Dr. Emmanuel Llinares

Senior Managing Director
Head of Global Transfer Pricing


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

Tel: +41 79 517 6895
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


Emmanuel Llinares, Chair of NERA’s Global Transfer Pricing Practice, is an economist specializing in transaction pricing, asset and business valuations, and intellectual property analyses in an international tax context. He has over 20 years experience in advising multinational companies and their legal advisors on defining and implementing their intra-group pricing policies, valuing assets including notably the pricing of complex transactions (intellectual property, financing, etc.). He has assisted them in the context of various re-structuring, pricing design, and negotiations with tax authorities. He has provided economic analyses in the context of tax and intellectual property-related litigations including the preparation of expert reports. Dr. Llinares has also advised governments in relation to specific corporate income tax-related cases. 

Dr. Llinares has managed a large number of valuation and intercompany pricing projects in a wide range of industries, including consumer products, telecommunication, energy, transportation, professional services, financial services, chemical industry, and various other sectors. He has been involved in the negotiation and preparation of several Advance Pricing Agreements. He has also managed the economic analyses aspects of a large number of tax-related audits in Europe and other regions.

Prior to joining NERA, Dr. Llinares was an economist with Arthur Andersen in London and with the KPMG network in Paris. Dr. Llinares 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. Between 2015 and 2019, Dr. Llinares was a member of the European Union Joint Transfer Pricing Forum, a group of leading experts in transfer pricing that advise the European Commission on transfer pricing matters.

Dr. Llinares publishes frequently on the subject of intra-group pricing and valuation. He regularly speaks at conferences on intra-group pricing and intellectual property at conferences in Europe and North America. Dr. Llinares is a member of the French Association of Valuation Experts (SFEV) and a member of the French branch of the International Fiscal Association (IFA). He is considered by Euromoney as one of the leading experts in Transfer Pricing. 



Title Type Author
Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Referenc... Book Amanda Pletz, Dr. Emmanuel Llinares, Dr. Niraja Srinivasan, Timothy McKenna, Ralph Meghames, Dr. Ronald Bernstein, Bernardo Danesi, Eugene Ng, Gary Lambert, and Mark Berenblut
Price Factoring Transaction Chapters in Intra Group Financial Transitions Reference G... Book Dr. Emmanuel Llinares and Bernardo Danesi
The Criminalization of Transfer Pricing in France: What the Future Holds Published Article Dr. Emmanuel Llinares
Taxation and Value Creation Book Dr. Emmanuel Llinares and Ralph Meghames
NERA Experts Offer Insight into OECD Guidance on the Transfer Pricing Implications of... White Paper
NERA Experts Comment on the OECD Proposal on Pillar One Blueprint Brief Dr. Harlow Higinbotham, Dr. Vladimir Starkov, Ralph Meghames, and Dr. Emmanuel Llinares
Irish Department of Finance Changes to Local Transfer Pricing Regulation White Paper Amanda Pletz, Dr. Emmanuel Llinares, and Bernardo Danesi
NERA Experts Comment on the OECD Proposal for a “Unified Approach” under Pillar One Regulatory Filing Dr. Vladimir Starkov, Dr. Yves Hervé, Amanda Pletz, Dr. Emmanuel Llinares, Dr. Harlow Higinbotham, Pim Fris and Dr. Jacques Potin
Transfer Pricing Treatment of Intangibles: Issues and Developments Published Article Dr Emmanuel Llinares and Ralph Meghames
NERA Experts Offer Guidance Through HMRC’s Diverted Profits Tax Legislation Brief Amanda Pletz, Dr. Emmanuel Llinares, and Bernardo Danesi