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Forum Overview

The Steering Committee welcomes up to 40 senior tax lawyers and corporate tax directors who have been personally selected from around the world to participate in discussions focused on the complex landscape of transfer pricing law. This Forum provides an opportunity to explore common concerns, exchange ideas and resolve challenges faced.

 

Using candid, seminar-style discussion, the group shares experiences from their varied jurisdictions and engages in meaningful dialogue on the most pressing issues of the day.

2025 Steering Committee

This elite group, comprised of experts in the field, personally nominates all invitees and develops the Agenda, which forms the basis of our discussions.

Committee Co-Chairs

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Denise Guthrie
BDO

Denise has 23 years of experience, including as an IRS economist, consultant, in-house transfer pricing specialist, and a corporate finance/FP&A specialist. At Carrier Corporation, Denise is responsible for global tax risk management including monitoring the company's portfolio of tax audits/controversies and FIN48 tax reserves. In addition, Denise designed a model using "best-in-class" automation software for recharging Carrier Corporation's global WHQ services and executes these recharges to over 700 profit centers globally. Denise is also the lead TP specialist for financial transactions and valuations. Previously, Denise was responsible for global compliance with the OECD's CBCR and MF filing requirements. As a senior economist in the IRS's APMA program, she evaluated multi-billion dollar applications for advanced pricing agreements ("APAs") and negotiated agreements with foreign tax authorities on these and other double tax cases. 

 

Denise has an MA in economics and a penchant for mathematical techniques that save time and create clarity. At M&T Bank, Denise designed a piece-wise polynomial formula that filtered balance sheet and P&L "variances to plan" in the ERP system for over 130 profit centers, reducing the monthly review effort from 400 hours to 8 hours. As a transfer pricing consultant, Denise designed an original metric using prime numbers that quantified the relative technical complexity of every mobile phone sold into the China market by all sellers over a 10 year period.

Denise has 23 years of experience, including as an IRS economist, consultant, in-house transfer pricing specialist, and a corporate finance/FP&A specialist. At Carrier Corporation, Denise is responsible for global tax risk management including monitoring the company's portfolio of tax audits/controversies and FIN48 tax reserves. In addition, Denise designed a model using "best-in-class" automation software for recharging Carrier Corporation's global WHQ services and executes these recharges to over 700 profit centers globally. Denise is also the lead TP specialist for financial transactions and valuations. Previously, Denise was responsible for global compliance with the OECD's CBCR and MF filing requirements. As a senior economist in the IRS's APMA program, she evaluated multi-billion dollar applications for advanced pricing agreements ("APAs") and negotiated agreements with foreign tax authorities on these and other double tax cases. 

 

Denise has an MA in economics and a penchant for mathematical techniques that save time and create clarity. At M&T Bank, Denise designed a piece-wise polynomial formula that filtered balance sheet and P&L "variances to plan" in the ERP system for over 130 profit centers, reducing the monthly review effort from 400 hours to 8 hours. As a transfer pricing consultant, Denise designed an original metric using prime numbers that quantified the relative technical complexity of every mobile phone sold into the China market by all sellers over a 10 year period.

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Himanshu S. Sinha
Trilegal
Himanshu Sinha leads the tax practice at Trilegal, one of India’s largest and leading full-service law firms. Himanshu has more than 20 years of experience in advising diverse range of clients on tax issues. His specialization is in the field of direct taxes – both on the advisory and controversy sides.

Himanshu Sinha leads the tax practice at Trilegal, one of India’s largest and leading full-service law firms. Himanshu has more than 20 years of experience in advising diverse range of clients on tax issues. His specialization is in the field of direct taxes – both on the advisory and controversy sides.

Committee Members

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Fernando Colucci
Machado Meyer
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David M. Farhat Jr.
Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates
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Mariana Gouveia de Oliveira
Abreu Advogados
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Joan Hortalà
Cuatrecasas Legal, S.L.P.
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Dr. Emmanuel Llinares
Senior Managing Director NERA

Senior Managing Director

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Aurelio Massimiano
Maisto e Associati
Aurelio Massimiano was admitted to the Association of Chartered Accountants in 2002. He obtained an LL.M. Degree in International Tax Law at the University of Leiden, The Netherlands. He joined Maisto e Associati in 2005 after having worked with the International Tax Office of the Italian Revenue Agency. He has become partner since 2014.

Aurelio Massimiano was admitted to the Association of Chartered Accountants in 2002. He obtained an LL.M. Degree in International Tax Law at the University of Leiden, The Netherlands. He joined Maisto e Associati in 2005 after having worked with the International Tax Office of the Italian Revenue Agency. He has become partner since 2014.

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Lauren Ann Ross
Covington & Burling LLP
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Richard L. Slowinski
Alston & Bird LLP

CONNECT. ENGAGE. EXCEL. This is a different event, unlike any you've attended

Built on meaningful interactions and genuine connections, the Forum is the premiere gathering for preeminent leaders in international transfer pricing law.

SPONSORING THIS FORUM

The Steering Committee would like to thank the following sponsor for their continued support of the International Cambridge Forum on Transfer Pricing Law. 
Please click the logo below to learn more about our Sponsor.

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For more information please contact:
Dr. Emmanuel Llinares

Senior Managing Director

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Thank you to our Sponsor

We are pleased to announce that NERA will once again be hosting participants for a Networking Reception and Dinner on Monday, September 29, 2025. We would like to thank NERA for their continued support of the International Cambridge Forum on Transfer Pricing Law.

About NERA 

Since 1961, NERA has provided unparalleled guidance on the most important market, legal, and regulatory questions of the day. Our work has shaped industries and policy around the world. Our field-leading experts and deep experience allow us to provide rigorous analysis, reliable expert testimony, and data-powered policy recommendations for the world’s leading law firms and corporations as well as regulators and governments. Our experience, integrity, and economic ingenuity mean you can depend on us in the face of your biggest economic and financial challenges. 


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Transfer Pricing Insights

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Monica Churchill

Forum Director