Rachit Agarwal

Principal Economist

Rachit Agarwal has gained significant experience in transfer pricing having worked in India, the Netherlands and in UK. He has been involved in a variety of transfer pricing matters ranging from advisory, audit support, compliance, risk assessment and mitigation and restructuring spanning different geographies.

His main area of focus is intra-group finance transactions including cash pools, loan portfolio valuations, debt pricing, guarantee fees, factoring arrangements, debt capacity review, derivatives analysis, designing group financing policies, etc. The other areas where he has worked include asset valuations, business restructuring, exit charge assessment, value chain analysis, transfer pricing policy design and anti-trust matters. He has also been involved in developing audit defence strategies on various transfer pricing matters across Asia, Europe and North America.

Rachit is an instructor for transfer pricing courses conducted at International Bureau of Fiscal Documentation and has lectured on transfer pricing at Vienna University, Leiden University and Maastricht University. Further, he has held transfer pricing training sessions for clients and has been a speaker at various conferences. He also regularly publishes articles on transfer pricing matters in leading tax journals.


  • Successfully defended the intra-group financing structure and valuation of intangibles with Dutch Tax Authorities
  • Significantly involved in the APA process for a number of multinationals with the Dutch Tax Authorities
  • Designed a group-wide cash pool and long term financing policy for a European life sciences major
  • Valued a portfolio of financial instruments to be transferred from Belgium to the Netherlands and significantly reduced the capital gain tax impact by pricing embedded options
  • Designed transfer pricing model and a tax impact in APAC and Europe for a consumer goods major
  • Hindi
  • CFA Institute, CFA Level III Candidate
  • University of Amsterdam, Masters of Science, Economics, 2010
  • University of Delhi, Bachelor of Arts (H), Economics, 2006


  • Brand Intangibles - Getting it right for Tax Purposes, May 2017
  • Foreign Exchange Risk Management and Control Post BEPS Combined with Turmoil in Global Currency Markets, Dec 2015