Advised one of the world’s largest automotive original equipment manufacturers and its multi-advisor teams on economic analysis, regulatory requirements and negotiation strategies for a four-country Advanced Pricing Agreement involving complex royalty and functional profitability issues. This project was unprecedented in its scope and complexity, and was successfully submitted to the four tax authorities on schedule despite several unanticipated material changes in business circumstances. Lead economist in three other automotive industry bilateral APAs dealing with same royalty and functional profitability analysis issues.
