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NERA's approach to transfer pricing documentation aims to combine compliance-oriented and policy-guiding approaches by developing intercompany pricing policies grounded in sound business strategy and well-established economic principles. Our thorough analysis of the industry structure and its value chain combined with rigorous analytical methodologies and clear presentation of the results allow us to develop transfer pricing solutions that meet both our clients’ business objectives and the arm’s length requirements imposed by national tax authorities.
A "masterfile" approach to transfer pricing documentation is a practical and cost-efficient solution for MNCs with operations in a group of countries that follow a common set of transfer pricing principles, such as those outlined in the OECD Transfer Pricing Guidelines or in the Pacific Association of Tax Administrators documentation requirements.
Best practices in creating masterfiles combine the centralized approach to documentation development with information gathering and review at the local level. NERA’s global network of transfer pricing experts provides MNCs with the capabilities to utilize our extensive data resources to implement this robust approach.
FASB Interpretation No. 48 (FIN 48) outlines procedures for recognition and measurement of uncertain tax positions in order to record them on financial statements. In a transfer pricing context, the tax benefits are often considered equivalent to the lack of increased income recognition in a given country resulting from transfer pricing adjustments imposed by the local tax authorities. Transfer pricing has a significant impact on FIN 48 disclosures of MNCs.
NERA assists clients with several aspects of FIN 48 implementation including:
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. 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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Increasing Transfer Pricing Litigation for Multinationals Operating in Europe | 30 March 2021 | |||
Global Transfer Pricing Forum 2020 | 01 December 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 | |||
NERA Sponsors the Ninth Annual IBA Finance and Capital Markets Tax Conference | 20 January 2020 | |||
Third Annual NABE Tech Economics Conference (TEC2019) | 03 November 2019 | |||
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 | ||
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 | ||
NERA Economic Consulting Announces Senior-Level Promotions | 19 March 2019 | Press Release | ||