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15 - 17 June 2021
Virtual ConferenceBST/UTC+1 Time Zone

Ednaldo Silva
Founder & Director at ROYALTYSTAT


Ednaldo Silva holds a Ph.D. in Economics from the University of California-Berkeley. Dr. Silva taught post-graduate economics at the Graduate Faculty of the New School in New York for over eight years, and became Senior Economic Adviser at the IRS Office of Chief Counsel. He helped draft the US transfer pricing regulations and developed the comparable profits method (CPM) called TNNM by the OECD. Dr. Silva introduced the “best method” rule and the principle of arm’s length as a range of results and not a point estimate. Dr. Silva held positions of Senior Tax Economist at Shearman & Sterling and Wyeth Pharmaceuticals. He founded and is Managing Director of RoyaltyStat, a first-to-market database of royalty rates extracted from license agreements. Dr. Silva was principal economic expert for the IRS on the Glaxo litigation that settled for $3.4 billion. He writes about transfer pricing on his blog:

Agenda Sessions

  • BREAKFAST BRIEFING - Royalty Rates: Lessons from Coca-Cola