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Cristiane Drumond

Senior Associate
Cristiane is a tax lawyer specialized in cross-border transactions, with 17 years of experience with transfer pricing under the OECD Guidelines and 6 years under the Brazilian regulations. Because of her dual-qualification, Cristiane is able to look at both (or more) ends of the intercompany transactions, helping clients optimize their tax planning.


Cristiane assisted the United States IRS expert witness in the largest transfer pricing case to date.
As a manager of a Big4 firm, she won the bid for the firm’s largest transfer pricing project in the capital markets to date, conducting the benchmark studies for entities located in the Americas, Europe and Asia Pacific.
  • Portuguese
  • English
  • -Federal University of Minas Gerais (UFMG), LL.M candidate in Taxation, expected conclusion in 2023.

    -University of Florida, LL.M, 2010, with honors.

    -UFMG, J.D., 2007.


Book Award in the topic “Taxation of Intangibles” with the Paper on “U.S. Cost-Sharing Regulations”. University of Florida, Fall 2010.

Latest Insights:

  • Author of “International Taxation of Intangibles in Brazil”. In: Intangibles in the World of Transfer Pricing. 1ed. New York: Springer International Publishing, 2020, v. 1, p. 86-105.
  • Co-author of “Preços de Transferência de Serviços”. In: Manual de Preço de Transferência. Beps, Brasil e OCDE. 1ed.São Paulo: Quartier Latin, 2018, v. 1, p. 93-126.
  • Speaker at ITR Brazil Tax Forum 2022’s panels:
    - “New Brazilian Transfer Pricing Regime under the OECD Guidelines”; and
    - “Taxation of the digital economy - the implementation of BEPS Pillar 1 and 2.”

  • Speaker at ITR Brazil Tax Forum 2021’s panel - “The Future of Transfer Pricing.”


Cristiane’s previous experience include 12 years working at a consulting boutique based in Washington, DC, specialized in Transfer Pricing and Valuation of Intangibles; and 3 years as a transfer pricing manager at a Big4 firm in São Paulo.

Related Information:

  • Quoted in "TP directors fear Brazil-OECD alignment delays after Lula win," International Tax Review, November 3, 2022.
  • Quoted in "Brazil Tax Forum: Concern mounts over comparables and intangibles in TP reform, International Tax Review, September 1, 2022.
  • Quoted in "Brazil's tax authority unveils game-changing TP plan," International Tax Review, June 30, 2022.
  • Quoted in “Higher compliance costs and more disputes expected under Brazil’s TP reform,” April 21, 2022.
  • Quoted in “Brazil’s move to adopt OECD TP guidelines could boost FDI,” September 23, 2021.