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Bernhard von Thaden

Principal Economist
About

Bernhard von Thaden focuses on transfer pricing, intangible valuation, supply chain and tax planning for public and private multinational companies. He is a recognized authority in these fields due to his extensive practical experience and long-standing work with high-profile clients.

Bernhard’s highly complex fields of transfer pricing and intangible asset valuation require deep technical knowledge. For decades he has successfully applied complex transfer pricing and valuation methods, he feels at home in advanced financial and economic models, and he effectively stays on top of continuously changing tax policy, legislative and market trends. He has experience working with both public accounting and law firms, which gives him a unique and valuable blend of legal, economic, and accounting perspectives.

Moreover, Bernhard assists in transforming multinational corporations' transfer pricing functions, implementing technology solutions for data sourcing, analysis, reporting, and workflow management, which lead to improved processes and controls.

For over 25 years Bernhard has advised a wide range of companies, including public and private Fortune 500 firms, as well as mid-market and start-up companies allowing him to reference diverse and innovative legal strategies, and offer more informed risk assessment.

Clients benefit from working with Bernhard because he is able to provide astute guidance in controversy situations, helping them resolve transfer pricing issues before they arise, including the use of Advance Pricing Agreements (APAs).

Bernhard von Thaden is not a lawyer.

Education
  • M.B.A., SDA Bocconi (Milan, Italy)
  • Masters in Economic Geography, International Relations, Business Administration, Ludwig-Maximilians-Universitaet (Munich, Germany)

EXPERIENCE

Bernhard has broad experience in the following areas:

  • Supply chain planning, tax planning and international restructuring under continuously evolving OECD policy guidance and successive U.S. Tax Reforms, including value chain planning, intangible planning, shared services and principal structures, as well as post-merger restructuring.
  • Controversy, including audit defense, support under Appeals, as well as Competent Authority procedures (MAP and APAs).
  • Global compliance (transfer pricing documentation, local intercompany filings) covering all relevant countries in the Americas, EMEA, and APAC.
  • Transforming multinational companies’ transfer pricing function, including processes and controls for cross-functional transfer pricing management, addressing organizational challenges, as well as implementing technology solutions for data sourcing, transfer pricing analysis and reporting, global compliance, as well as workflow and knowledge management.

Representative Projects – Intercompany Pricing

  • Successfully implemented tax structure and transfer pricing policy for newly established global e-commerce platform of a Fortune 100 electronics distributor.
  • Led engagement for negotiation and successful implementation of US-China Bilateral Advance Pricing Agreement (APA) for Fortune 100 life sciences company; APA covered 11 roll-back and 7 future years with complete elimination of double taxation.
  • Successfully settled combined transfer pricing and customs audits by US, Korea, China and Argentina; essential part of supporting analysis was reconciliation of pricing methods under tax and customs regulatory frameworks, and defending analysis in front of respective authorities.
  • Consolidated global transfer pricing compliance for numerous Fortune 500, as well as small and medium-sized, companies in the life sciences, entertainment, technology and defense sectors; led to huge efficiency gains due to risk-based tiering of individual jurisdictions, deployment of specialized resources, and deployment of automation and AI tools.

Representative Projects – Transaction Support

  • Advised and closely assisted global technology and defense company with integration of a transformative acquisition, incl. integration of supply chains and underlying transfer pricing policies, assessment of historical transfer pricing risks, support in defending historical tax positions, implementing updated transfer pricing policy and establishing state-of-the-art transfer pricing processes and intercompany data solutions.
  • Advised and supported Fortune 100 life sciences company in preparing major division for a spin and IPO; implemented SpinCo’s in standing up a transfer pricing function as part of newly established tax and accounting departments.
  • Implemented transfer pricing policies, as well as intercompany processes and controls for major Korean e-commerce company in preparation of US IPO.
  • Over period of 20+ years, performed numerous buy-side transfer pricing and IP valuation due diligence for Fortune 100 life science company.

Representative Projects - Intellectual Property Valuation

  • Valued product and process IP for a newly launched product line of Fortune 100 life sciences company for purpose of establishing a qualified cost-sharing agreement.
  • Valued customer IP (brand, customer list, contracts) for global e-commerce company for purpose of setting up globally aligned tax structure with centralized IP ownership.
  • Performed legal entity valuations for Fortune 500 technology and defense company for purpose of global restructuring; required normalizing legal entity financials for corrected transfer pricing.
Languages
  • English
  • German

AWARDS AND RECOGNITION

International Tax Review has repeatedly named Bernhard one of the state-of-the-art leading transfer pricing advisers.

Seminars

He is a regular speaker at industry, tax, and transfer pricing events such as those hosted by TEI, ABA, NABE, TP Minds and TP Symposium.

  • “Implications and Scope of Amount B: Simplified and Streamlined Approach,” TP Minds West Coast, 2024
  • “Reviewing your Transfer Pricing Strategy,” TP Minds West Coast, 2023

PRIOR EXPERIENCE

Bernhard has held significant leadership and senior roles in the fields of transfer pricing and valuation, as well as non-profit governance roles. Most recently, Bernhard was a Principal at one of the Big Four accounting firms.