Sriranjani Nagarajan focuses on economic analysis, valuation and research to help clients plan and execute transfer pricing strategies and solutions. She has been a member of Baker McKenzie's economics consulting practice since 2003 and also has significant experience in developing pricing and profitability benchmarks for intercompany transactions involving tangible goods, intangible property and services. A particular focus of her practice has been the structuring of intercompany transactions involving cost sharing and valuation of intangible property.
Sri has spoken at programs organized by various institutions such as Tax Executives Institute, the Alliance for Tax, Legal & Accounting Seminars, Council for International Tax Education and Bloomberg BNA. She has also developed and conducted several introductory and advanced training programs on transfer pricing.
Representative Legal Matters
- Transfer pricing planning, valuation and documentation for multinational clients focused on licensing, cost-sharing and/or intangible property migration.
- Economic analyses for audits, appeals and litigation defense of cost sharing buy-ins and intangible property licenses.
- Implementation of pricing policies for inbound and outbound intercompany services and preparation of documentation.
- Preparation of global transfer pricing documentation for different functions in the supply chain, involving a team of transfer pricing practitioners from US and various foreign jurisdictions.
- Economic analyses to facilitate negotiation of advance pricing agreements with US and foreign tax authorities.
- Evaluation of IRS and independent experts' transfer pricing reports, valuation analyses, and economic studies in a controversy context.
- Advice regarding US and non-US transfer pricing exposures based on detailed review and analysis of facts and financial data, and modeling different scenarios of assumptions and outcomes for various transactions.
Professional Associations and Memberships
- Mensa - Member
- University of Southern California (2003)
- Symbiosis Institute (1998)
- University of Madras (India) (1996)