She advises clients regarding the market/arm’s-length nature of their transfer pricing structure related to cross-border transfers of tangible goods, intellectual property (technology or marketing intangible assets developed, such as proprietary software/hardware/processes, trademarks, trade names, brand names), administrative and other services, and intercompany financing.
Marina provides transfer pricing documentation for tax compliance purposes, transfer pricing planning analyses for start-ups or restructuring or globalization of operations, transfer pricing analyses to support corporations’ world-wide tax minimization strategies and analyses to support negotiations with multiple tax authorities for advance pricing agreements and tax controversy/audit defense situations. She advises multinational corporations and their worldwide affiliates in navigating and complying with the vast array of transfer pricing guidelines and methods applicable in different countries, as well as OECD guidelines.
Her experience advising a diverse client base operating in multiple industries and countries, including consumer electronics, entertainment (music and motion picture production), software development, information services, financial services, e-commerce, retail pharmacy, transportation, and pharmaceutical firms, among others.
