Transfer Pricing Portfolios Library

The Transfer Pricing Portfolios Library provides everything necessary to develop and implement effective transfer pricing strategies for intercompany exchanges of goods and services across countries, to ensure compliance, and to manage intercompany prices to avoid penalties and double taxation.




Written by leading transfer pricing practitioners, Bloomberg BNA's Transfer Pricing Portfolios Library provides news and commentary on the highly complex and quickly evolving and specialized practice area. The Transfer Pricing Tax Management Portfolios feature in-depth analysis by renowned transfer pricing experts and include practical guidance, real-world examples, and multiple perspectives.


Benefit from analysis and perspective from leading U.S. and foreign practitioners and interviews with government officials. The Transfer Pricing Report, included in this Library, provides U.S. and Foreign government officials’ interpretations of laws they are enforcing in transfer pricing and permanent establishment areas. The Transfer Pricing Report providing bi-weekly news and developments, and instant access to relevant source documents and practice tools.

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"We have found the Bloomberg BNA Transfer Pricing Portfolios Library to be an extremely valuable resource – both for keeping up to date with important developments, as well as using the toolkit capabilities for enhanced and efficient research for clients. It represents great value for money."
- Jason Casas | Partner – Head of Transfer Pricing Services, Grant Thornton Australia


Practice Tools
  • Federal Tax Calendar, working papers, tables, charts, and lists
News & Commentary
  • Current Reports and regular Special Reports providing news and developments.
Primary Sources
  • Laws & Regulations, Agency Documents, and Cases.


  • Introductory materials on transfer pricing
  • Section 482 Regulations and Rulings
  • Transfer pricing judicial decisions, strategy, and outcomes
  • Economic, managerial, and accounting principles in transfer pricing
  • Transfer pricing records and information
  • Alternative practical strategies in transfer pricing
  • Section 6662 Transfer Pricing Penalties
  • Advance pricing agreements
  • Cost-sharing arrangements
  • Base Erosion & Profit Shifting
  • Transfer pricing rules of Australia, Belgium, Brazil, Canada, China, Denmark, France, Germany, Hong Kong, India, Italy, Japan, Korea, Luxembourg, Mexico, Netherlands, New Zealand, OECD, Spain, Sweden, Switzerland, United Kingdom, and United States.
  • OECD Transfer Pricing Rules and Guidelines


