Philippe G. Penelle

Philippe is a managing director in the Transfer Pricing practice, based in Los Angeles. He leverages over 20 years of extensive experience in designing, valuing and defending controlled transactions involving the transfer of intellectual property rights on behalf of multinational clients and their counsel.

Philippe’s area of expertise includes intellectual property transfer pricing strategy in connection with cost sharing arrangements, contributions to international partnerships, contributions to corporations and licensing arrangements involving specific allocations of fixed cost funding commitments. He has successfully represented clients in high profile cost sharing controversy cases involving billions of dollars of potential adjustments. His most recent work offers a measure of the income method that does not require discount rates and, thereby, eliminates discount rate controversies with the IRS, saving taxpayers significant time and costs.

Philippe was deeply involved in the base erosion and profit shifting (BEPS) work carried out by Working Party No. 6 (WP6) on Taxation of Multinational Enterprises at the Organisation for Economic Co-operation and Development (OECD). He has testified at several OECD public consultations concerning the revisions to the OECD transfer pricing guidelines. From 2016 to 2020, he was the co-chair of the United States Council for International Business (USCIB) Transfer Pricing Sub-Tax Committee.  Philippe is a regular invited speaker at international tax conferences, including the annual USCIB-OECD International Tax Conference, the National Association for Business Economics (NABE) and the University of San Diego Transfer Pricing Symposium.

Philippe is a trusted advisor to senior executives in the life sciences, technology, crypto assets, video game, entertainment and media, fashion and retail industries. He also has extensive experience in traditional industries that are capital intensive and display significant economies of scale, such as semi-conductor companies, or heavy machinery and equipment companies. His experience in that space includes due diligence and integration services in mergers and acquisitions.

Philippe holds a Ph.D. in economics from the University of Chicago and a MS (summa cum laude) in econometrics from the Université Libre de Bruxelles in Belgium. He is fluent in English and French. He is a former tenure-track assistant professor at the University of Chicago.


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