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Siwen Cai works with multinational corporations, law firms, and tax authorities to address transfer pricing issues including transfer pricing planning, documentation, controversy, and intangible asset valuation. Ms. Cai has expertise in developing and defending effective arm's length pricing strategies, conducting rigorous economic analysis based on functional reviews and value chain analysis, and building financial models for planning and valuation. She advises clients on complex intercompany transactions and develops and uses modeling tools to assess the tax and business implications of global transfer pricing policies.


Ms. Cai has assisted clients with the negotiation of unilateral and bilateral Advance Pricing Agreements (APA) with tax authorities in North America, Asia, and Europe; the preparation of transfer pricing compliance documentation for different jurisdictions; and the design and implementation of global profit split systems to align profit allocation with value creation. Her work spans many industries, including consumer products, online retail, software and digital services, technology, automotive, and pharmaceuticals.

Ms. Cai is a Chartered Financial Analyst® (CFA®) charterholder and a member of CFA Society San Francisco.


  • MA in international economics and finance, Brandeis University
  • BA in economics, University of International Business and Economics, China


  • Chartered Financial Analyst (CFA)