Bernhard von Thaden, Principal Economist at DLA Piper, specializes in international transfer pricing and business and intangible valuation for publicly-traded and private multinationals in a wide variety of sectors. His industry experience over the past 10+ years includes client sectors as diverse as high tech (software, hardware, capital equipment, and telecom), media, life sciences, consumer goods, automotive, logistics, and transportation, as well as energy and natural resources.

Mr. Von Thaden has strong experience in managing global transfer pricing and valuation projects covering all types of transactions, among them including cost sharing, licensing, intercompany services, and financing. Over the years, he has successfully run transfer pricing and valuation projects for a variety of purposes, including:

• Global compliance covering all relevant countries in the Americas, Europe, and Asia;
• Controversy, including audit defense and unilateral and bilateral Advance Pricing Agreements;
• Tax planning and international restructuring, including supply-chain restructuring, intangible holding companies, leveraged financing, centralized procurement, and trading structures, as well as contract manufacturing and commissionaire structures; and
• Developing and refining state-of-art procedures around transfer pricing management that meet requirements under FAS 109 and SOX 404.

International Tax Review has repeatedly named him one of the leading transfer pricing advisers in Los Angeles, and he has been cited in the 2008 Guide to the World's Leading Transfer Pricing Advisers. Mr. von Thaden is a frequent speaker at industry, tax and transfer pricing events such as those hosted by TEI, Euromoney, ATLAS, and CITE. He recently testified before the US Department of the Treasury on the APA Programs' area of improvement. Finally, he has written numerous articles on transfer pricing and related topics, published in the International Tax Review.

Before joining DLA Piper, Mr. von Thaden was a partner with KPMG's valuation and transfer pricing practice, which he joined after working with Roland Berger and Partner, a leading international management consulting firm in Europe. He received an MBA with a focus on investment banking from Bocconi University in Milan and a Masters in Economic Geography from Ludwig-Maximilians University in Munich. He is fluent in English, German, and Italian.

Representative Projects

• Successfully managed bilateral APA between the US and the Netherlands for one of the world's leading semiconductor equipment manufacturers. The APA included a very substantial transfer of a portfolio of intellectual property.
• Successfully concluded unilateral APA for the world's leading industrial laser manufacturer.
• Successfully assisted a global IT outsourcing company in reaching no-adjustment settlement in a US transfer pricing audit.
• Restructured and strengthened an intangible holding company and commissionaire structure for a leading developer of corporate software.
• Implemented a centralized purchasing company for Canada's leading printing and media company.
• Implemented a trading company and commissionaire structure for one of the world's leading dental systems companies.
• Restructured and strengthened an intangible holding and purchasing company for a leading toy company.
• Annually prepare global transfer pricing documentation for more than 20 countries throughout the Americas, Europe, Asia, and Africa for one of the world's leading medical instruments company; successfully assisted the company in settling both US and overseas transfer pricing audits with no or minor adjustments.
• Assisted a large mortgage company in preparing transfer pricing policy and process documentation for SOX 404 compliance.
• Assist companies in a variety of sectors in preparing tax reserve calculations under FAS 109.
• Performed and managed numerous fair market value analyses for tax as well as financial reporting purposes, including purchase price allocations, stock options, companies and entities, value discounts and premiums, and a wide variety of intangible assets.