Transfer Pricing

Strategy Design

Strategy Design

Transfer pricing strategy and planning issues often arise when MNCs undertake new initiatives in mergers and acquisitions, performance benchmarking, business restructuring, and incentive management policies. NERA's strategy work focuses on developing sound transfer pricing solutions based on economic principles that satisfy management objectives and regulatory requirements. Leveraging our expertise in economics, NERA’s transfer pricing experts employ unique supply chain management, tax valuation, and value chain alignment models to provide our clients with transfer pricing strategies that consistently exceed expectations.

Supply Chain Management

Efficient supply chain management cannot be sustained without taking intercompany pricing into account. Transfer pricing has a strategic role in managing and controlling the allocation of profits among entities inside a multinational enterprise. Transfer pricing is essential for the successful management of a MNC's effective tax rate, and for its risk management. NERA is experienced in developing sustainable transfer pricing solutions to support our clients’ supply chain optimization initiatives and incorporating the desired tax planning strategies.

Transfer Pricing Due Diligence

NERA’s global regulatory work focuses on helping clients analyze and document their cross-border intercompany transactions in accordance with the tax regulations in the countries in which they operate. Our transfer pricing experts benchmark clients’ businesses against industry comparables in order to assess the risks they face. NERA’s access to financial databases and our knowledge of the transfer pricing compliance environment enable us to determine whether the transfer prices, commissions, royalties, or interest rates in a given transaction are in line with the arm’s length standard and country-specific requirements.

Transaction and M&A Support

Transfer pricing plays an important role in strategic business decisions related to internal restructuring processes and mergers and acquisitions (M&A). NERA’s transfer pricing experts have developed considerable experience in assisting clients with various aspects of restructuring and M&A activities, from support during the due diligence process to the management of post-merger integration issues. Our advisory work in this area includes:

  • Assessing clients' transfer pricing risks during the due diligence processes (buy-side);
  • Valuation of intangible property to determine an arm’s length taxable basis in the country of its ownership (sell-side);
  • Valuation of intangible property in the context of business combinations (IFRS 3);
  • Development of a "blueprint" for new or revised global transfer pricing policies in the context of post-merger integration; and
  • Valuation of intangibles or owner's equity, and design of transfer pricing policies in the context of business restructuring.
Name Title Location Phone Email
Dr. Yves Hervé Managing Director Frankfurt +49 69 710 447 508 yves.herve@nera.com
Dr. Harlow Higinbotham Managing Director Chicago +1 312 573 2803
+86 21 6103 5544
+86 10 6533 4395
harlow.higinbotham@nera.com
Dr. Emmanuel Llinares Managing Director
Head of Global Transfer Pricing
Paris
Geneva
London
+33 1 70 75 01 93
+41 22 819 94 94
+44 20 7659 8650
emmanuel.llinares@nera.com
Philip de Homont Director Frankfurt +49 69 710 447 502 philip.de.homont@nera.com
Dr. Vladimir Starkov Director Chicago +1 312 573 2806 vladimir.starkov@nera.com
Nihan Mert-Beydilli Associate Director Los Angeles +1 213 346 3035 nihan.mert.beydilli@nera.com
Tom Braukmann Principal Frankfurt +49 69 710 447 511 tom.braukmann@nera.com
Dr. Alexander Voegele Affiliated Consultant Frankfurt +49 69 710 447 501 alexander.voegele.affiliate@nera.com
Title Type Author
Managing Transfer Pricing in the COVID-Related Economic Downturn Published Article Dr. Harlow Higinbotham, Dr. Vladimir Starkov, Nihan Mert-Beydilli
Germany: The Changing Model of Group Financing Centres Published Article Yves Hervé, Philip de Homont and Georg Dettmann
NERA Experts Offer Insight into OECD Guidance on Financial Transactions White Paper Amanda Pletz, Ralph Meghames and Dr. Georg Dettmann
NERA Contributes to Bloomberg Tax Winter 2019 Transfer Pricing Forum Published Article Dr. Alexander Voegele and Philip de Homont
What Is the Value of Users, Anyway? How to Value the User Contribution to Digital Ent... Published Article Vladimir Starkov and Oceana Wang
Sustaining Contract R&D Service Solutions in a Post-BEPS DEMPE Context Published Article Dr. Yves Hervé, Philip de Homont
Implicit Support and Its Implications on Guarantee Fee Pricing: Fact or Fiction Published Article Amanda Pletz, Gary Lambert, Dr. Georg Dettmann, and Diana Kabir
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
How to Adapt to the DEMPE Concept When Using Third-Party Licensing Agreements for Tra... Published Article Dr. Yves Hervé, Philip de Homont
NERA Experts Comment on Digital Economy Discussion Paper by Australian Treasury Regulatory Filing Dr. Emmanuel Llinares, Dr. Harlow Higinbotham, Sébastien Gonnet, Dr. Vladimir Starkov