing projects for multinationals in a wide range of industries, including transportation, energy, chemical, luxury goods, financial services, health care, real estate, media and entertainment, and food and beverage. He has also managed the economic analyses aspects of a large number of tax-related audits in Europe and other regions. He is considered by Euromoney to be one of the world's leading transfer pricing advisors.

Dr. Llinares has been a member of the EU Joint Transfer Pricing Forum since June 2015.

Prior to joining NERA, Dr. Llinares was an economist with Arthur Andersen in London and with the KPMG Tax network in Paris. He is a former lecturer at the Economics Department of the University of Delaware and at the Ecole Supérieure de Gestion, a business school in Paris.

Dr. Llinares has a PhD in economics from the University of Delaware and a doctorate in economics from the University of Lyon. He publishes frequently on the subject of transfer pricing and valuation.



Title Type Author
NERA Experts Review OECD Discussion on Financial Transactions and Recommend Starting ... Regulatory Filing Dr. Emmanuel Llinares, Amanda Pletz and Gary Lambert
Comments on OECD Request for Input on Work Regarding Tax Challenges of the Digitalize... Regulatory Filing Harlow Higinbotham, Pim Fris, Vladimir Starkov and Emmanuel Llinares
Comments on OECD Discussion Draft on the Revised Guidance on Profit Splits Regulatory Filing Emmanuel Llinares, Harlow Higinbotham, Nihan Mert-Beydilli, and Vladimir Starkov
Apple and the CCCTB: Can the European Commission Have Both? Published Article By Dr. Emmanuel Llinares and Guillaume Madelpuech
Discussion Draft on BEPS Action 8: Discussion Draft on Hard-to-value Intangibles Regulatory Filing Pim Fris, Dr. Emmanuel Llinares, and Guillaume Madelpuech
BEPS Action 8: Revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost C... Regulatory Filing Dr. Vladimir Starkov, Vladimir Starkov, Dr. Emmanuel Llinares and Pim Fris
BEPS Action 8, 9 and 10: Discussion Draft on Revisions to Chapter I of the Transfer P... Regulatory Filing By Pim Fris, Dr. Emmanuel Llinares, and Dr. Vladimir Starkov
Discussion Draft on BEPS Action 10: Use of Profit Split in the Context of Global Valu... Regulatory Filing By Dr. Harlow Higinbotham, Dr. Emmanuel Llinares, and Pim Fris
BEPS Action 10: Discussion Draft on the Transfer Pricing Aspects of Commodity Transac... Regulatory Filing By Amanda Pletz and Dr. Emmanuel Llinares
The Value of Intangibles in a Changing Global Financial Services Sector Presentation By Dr. Emmanuel Llinares and Amanda Pletz