Akira Akamatsu
Local Partner (Tokyo)
White & Case LLP
Dr. Akira Akamatsu served at the National Tax Agency (NTA) National Office and the Tokyo Regional Taxation Bureau from 1975 to 1990. His last position was as a NTA International Examination Section Chief. As a zeirishi concentrating in international taxation, specifically transfer pricing taxation, taxation on permanent establishments, cross border M&A, anti-tax haven regulations (Japanese CFC regulations), foreign tax credits, and tax treaty interpretation, Dr. Akamatsu is mainly involved in consulting and managing tax examinations, tax disputes, competent authority consultations under tax treaties, and advance pricing agreements (APAs). Dr. Akamatsu has published articles in major Japanese and international tax journals and lectured both in Japan and overseas. He was honored with a special award from the Japanese Tax Institute for his book International Tax Principles and Japanese International Tax Law (Zeimu Kenkyukai, 2001). Dr. Akamatsu’s other works include Kokusai Kazeino Jitsumuto Riron–Global Economy and Tax Laws [Theory and Practice of International Taxation–Global Economy and Tax Laws] (Zeimu Kenkyukai, 2009, Second Edition). Dr. Akamatsu also co-authored Chiteki Zaisan Zeimu Senryaku [Intellectual Property Taxation Strategies] (Zeimu Keiri Kyokai, 2007).Dr. Akamatsu received his Doctor of Law at Hitotsubashi University, Tokyo.Bloomberg BNA Portfolios and publications:6960 T.M., Transfer Pricing: Rules and Practice in Selected Countries (J-L) (author)
Reuven S. Avi-Yonah
Reuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
David B. Bailey
David B. Bailey, Duke University (A.B. 1994); Georgetown University Law Center (J.D. 1999); New York University School of Law (LL.M. in Taxation, 2001); Executive Editor, The Tax Lawyer; Graduate Editor, Tax Law Review.
Tony Beare
Tony Beare is a Tax Specialist with Slaughter & May in London, England.
Nathan Boidman
Nathan Boidman, Esq., Davies Ward Phillips & Vineberg, Montreal, Canada.
Philip Carmichael
Philip Carmichael is a principal economist in Baker & McKenzie's New York office. He has advised several US-based companies on global transfer pricing including transfer pricing analysis, planning, documentation and dispute resolution. He has also coordinated and prepared documentation to serve the needs of tax authorities across different jurisdictions. In transfer pricing disputes, he has assisted in the preparation of economic analyses and responses to information requests, as well as advised on strategy. Prior to joining Baker & McKenzie, Mr. Carmichael was a principal in the economic and valuation services practice of KPMG LLP.
Patrick Cauwenbergh
Patrick Cauwenbergh is an International Tax Partner with Deloitte Belastingconsulenten and is the head of the transfer pricing and tax effective supply chain group within Deloitte. He has participated in transfer pricing assignments for Europe-based companies (including many of the largest Belgian controlled groups) regarding their relations with other EU-countries, Eastern Europe countries, the United States, Japan, etc. He obtained a Ph.D. in law on “international transfer pricing” at the University of Antwerp, where he is a Professor of International Tax Law, and obtained a Master in International and European Taxation at the Ecole Supérieure des Sciences Fiscales in Brussels. In addition, he has prior experience in the corporate tax aspects of the financial industry (hybrid financing, global trading, cash pooling, charge out of corporate fees, cost sharing, leasing transactions, etc.). He has published two monographs, authored several articles on international transfer pricing, is Guest Professor at the Universities of Gent and Leuven, and is a regular speaker at seminars on related topics.
Clark J. Chandler
Clark J. Chandler, Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Dr. Chandler is a principal with KPMG LLP's Washington national Tax/Economic Consulting Services practice. He has testified extensively and worked for both tax authorities and multinational corporations in the area of international transfer pricing.
Jenny Cottrell
Jenny Cottrell is with Stephenson Harwood in London, England.
Robert E. Culbertson
Robert E. Culbertson, Yale University (B.A. 1979), Harvard University (J.D. 1982).
Nicasio J. del Castillo
Nicasio del Castillo, Universidad del Uruguay; Harvard Law School (International Tax Program, 1970); member, AICPA Subcommittee on International Taxation and International Fiscal Association.
William G. Dodge
William G. Dodge, University of Georgia, Master of Accountancy (Tax) (1979); Walsh College, B.A. (1976); Director, Global Transfer Pricing Team; Co–Director, U.S. Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly Partner–in–Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Member, Tax Management Advisory Board (Transfer Pricing). Mr. Dodge is a regular speaker at seminars and has worked in New York, London, and Tokyo where he served many of Deloitte & Touche's largest U.S. and non–U.S. clients.
