• Preparation of annual contemporaneous documentation reports for a US high technology multinational, including 40 separate country compliant reports under the OECD framework
  • Numerous valuations of IP Migration transactions, under both the pre-2009 and the new 2009 “Platform Contribution Transaction” framework of Treasury Regulation Section 1.482-7
  • Analysis and support for arm’s length interest rates on long term loans between affiliates of various countries, using specialized databases of credit ratings
  • Valuation of trademark portfolios in the automotive industry for tax purposes. International and local tax advice related to the transfer of those trademarks across jurisdictions. Trademark registrations and related intellectual property law advice
  • Valuation of assets for a company in bankruptcy proceedings. The valuation was used by the trustee and the court to negotiate minimum prices with potential buyers and to expedite winding up the company
  • Represented a leading networking infrastructure company in its global restructuring involving nearly every European jurisdiction and including a Dutch Advanced Pricing Agreement (APA) that achieved unprecedented results
  • Valuation of several refineries and gas stations for one of the largest oil and gas companies in the world for real estate tax purposes. International and local tax advice related to the transaction
  • Represented a global health sciences company in the negotiation of the first bilateral Advanced Pricing Agreement (APA) negotiated between the US and Ireland
  • Valuation of shares required for tax purposes as a result of the reorganisation of a Japanese conglomerate
  • Tax and transfer pricing planning advice to a US multinational during the acquisition of a European target, including all related legal advice such as corporate law, civil law and labour law
  • Advice on the design, documentation and implementation of the transfer pricing policy of an international player in the renewable energy sector
  • APA for several US technology companies
  • Transfer pricing documentation for several companies in the pharmaceutical and medical equipment industries
  • Tax and transfer pricing planning advice for Russian investors starting up businesses in Europe, including VAT and legal advice
  • Tax litigation and transfer pricing expert witness support for several Fortune 500 companies in different countries. The subjects of the disputes included: intercompany pricing of loans, valuation of intangibles and commissionaire structures