• Designed the transfer pricing set-up for North Americas and filed a unilateral APA in the U.S. for a fast-moving consumer goods multinational group.
  • Analysed multiple management services from a transfer pricing point of view for a US-based multinational pharmaceutical corporation, implemented a shared service allocation model to charge out respective costs to the group entities, and documentation of the new transfer pricing model.
  • Re-assessed the profit allocation to permanent establishments within 27 different jurisdictions on a two-year project including tax return corrections according to Sec. 153 AO (German Fiscal Code) for a German based construction group company. Implemented guidelines for the client to identify permanent establishments.
  • Agreement Procedures (MAP)/EU Arbitration to avoid double taxations and to resolve transfer pricing disputes; and worked and completed Advance Pricing Agreement (APA) for a multinational automotive supplier.
  • Led complex Value Chain Analysis/Value Chain Transformation projects for a leading retail client; coordinated the projects; acted as client contact and mediated the needs to the team and project partners.
  • Analysed current operational business models and provided recommendations for improvements; designed, implemented new transfer pricing models. Filed corrected tax returns and declarations to be in-line with Sec. 153 AO. Monitored new models under the new structure; developed transfer pricing guidelines.