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Sirathorn B.J. Dechsakulthorn

Sirathorn B.J. Dechsakulthorn


B.J. Dechsakulthorn advises on the development of transfer pricing policies, including supply chain optimization and valuation of intangibles such as trademarks, brand, technology and other intangibles. She also has experience in managing several transfer pricing planning, audit and documentation projects. 

Her industry experience includes software, hardware, life sciences, consumer goods, automotive, light and heavy industrial goods, healthcare and financial services. In addition, she focuses on the economic and valuation issues arising in mergers and acquisitions, restructuring, venture capital and other transactions.

B.J. Dechsakulthorn is not a lawyer.

Areas of FocusTax


Key experience

  • Prepared and managed several global transfer pricing documentation reports for various industry sectors including financial services, consumer products, entertainment and manufacturing industry
  • Analyzed numerous transactions, including intangible property transfers, intercompany loans, cash pooling and various services transactions
  • Advised on cost sharing or cost contribution structure
  • Developed management fee allocation systems for clients in various industry sectors
  • Analyzed intercompany pricing and fee structures for various industry sectors including the manufacturing and the financial services industry
  • Provided analysis for operational transfer pricing for global manufacturers
  • Provided analyses of royalty rates for brand name and technology
  • Prepared transfer pricing advice regarding implementation of global brand name licensing structures
  • Valued trademarks and other pre-existing intangibles for tax/planning purposes in various industry sector
  • Advised clients in the development and implementation of solid and robust transfer pricing systems for the intercompany transfer of tangible goods
  • Performed transfer pricing due diligence analyses
  • Assisted in several FIN48 analyses in various industry sectors
  • Thai
  • Ph.D., Economics with a specialty in international money and finance, Claremont Graduate University
  • M.A., Economics, Claremont Graduate University


  • Co-author, "Treatment of Losses Under OECD Pillars 1 and 2," Tax Notes International, July 20, 2020