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 Senior Managing Director Frankfurt +49 69 710 447 508
Dr. Harlow Higinbotham Senior Managing Director Chicago +1 312 573 2803
Dr. Emmanuel Llinares Senior Managing Director
Head of Global Transfer Pricing
+33 1 70 75 01 93
+41 79 517 6895
+44 20 7659 8650
Philip de Homont Managing Director Frankfurt +49 69 710 447 502
Dr. Vladimir Starkov Managing Director Chicago +1 312 573 2806
Tom Braukmann Director Frankfurt +49 69 710 447 511
Alexis Jin Consultant Chicago +1 312 573 4804
Dr. Alexander Voegele Affiliated Consultant Frankfurt +49 69 710 447 501
Title Type Author
Referentenentwurf zur Funktionsverlagerungsverordnung: Erhöhtes Risiko von Streitverf... Published Article Dr. Jens Rubart and Ronald Bernstein
‘Coca-Cola’ vs. Section 482: Is It Time to Refresh the Regulatory Guidance? Published Article Dr. Harlow Higinbotham and Dr. Niraja Srinivasan
NERA Experts Contribute Chapter to "The Future of the Profit Split Method" Book Dr. Harlow Higginbotham and Dr. Vladimir Starkov
Transfer Pricing Roundtable in Financier Worldwide. Expert QA Dr. Vladimir Starkov and Philip de Homont
Amount B: Facts and Circumstances Matter—Even for Routine Distributors Published Article Dr. Harlow Higinbotham and Dr. Vladimir Starkov
Dr. Yves Hervé’s Interview in Financier Worldwide Report Dr. Yves Hervé
Taxation of the Digital Economy: Analysing User Base Value Published Article Dr. Yves Hervé and Philip de Homont
NERA Experts Comment on the OECD Proposal on Pillar One Blueprint Brief Dr. Harlow Higinbotham, Dr. Vladimir Starkov, Ralph Meghames, and Dr. Emmanuel Llinares
NERA Experts Author a Chapter in New Book on Transfer Pricing Developments Around the... Book Amanda Pletz
Assessing the Transfer Pricing Treatment of COVID-19 Restructuring Published Article Dr. Yves Hervé and Philip de Homont