Guillaume Madelpuech



Tel: +33 1 70 75 01 58
Fax: +33 1 45 02 30 01

Email: guillaume.madelpuech@nera.com
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Master of Business Administration, ESSEC, Paris
Postgraduate degree (DEA) in economics (industrial organization), University of Paris Dauphine


Mr. Madelpuech is a Principal within the Paris Transfer Pricing Practice. He is an economist specializing in transfer pricing, economic modeling, and intercompany valuation. For a number of years, he has advised multinational enterprises with regard to their transfer pricing policy design, documentation, and defense, particularly in the case of projects related to business restructuring, intangible-related transactions and intellectual property migration.

Mr. Madelpuech has conducted a number of transfer pricing projects for multinationals in a wide range of industries, including high-tech, consumer goods, automotive, luxury goods, financial services, health care, real estate, media and entertainment, and energy. Prior to joining NERA, Mr. Madelpuech was an economist with EY transfer pricing and valuation groups for eight years, working in both Paris and New York City offices. He was praised by the French publication Décideurs as one of the lead economists for the EY Paris team, in 2011 and 2014.

Mr. Madelpuech is a frequent contributor to the OECD policymaking related to the Base Erosion and Profit Shifting (BEPS) Action Plan and has been invited to represent NERA at OECD public consultations. He has been a lecturer on transfer pricing at the University of Vienna, and at ESCP Europe. Mr. Madelpuech is a member of the Society of French Valuation Experts (SFEV) and of the International Fiscal Association (IFA). He is a frequent contributor to journals and trade publications.

Some of his work includes:

  • "Business Restructuring: The Arm's Length Principle Under Pressure (Business restructuring: le principe de pleine concurrence sous tension)" with Franck Berger in Option Finance, 17 February 2014
  • "Valuing Intangibles: The End of the Rule of Thumb? The Uniloc Case (Méthodes d'évaluation des redevances d'incorporels: La fin de la Rule of Thumb? La décision Uniloc)" in La Lettre Juridique et Fiscale, April 2011



Title Type Author
Bloomberg Tax Transfer Pricing Forum Published Article Alexander Voegele and Tom Braukman
Comment on OECD Discussion Draft of the BEPS Action 8 “Hard-to-Value Intangibles” Gui... Regulatory Filing Dr. Vladmir Starkov and Guillaume Madelpuech
Apple and the CCCTB: Can the European Commission Have Both? Published Article By Dr. Emmanuel Llinares and Guillaume Madelpuech
Economic Analysis for Developing Countries—Comments on the IMF, OECD, UN, and World B... Regulatory Filing By Dr. Vladimir Starkov, Sébastien Gonnet, and Guillaume Madelpuech
The take on comparables: A French perspective Published Article By Guillaume Madelpuech
Comments on the OECD Public Discussion Draft on the Attribution of Profits to Permane... Regulatory Filing By. Pim Fris and Guillaume Madelpuech
Discussion of the Amendments to Chapter IX of the OECD Transfer Pricing Guidelines on... Regulatory Filing By Pim Fris and Guillaume Madelpuech
The Impact of the OECD Hard to Value Intangible Framework Published Article 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
Discussion Draft on BEPS Action 10: Proposed Modifications to Chapter VII of the Tran... Regulatory Filing By Dr. Stuart Harshbarger, Dr. Vladimir Starkov, and Guillaume Madelpuech