Handling Global Transfer Pricing Controversy. With Randall Fox & Luis Abrantes

Randall Fox, Co-Head of Transfer Pricing, DLA Piper

Randall has a unique background that involves time in Big4, government (Internal Revenue Service) as well as an international organization (World Bank Group) all focused on transfer pricing. He has worked directly with dozens of tax administrations around the world, and assisted some of the world's largest companies with preventing and resolving transfer pricing disputes. He combines a technical background in transfer pricing with practical knowledge of transfer pricing dispute resolution in countries around the world.

Luis Abrantes, Head of Transfer Pricing, Carlsberg

Luis Abrantes has been with Carlsberg, in Copenhagen, since 2010 and is currently heading its transfer pricing team, part of the Group Tax department. Since joining Carlsberg he has been significantly involved in business reorganizations in Europe and Asia, introducing transfer pricing manuals in the Group, developing and managing pricing models for IP licensing, HQ Services and sourcing of goods, amongst others. During this period he gained significant experience in managing in-house stakeholders of inter-company transactions, focusing on operational transfer pricing and the effective implementation of pricing models. He has also worked extensively with tax authorities, in the context of training, tax audits, APAs, MAPs and tax rulings. Before joining Carlsberg Luis worked with Deloitte for 8 years as a transfer pricing adviser, both in Lisbon and Chicago. His educational background is in economics, having graduated at Instituto Superior de Economia e Gestão, in Lisbon.