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
    Economic analysis of international hub and advanced pricing agreement negotiation
    The uptick in global tax disputes necessitated a rethinking of the company’s transfer pricing strategy to manage HQ double taxation. CRA performed a...
    View engagement
  • 02
    Global transfer pricing design supports technology startup growth
    Our team worked with numerous local law firms to design and price commercially-rational and tax-efficient intercompany transactions to facilitate their startup...
    View engagement
  • 03
    Transfer pricing support for pharmaceutical IP royalties under CWI considerations
    Recent changes to drug pricing regulations and positions taken by the IRS relating to CWI necessitated deeper analyses of their existing transfer prices. Gene...
    View engagement

Credentials