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
Dr. Harlow Higinbotham Managing Director Chicago +1 312 573 2803
+86 21 6103 5544
+86 10 6533 4395
Dr. Emmanuel Llinares Managing Director
Head of Global Transfer Pricing
+33 1 70 75 01 93
+41 22 819 94 94
+44 20 7659 8650
Sébastien Gonnet Director Paris
+ 33 1 45 02 30 00
+39 02 305771
Dr. Vladimir Starkov Director Chicago +1 312 573 2806
Nihan Mert-Beydilli Associate Director Los Angeles +1 213 346 3035
Tom Braukmann Principal Frankfurt +49 69 710 447 511
Pim Fris Affiliated Consultant Brussels
+32 2 282 4355
+33 1 70 75 01 91
Dr. Alexander Voegele Affiliated Consultant Frankfurt +49 69 710 447 501
Title Type Author
NERA Experts Comment on Digital Economy Discussion Paper by Australian Treasury Regulatory Filing Dr. Emmanuel Llinares, Dr. Harlow Higinbotham, Sébastien Gonnet, Dr. Vladimir Starkov
The Rising Role of Transfer Pricing in Tax Planning and Litigation Published Article Philip de Homont
Forum: Taxation of Intangible Assets Published Article Emmanual Llinares, Harlow Higinbotham, and Yves Hervé
Using statistical analysis to improve TNMM Published Article Yves Hervé and Philip de Homont
DEMPE Analysis for CUP Studies Published Article Yves Hervé and Philip de Homont
Bloomberg Tax Transfer Pricing Forum Published Article Alexander Voegele and Tom Braukman
Comments on OECD Discussion Draft on the Revised Guidance on Profit Splits Regulatory Filing Emmanuel Llinares, Harlow Higinbotham, Nihan Mert-Beydilli, and Vladimir Starkov
Recent Developments on the Profit Split Method Book Sébastien Gonnet
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