Our work in transfer pricing matters has covered all stages of disputes, including discovery, expert report filings, depositions, and trial. We have worked on disputes involving transfer pricing–related transactions such as platform contributions, licensing, and cost-sharing agreements. Our experience involves taxpayers operating in the technology sector (such as online platforms), computer software and hardware, consumer packaged goods, medical devices, and the pharmaceutical industry.

Marketing Intangibles

Cornerstone Research has worked with experts to analyze taxpayer marketing intangibles, including:

  • Determining the nature of marketing intangibles of a taxpayer, such as brand, distribution networks, customer (or user) lists and relationships, and marketing know-how.
  • Analyzing the way in which marketing intangibles are built and supported at firms, including which geographical entities build and support these assets.
  • Analyzing the value and longevity of marketing intangibles.
  • Determining the mechanisms through which marketing intangibles affect firm performance.
  • Assessing how marketing intangibles interact with other firm assets to affect firm performance.
Technology Intangibles

Cornerstone Research has worked with experts to analyze economic issues associated with technology intangibles, including:

  • Explaining how firms build and maintain technology, including IP and trade secrets, and the extent to which such assets arise from cumulative versus shorter-term efforts.
  • Assessing the longevity of different kinds of technology assets, including software and hardware technology.
  • Analyzing how technology assets interact with other assets at a company, and how they are affected by specific company dynamics, such as at platform companies.
  • Evaluating how much intangible technology assets contribute to a firm’s profitability.
  • Evaluating the relative contributions of intangibles and manufacturing, marketing, or distribution capabilities.

We have experience valuing businesses or components of businesses in the context of transfer pricing. This includes performing assessments of the appropriate valuation methodologies for businesses at different stages of development. Our staff and experts have particular expertise in:

  • Analyzing valuation issues in early-stage, high-growth technology firms, including ones that are privately traded.
  • Assessing the contributions of different entities to a company’s global value chain.
  • Assessing the effect of company dynamics on valuations, such as the dynamics of network effects at platform companies.
Industry Analysis

Our broad range of experts can provide an overview of the dynamics in an industry and explain typical practices of companies. Our experts have worked in a variety of sectors, including as:

  • Pharmaceutical executives
  • Hardware technology company leaders
  • Top finance managers
  • Technical experts