Eric Torrey

Eric Torrey

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


Eric Torrey is a Principal Economist in the Washington, DC office with over twenty years' experience advising multinationals on transfer pricing and ancillary matters. He represents US and foreign multinationals, primarily on transfer pricing disputes and supply chain or business restructurings. Eric is a regular author and speaker on transfer pricing topics.

Eric is a member of the transfer pricing steering committee at the USCIB (the US affiliate of the Business and Industry Advisory Committee to the OECD). He is also on the Firm's global transfer pricing steering committee. Eric is co-chair of the Firm's North America affinity group for Hispanic / Latino employees and a member of the Washington, DC Inclusion and Diversity committee.

Practice Focus

Eric's practice primarily focuses on the resolution of transfer pricing disputes and tax planning of intercompany transactions. In his dispute resolution work he advises clients defending their transfer pricing in US or foreign audits, IRS appeals, and litigation. In particular, Eric has significant experience negotiating and facilitating advance pricing agreements (APAs) and Mutual Agreement Procedures (MAPs) for US and foreign multinationals. His tax planning work involves helping multinationals structure intercompany transactions in connection with reengineered supply chains, post-acquisition integrations, and other business restructurings. He also advises on certain transfer pricing documentation, primarily for companies with significant intellectual property. Eric routinely works with companies in industries such as industrial manufacturing; technology; automotive; telecommunications; pharma, medical devices, healthcare and life sciences; transportation and logistics; media and entertainment, and; retail and branded products.

Representative Legal Matters

  • Directed APA submissions and facilitated negotiations between the US and various treaty partners including Switzerland, China, India, Germany, Canada, and Mexico, primarily for the licensing or transfer of intellectual property.
  • Led project involving the restructuring of the research, development, ownership, and licensing of critical manufacturing technology for US-based multinational.
  • Led the economic analysis and valuation efforts central to a tax dispute of a major US media company's restructuring of its operations in EMEA. A USD 1.4 billion proposed income adjustment was successfully resolved at appeals for 2% of the proposed adjustment.
  • Assisted a US multinational in examining and quantifying the tax risk associated with the potential global restructuring of the management, performance, strategy and funding of their core intellectual property.
  • Advised a major US pharmaceutical, medical device, and consumer goods company in the overhaul of their US transfer pricing documentation.

Professional Associations and Memberships

  • National Association for Business Economics (NABE)
  • United States Council for International Business (USCIB)


  • Vanderbilt University (BS)
  • Georgetown University (MBA)


  • English
  • Spanish

Previous Offices

  • Mexico City
  • Speaker, "Measurement of Transfer Pricing Risk Under ASC 740," NABE Transfer Pricing Symposium, Washington DC, 2023
  • Co-Author, "The Global Landscape of Transfer Pricing Controversy: Trends You Can’t Afford to Ignore," 51 Tax Management International Journal. No. 12 (Dec. 2, 2022)
  • Contributing Author, "United States Branch Report: Big Data And Tax - Domestic And International Taxation Of Data-Driven Business," International Fiscal Association, 2022 Berlin Congress
  • Speaker, "Digitalization of the Economy," Baker McKenzie Tax Leader Workshop, Palm Beach 2019
  • Co-Author, "APMA's New Model Signals Move Toward Profit Splits," Baker McKenzie Tax News and Developments, March 6, 2019
  • Speaker, "U.S. vs. OECD Perspectives on the Final BEPS Transfer Pricing Report," Hong Kong, 2018