Shirazi Moiz

Moiz Shirazi

Principal Economist
Baker & McKenzie Consulting LLC
Not admitted to practice law in this jurisdiction


Moiz Shirazi is a Principal Economist in the Palo Alto office. He focuses on transfer pricing and provides his clients with economic analyses and valuations that assist them in planning and supporting business reorganizations, as well as establishing and documenting global transfer prices. Mr. Shirazi has led economic analyses for a diverse set of clients from many different industries, including analyses on transfer pricing planning in the context of global restructuring, assistance in negotiating advance pricing agreements (APAs) with the IRS, intangible property valuation, preparing US and foreign transfer pricing documentation and transfer pricing controversy.

Practice Focus

Mr. Shirazi focuses his practice on transfer pricing and valuation matters in relation to pricing of intercompany loans, cash pooling arrangements, guarantee fees, thin capitalization, stock option valuation, credit swaps, interest rate swaps, currency swaps, and other financial instruments. He has worked with some of the largest companies in the financial services industry to establish pricing for financial instruments, shared services arrangements, global trading and investment management operations, and revenue sharing in the context of client acquisition. Mr. Shirazi has also worked with some of the largest insurance companies in pricing for reinsurance transactions and remuneration for underwriting services.

Representative Legal Matters

  • Assisted global insurance company in pricing of risk transfer associated with reinsurance and captive insurance functions and revenue sharing between network and brokerage offices around the world.
  • Led efforts to analyze and develop pricing for intercompany credit and performance guarantees as part of a global commodity trading operation.
  • Assisted Fortune 100 retailer in negotiating 2 bilateral APAs involving the United States, Canada, and Mexico, including managing all aspects of the economic and transfer pricing analyses.
  • Assisted large pharmaceutical company in establishing an intercompany pricing policy for cash pooling and intercompany lending across the group in accordance with thin capitalization and transfer pricing rules involving more than 10 jurisdictions.
  • Conducted numerous transfer pricing analyses related to intercompany sale of tangible and intangible property and intercompany services for companies in the automotive, financial services, insurance, transportation and logistics, chemical, and pharmaceutical industries.
  • Assisted Fortune 100 company in valuing over 500 entities as part of a major acquisition.

Professional Associations and Memberships

  • American Bar Association - Transfer Pricing Committee
  • International Trade Association of Greater Chicago
  • U.S. - Russia Business Council
  • U.S. - Tokyo Business Council


  • University of Chicago (M.B.A.)
  • University of Chicago (B.A. Economics)


  • English


Speaker, “Intercompany Credit & Performance Guarantees,” CITE Advanced US Transfer Pricing Seminar, August 2011

Speaker, “IP Licensing and International Transfer Pricing Issues,” CITE Advanced US Taxation of Intellectual Property Seminar, July 2011

Speaker, “Cross Border Financing,” TEI Region II Tax Forum, June 2011


Co-author, “Transfer Pricing for Intercompany Financial Transactions: Application of the Arm’s-Length Principle: In Theory and Practice,” BNA Tax Management Transfer Pricing Report, 6 May 2010

Co-author, “Transfer pricing and the CPM/TNMM in a downturn,” Planning for the Recovery, Examining Transfer Pricing in the Current Environment and Beyond, September 2009

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