Gene Tien

Vice President
Gene Tien | Transfer Pricing | Charles River Associates

Gene Tien, PhD. is a vice president in Charles River Associates’ Transfer Pricing Practice.

Dr. Tien designs, values, and implements multinational intercompany pricing strategies, and advises on transfer pricing documentation, audit defense, and dispute resolution for US and non-US headquartered companies. He works with clients in a variety of industries to efficiently align and set high-value and intangible-generating transactions, while managing global tax and customs audit exposures. These industries include those in the digital economy, pharmaceuticals, medical devices, retail, oilfield / natural resource services, and the branded consumer product goods sectors.

Dr. Tien has over 25 years of experience in transfer pricing and economic valuation issues relating intangibles planning and controversy. He has participated in the successful conclusion of tax disputes, rulings, and bilateral arrangements in the US, and across Europe and Asia.

Prior to joining Charles River Associates, he was a senior economist at Baker & McKenzie where he advised law firms on transfer pricing planning and litigation matters for almost two decades after serving as an economist at PricewaterhouseCoopers in Chicago, Dallas, and Houston. While at Northwestern University, he specialized in Industrial Organization, studying technology transfer and the structure of licensing contracts.

Selected engagements

  • 01
    Assisting European multinationals with TP planning for US organic growth and M&A
    CRA’s Gene Tien assisted multiple foreign-parented companies in navigating the complexities of expanded US operations. For the past decade, the relatively...
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  • 02
    German transfer pricing audit defense and resolution for life sciences companies
    Several life sciences companies faced transfer pricing audits of their German subsidiaries, with tax authorities challenging percentage-of-revenue distribution...
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  • 03
    EMEA ruling and audit defense assistance for IP restructuring
    CRA’s Gene Tien assisted on multiple IP planning matters involving IP transactions related to life sciences, the digital economy, and financial services in...
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Credentials