Michael C. Durst
Michael C. Durst, Williams College (B.A. 1975), M.I.T. (M.S. (Econ.) 1978), U.Cal. Berkeley (J.D. 1981), Harvard University (LL.M. 1985).
Graham Earles
Graham Earles is a Tax Specialist with Slaughter & May in London, England.
Stephen M. Edge
Stephen M. Edge is a corporate tax partner at Slaughter & May, where he has an extensive tax consultancy practice that includes advising business and transaction structuring, dealing with in-depth tax investigations and tax litigation, and working in the transfer pricing/thin capitalisation area.
Christian Emmeluth
Christian Emmeluth obtained an L.L.B.M. from Copenhagen University in 1977 and became a member of the Danish Bar Association in 1980. During 1980-81, he studied at the New York University Institute of Comparative Law and obtained the degree of Master of Comparative Jurisprudence. Mr. Emmeluth was a partner in the law firm of Koch-Nielsen & Gronborg based four years in London but is now based in Copenhagen.
David Garcia Fabregat
Bruno Gouthiere
Bruno Gouthiere, Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris; partner with CMS Bureau Francis Lefebvre, international tax department, since 1989; previously, he was acting as Chief of Staff, International Tax Relations, Tax Policy Department, Ministry of Finance; author of reference books in international tax law, such as “Les Impôts dans les affaires internationales”, "Les Holdings", "Transfer Pricing Rules and Practice in France" (Tax Management, BNA), "Advance Rulings in France" (IBFD), "The International Guide to Holding Companies" (IBFD), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), and of numerous articles in French and foreign legal, tax and financial reviews;  member of various associations of tax practitioners such as the International Fiscal Association (“IFA”) and the Fiscal Committee of the European Fiscal Confederation (“CFE”).
Karl L. Kellar
Woo Taik Kim
Woo Taik Kim, Seoul National University (B.A., 1970); Columbia University (M.B.A., 1972); tax partner, Kim & Chang, Seoul; Member, Korean Institute of Tax Attorneys, Korean Institute of Certified Public Accountants, New York State Society of Certified Public Accountants, International Fiscal Association.
Kenneth J. Krupsky
Kenneth J. Krupsky, Tax Partner, Jones Day (Washington, DC); Columbia Law School (J.D. 1972; Harlan Fiske Stone Scholar; International Fellow; Columbia Law Review; Comments and Case Notes Editor, Columbia Journal of Transnational Law); Columbia College (B.A. in Philosophy 1969; National Merit Scholar). Served as Deputy Assistant Secretary of the Treasury for Tax Policy, U.S. Treasury Department in President Clinton's second term, Chair of the International Tax Committee of the District of Columbia Bar Association, and Adjunct Professor at Georgetown University Law Center. Member of Tax Management International Journal's "Panel of Leading Practitioners" and regularly contributes to that journal.  Other publications include:  Joint Ventures with International Partners (coauthor, Butterworth 1994); and International Joint Ventures coauthor, Federal Publications 1986; 2d ed. 1988).  Regularly listed as a leading tax lawyer in Chambers USA, Euromoney's International Tax Review (one of the "world's leading tax advisers" and "world's leading transfer pricing advisers"), and Super Lawyers.
Marc M. Levey
Zion Levi
Harrison B. McCawley
Harrison B. McCawley, A.B., Princeton University (1948); LL.B., Harvard Law School (1951); Attorney, Tax Division, Department of Justice (1955–60); Staff Attorney, Joint Committee on Taxation (1960–72); Refund Counsel, Joint Committee on Taxation (1972–80).
Jerrie V. Mirga
Jerrie Varrone Mirga, College of William & Mary, B.A. (1979); George Washington University, MBA (1985) and post-MBA Certificate (2001); Vice President, Economic Consulting Services, LLC. Ms. Mirga advises clients on transfer pricing issues involving tangible and intangible property for planning, documentation and audit purposes.
Michael F. Patton
Michael F. Patton;  University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation); was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper; was a member of the Treasury/IRS study group to revise the competent authority function;  worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention; was the lead U.S. Treasury negotiator in many negotiations with foreign governments for tax information exchange agreements under the Caribbean Basin Initiative; named one of the Best of the Best U.S. transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euromoney and the International Tax Review; has been named as a “Highly Recommended” tax advisor by the International Tax Review; member, Editorial Advisory Board of Tax Management, Inc; contributor to the Tax Management International Tax Journal, the Transfer Pricing Reporter, and other publications; is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department.
Horacio Pena
Irving H. Plotkin
