[Managing Director]
Tax Advisory Consultant
Tax Researcher
Transfer Pricing

Qualifications: JD (law), LLM, International Taxation and Financial Services; Tax Compliance and Risk Management, PhD Transfer Pricing.

Dr. Emmanuel Shola Ayeni received a B.A from the University of Houston. Thereafter, Dr. Ayeni earned three law degrees including a JSD – – the PhD equivalent in law (the most advanced law degree in the U.S.) – – from the Thomas Jefferson School of Law. In addition to his PhD in Law, Dr. Ayeni holds an LL.M in International Taxation and Financial Services; Compliance and Risk Management from the Thomas Jefferson School of Law and a J.D. from the Thurgood Marshal School of Law, Houston. He has in-depth knowledge and experience in Transfer Pricing of tangible and intangible assets. Dr. Ayeni also has knowledge in International Taxation and Financial Services; Compliance and Risk Management with an extensive, diversified and in-depth knowledge and experience in banking and financial services. He also has demonstrable knowledge in Corporate and Personal tax management; APA; ALP; Tax Treaties and PE. He has demonstrable knowledge in Tax Regimes, Arbitrage, Section 482 and Subpart F Income of Controlled Foreign Corporations. The core of Dr. Ayeni’s knowledge involves the establishment of appropriate pricing arrangements for the cross-border transfer of goods, services, and intellectual property among related parties. He is also able to help clients prepare cost allocation models, APA reports, controversy responses, and Competent Authority packages, in addition to the common annual documentation, planning reports, and provision review memos. Furthermore, as the US, OECD, and foreign tax authorities continue to adjust transfer pricing rules, he has gained significant experience in preparing BEPS Country-by-Country reports, Master Files and Local Files. Dr. Ayeni also has experience conducting in-depth functional interviews and company research to analyze clients’ business functions. His practice focus includes but not limited to real estate, food production, retail, transportation, technology industries, intellectual properties, and oil and gas industry, to name a few.
He has demonstrable ability to establish relationships with client personnel at appropriate levels, consistently deliver high quality client services, monitor progress, manage risk and ensure key stakeholders are kept informed about progress and expected outcomes. He also has the knowledge to review KYC documentation, and a strong understanding of US Patriot Act, Bank Secrecy Act and AML regulatory framework. Most importantly, Dr. Ayeni has and continue to stay abreast of current business and industry trends relevant to Tax Regime and the AML/KYC space.

Relevant experience in handling Transfer Pricing assignments range from compliance, Litigation support, benchmarking and planning for the inbound and outbound multinational companies in verticals including Manufacturing, Information Technology, Infrastructure, etc.

Benchmarking analysis: Review and analysis of benchmarking sets and customization based on specific profile of the client through quantitative and qualitative adjustments.

Planning Assignments: Transfer price determination for the proposed/existing international and domestic related party transaction/s to align with the arm’s length standard as per the existing Transfer Pricing Regulations.

Assessment/ Litigation support: Preparation of submission/application/appeal on notices/orders/directions of the Transfer Pricing Officer, Dispute Resolution Panel, Commissioner of Income Tax (Appeals) and Income Tax Appellate Tribunal.

Annual Compliance includes Form 3CEB – (Report from an accountant to be furnished under section 92E relating to. international transaction(s) and specified domestic transaction(s) – Rule 10E); Complete identification and review of international and domestic transactions with related parties through documentation examination (viz., financials, inter-company agreements, work orders, invoices, debit and credit notes etc.) relevant to the transactions, required to be reported in Form 3CEB.

Transfer Pricing Memorandum: Analysis and documentation of Functional, Asset and Risk analysis (FAR) relevant to international and domestic transactions. Devising and application of bench-marking analysis based on FAR and industry analysis relevant to the transactions.

Master File: Overview and documentation of relevant information based on global operations, inter-company transactions, transfer pricing policy and FAR within the overall framework of Multi-National Corporations, based on Indian Regulations/ OECD BEPS Action 13 of guidance report.

Country By Country Reporting: Tax jurisdiction-wise reporting in accordance with OECD BEPS Action 13 of guidance report. Compliance Analysis, bench-marking and testing of related party transactions along with recommendations.

Advance Pricing Agreement (APA): Filing and furnishing application for pre-filing and main filing and preparation of presentations/submissions for miscellaneous questionnaire/s issued and site visit during negotiations.

Global documentation: Preparation of global transfer pricing documentation consistent with the respective jurisdictional Transfer Pricing Regulations and OECD guidelines.

Relevant Sales & Used Tax Experience

Manage U.S. indirect tax compliance with an external service provider to ensure accurate and timely filing of sales & use tax returns

Maintain tax calendars of US Indirect tax, property tax, business licenses, and other ad hoc tax related payments

Monitor tax changes and legislative US tax updates

Research the Sarbanes-Oxley Act tax documentation controls

Perform research and analysis, and apply tax laws to support technical positions related to the Company’s business transactions

Facilitate and manage the preparation and review company federal tax returns and the accurate, timely filing of all tax forms.

Ensure accurate, timely filing of consolidated federal, state and local income tax returns and other business-related filings.

Implement opportunities for process improvement in company tax procedures.

Develop and implement strategic tax planning for all necessary federal and state taxes.

Work with tax team as they prepare components of the company’s US federal income tax return and other tax documents.

Plan for and develop overall return calendar and coordinate timing and inputs with tax team.

Maintain effective control procedures over all aspects of the tax process.

Manage and facilitate IRS income tax audits: preparing responses, creating schedules, etc.

Monitor legislative and regulatory tax law developments, communicate the effects of these developments to management and the tax team and create strategies on the changes to taxation legislation.

Review tax returns and quarterly/yearly tax projections.