Transfer Pricing Litigation Around the World

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Transfer pricing may be the largest tax controversy area around the world.  While most cases are settled outside of Court, more cases have been appearing in Court in recent times.

Since 2009, Dr. Brian Becker has likely testified in eight transfer pricing trials and submitted expert reports in six others that settled before trial. This webinar will use experience in different courtroom venues around the world to contrast the types of economic analyses seen in litigation with those typically provided as contemporary documentation.  The distinctions can be instructive and allow the audience members to self-question the heavy weight on boiler plate language over regulations, detailed facts, and detailed comparable search and the light weight on bargaining power, the hypothetical transaction being valued, objective/supporting benchmarks, etc.

The ultimate value is that litigation allows the audience to see the effects of when “the rubber meets the road.”  Economists cannot simply negotiate around their positions or create a new position, but must support their conclusion with facts, data, and theory.

Educational Objectives:
• Understanding the differences between the negotiation environment in discussions with tax authorities and the Courtroom environment during transfer pricing litigation
• The need for transfer pricing analyses to focus on facts that influence pricing, figures, and economic/statistical analysis
• The need to fully define and describe the hypothetical arm’s length transaction being priced

Who would benefit most from attending this program? 
Corporate transfer pricing professionals, corporate tax counsel, tax attorneys at law firms, tax litigation attorneys.



Dr. Brian C. Becker has served as an economic expert witness and consultant for 22 years after earning a Ph.D. in Applied Economics from The Wharton School of the University of Pennsylvania, and a B.A. in Applied Mathematics and Economics from The Johns Hopkins University. Dr. Becker has produced more than 500 economic expert reports for Fortune 500 corporations, international law firms, the Internal Revenue Service, the Department of Justice, the Australian Taxation Office and the Canada Revenue Agency. Dr. Becker has provided testimony in a number of legal venues around the world, including U.S. Tax Court, The U.S. Supreme Court, The Australian Administrative Appeals Tribunal, The Federal Court of Australia, The Tax Court of Canada, The Canadian International Trade Tribunal, and The U.S. International Trade Commission. In addition to this expert witness experience, Dr. Becker has published more than two dozen papers/book chapters in the areas of transfer pricing, intellectual property, commercial damages, international trade, and valuation. He has also taught Corporate Finance, Statistics, Derivative Securities, and other courses as a Visiting Professor in the MBA programs of four universities.