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Although cost-sharing arrangements have been used by multinational companies (MNCs) as part of tax planning strategies for years, recent regulatory developments have subjected cost-sharing arrangements to intense scrutiny. These developments include a major reformulation by the US Internal Revenue Service (IRS) of the 1995 cost-sharing regulations in January 2009; OECD ongoing revision of guidance on business restructuring; and the introduction by the German tax authorities of aggressive regulations related to valuing transfers of functions or risks in 2005.
Under these new regulations, certain intercompany transfers of intangibles—broadly defined as transfers of any profit-driving assets and capabilities—may have to be valued under a framework where all of the benefits from the transferred intangibles, including the benefits from subsequent development of these intangibles, accrue to the original intangibles developer.
NERA's experts assist clients in addressing the new requirements of these regulatory pronouncements and in adapting the valuations applied for existing arrangements and restructuring transactions to the new valuation paradigms.
Name | Title | Location | Phone | |
---|---|---|---|---|
Dr. Yves Hervé | Senior Managing Director | Frankfurt | +49 69 710 447 508 | yves.herve@nera.com |
Dr. Harlow Higinbotham | Senior Managing Director | Chicago | +1 312 573 2803 | harlow.higinbotham@nera.com |
Dr. Emmanuel Llinares |
Senior Managing Director
Head of Global Transfer Pricing |
Paris
Geneva London |
+33 1 70 75 01 93
+41 79 517 6895 +44 20 7659 8650 |
emmanuel.llinares@nera.com |
Philip de Homont | Managing Director | Frankfurt | +49 69 710 447 502 | philip.de.homont@nera.com |
Dr. Niraja Srinivasan | Managing Director | Washington, DC | +1 202 466 9290 | niraja.srinivasan@nera.com |
Dr. Vladimir Starkov | Managing Director | Chicago | +1 312 573 2806 | vladimir.starkov@nera.com |
Tom Braukmann | Director | Frankfurt | +49 69 710 447 511 | tom.braukmann@nera.com |
Alexis Jin | Consultant | Chicago | +1 312 573 4804 | alexis.jin@nera.com |
Dr. Alexander Voegele | Affiliated Consultant | Frankfurt | +49 69 710 447 501 | alexander.voegele.affiliate@nera.com |
Title | Date | |||
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What is on the Transfer Pricing Horizon? | 04 March 2022 | |||
Increasing Transfer Pricing Litigation for Multinationals Operating in Europe | 30 March 2021 | |||
Global Transfer Pricing Forum 2020 | 01 December 2020 | |||
IFA New England Fall Conference | 05 November 2020 | |||
TP Minds International 2020 | 01 September 2020 | |||
Life Sciences Accounting and Reporting Congress | 10 August 2020 | |||
Keeping Your International Tax Structure Healthy During a Pandemic | 29 July 2020 | |||
Advanced Transfer Pricing Course at Leiden University | 23 February 2020 | |||
2020 Global Transfer Pricing Conference: Transfer Pricing Developments Around the Wor... | 19 February 2020 | |||
Lecture on Economic Regulation of Natural Monopolies and Optimal Design of Intellectu... | 04 February 2020 | |||
Title | Date | Type | ||
---|---|---|---|---|
Horst Frisch Economists Join NERA’s Transfer Pricing Practice | 13 September 2022 | Press Release | ||
NERA Expert Recognized as a Leader in Tax by ITR World Tax | 12 September 2022 | Press Release | ||
Horst Frisch Joins Forces with NERA | 18 July 2022 | Press Release | ||
NERA Experts Promoted to Associate Director, Senior Consultant, and Consultant | 23 March 2022 | Press Release | ||
NERA Corporate Tax Expert Recognized in Who’s Who Legal 2021 | 01 October 2021 | Press Release | ||
NERA Director Philip de Homont Listed in Rising Stars Expert Guide 2020 | 22 February 2021 | Press Release | ||
Global Transfer Pricing Expert Joins NERA Economic Consulting | 10 September 2020 | Press Release | ||
Steadfast in Uncertain Times: How NERA Is Responding | 16 April 2020 | Press Release | ||
NERA Economic Consulting Opens Office in Milan, Italy | 19 November 2019 | Press Release | ||
Who’s Who Legal Recognizes 28 NERA Experts in 2019 Consulting Directory | 30 July 2019 | Press Release | ||