Irving H. Plotkin, Wharton School, University of Pennsylvania, B.S.; Massachusetts Institute of Technology, Ph.D. in mathematical economics. Dr. Plotkin is Managing Director of the Boston Tax practice of Pricewaterhouse Coopers; for many years previous, he was Vice-President for Forensic Economics at Arthur D. Little, Inc. Dr. Plotkin has designed and conducted research studies on various topics including the effects of government regulation, self-regulation, industry efficiency and risk taking. Dr. Plotkin lectures frequently on economic and regulatory issues, and based on his research work, has presented expert testimony in the Tax Claims, U.S. District, and State Courts on behalf of taxpayers and the IRS in a number of high-profile tax disputes (including Du Pont, UPS, DHL, ACM, Bausch and Lomb, The Limited, Dow, and the captive cases) and has testified before U.S. congressional committees and federal and state commissions.
Bob Ramage
Bob Ramage is a Tax Specialist with Slaughter & May in London, England.
George H. Soba
George H. Soba, Esq., New York University School of Law, LL.M. (Taxation) (1982); University of Toledo College of Law, J.D. (cum laude) (1981); Franklin and Marshall College, B.A. (1978); formerly IRS Tax Counsel, Brooklyn District Counsel Office and Senior Attorney–Advisor in the Office of Associate Chief Counsel (International).
Manuel F. Solano
Manuel F. Solano, Universidad Autonoma de Centro America, Costa Rica; Youngstown State University (B.S., 1986); Georgetown University Law Center (J.D., 1989); member, American Bar Association; member, New York State Bar.
Gary M. Thomas
Gary M. Thomas, B.A., University of Washington, 1973; J.D., Harvard Law School, 1977; Asia University, Masters of Japanese Law/Taxation (1989) and Masters of Japanese Accounting (1994); Partner, White & Case LLP, Tokyo, Japan; admitted in Japan as licensed tax attorney (zeirishi); member of Tokyo Zeirishi Association, California State Bar Association, and Dai-ni Tokyo Bar Association; speaker on Japanese international tax issues; author, articles on Japanese taxation in the United States, Japan and Europe.
Monique van Herksen
Bart Van Honsté
Bart Van Honsté is a manager for the Brussels transfer pricing group of Deloitte & Touche where he works on transfer pricing issues, including those related to reorganizations, permanent establishments, and e-commerce. He has been involved in several arbitration procedures under the E.U. Arbitration Convention. Mr. Van Honsté obtained a degree in Economic Sciences at the University of Leuven (1993), a degree in Law at the University of Antwerp (1997), and a Master in Taxation at the University of Brussels (Solvay). He is a regular speaker at transfer pricing seminars and is the author of several publications with respect to transfer pricing in international and Belgian tax journals.
John P. Warner
John P. Warner, B.A., George Washington University (1971); J.D., University of California, Berkeley (Boalt Hall) School of Law (1977); Member, American Bar Association Section of Taxation; Chair, American Bar Association Section of Taxation Transfer Pricing Committee (2008-2010); Admitted to practice, United States Tax Court, United States Court of Federal Claims, United States Supreme Court; Reported Cases: Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988); Author: "Squaring the Transfer Pricing Circle," 33 Tax Mgmt. Intl. J. 3 (2004), "Control, Causality and Section 482," 28 Tax Mgmt. Intl. J. 403 (1999), .
Steven C. Wrappe
Steven C. Wrappe, Esq., New York University School of Law, LL.M. (Taxation) (1988); University of Texas School of Law, J.D. (1985); University of Notre Dame, Bachelor of Business Administration (1980). Member, State Bar of Texas; Certified Public Accountant. Partner, National Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly, IRS APA Program attorney. Internationally–recognized speaker on the resolution of transfer pricing disputes, with speeches before the Tax Executives Institute, American Bar Association, and Federal Bar Association. Adjunct faculty member at George Mason University Law School, teaching International Tax, and guest lecturer in the LL.M. Program at New York University School of Law.
Dong Jun Yeo
Dong Jun Yeo, Tax Attorney, Kim & Chang; Seoul National University, College of Social Science, International Economics (B.A., 1980); University of Illinois, Urbana-Champaign (M.A. in Accounting, 1987); Employment, Tax practice in Korea (1981-1985), tax practice, New York (1987-1992); Member, Korean Institute of Certified Public Accountants, American Institute of Certified Public Accountants. Languages: Korean and English.


Formats and Frequency

Available in print and on the web. Contents vary by format. The Portfolios are updated regularly. The Transfer Pricing Report is issued bi-weekly. The International Journal is updated monthly. Insights & Commentary (International) is produced regularly.
Email summaries, providing the highlights and table of contents for each Report, with URLs to full text articles and documents, are also available.