Denise Guthrie

Tax Managing Director, NTO Transfer Pricing at BDO

Denise has roughly 25 years of experience as a finance and transfer pricing specialist. She has worked as a transfer pricing specialist at tax consulting firms, at the IRS, and in-house. As an in-house tax specialist at large US-based multinationals, Denise was responsible for managing a wide range of global transfer pricing planning projects and compliance obligations, with an emphasis on headquarter services allocations, financial transaction pricing and local country documentation requirements, including country-by-country reports. Denise was also responsible for global tax risk management including oversight of global audits and FIN48 reporting. She has designed numerous “big data” solutions to address operational transfer pricing needs and has contributed to the development of web-based operational transfer pricing tools. At the Advance Pricing and Mutual Agreement (APMA) program of the IRS, Denise’s work included developing and defending U.S. positions on multi-billion-dollar cases involving intangible property migration, cost-sharing arrangements, and tangible property and service transactions under both centralized and decentralized risk structures. In her roles at tax consulting firms, Denise managed all aspects of transfer pricing planning and documentation projects and developed operational transfer pricing procedures for taxpayers in a wide range of industries including industrial products, financial services, and telecommunications. Before focusing on transfer pricing, Denise was a senior financial analyst and banking officer, providing analyses for the c-suite and board of directors of a $60 billion bank, including bank-wide budgeting and performance monitoring, post-acquisition performance monitoring, and valuation analyses. At the bank, Denise designed a “big-data solution” to reduce the administrative burden of reviewing the monthly balance sheets and P&Ls for over 100 strategic business units.