Transfer pricing cases are usually won or lost on the facts. In NERA’s experience, the key to effective resolution of transfer pricing audit disputes is a credible and convincing narrative as to what drives profits, based on analysis of functions, assets, and risks along with supporting financial information and regulatory context. It is essential to integrate the value chain analysis and the underlying economics of the business. With the introduction of country-by-country reporting under OECD’s BEPS initiative—which may lead to misperceptions of the roles and responsibilities and contribution to value creation by the members of a global organization— understanding and quantifying contributions to the value chain consistent with the underlying economics of the business becomes even more important.

In a breakfast panel, "Transfer Pricing Audits and Value Creation: The Importance of the Underlying Business Rationale," NERA Senior Vice President Dr. Harlow Higinbotham, NERA Vice President Dr. Vladamir Starkov, and former Vice President Nihan Mert-Beydilli will present examples of value chains and profit metrics from actual case studies, showing the potentially differing perspectives of taxpayers and tax authorities regarding value chains and value creation.

NERA's breakfast panel will take place on 29 January 2016 at 7:15 am. To register, visit the ABA's website.