Avinash Tukrel

Avinash S. Tukrel (Avi)

Avinash S. Tukrel (Avi) has over 14 years of international transfer pricing experience gathered in Canada, the United Kingdom (UK), Malaysia, Australia and India. He has led numerous transfer pricing planning, compliance, operationalization and controversy management engagements. Avi has had clients in the pharmaceuticals and life sciences, technology, content and media, consumer and industrial products, oil and gas (O&G) as well as diversified services sectors. After obtaining his University degree and prior to having a career in transfer pricing, he worked in investment banking and equity research support roles.

Avi’s transfer pricing experience covers all aspects of the transfer pricing lifecycle, including:
  • Transfer Pricing Planning: set up inter-company pricing models and policies that enable a holistic alignment of the value chain to the operational and tax aspects of a business;
  • Transfer Pricing Compliance: preparation of transfer pricing documentation in accordance with country specific regulations, the OECD’s BEPS Action 13 Global File and Local Files as well as Country-by-Country Reporting (CbCR) for a number of Canadian, US, UK, Malaysian and Indian head-quartered corporations and their global subsidiaries;
  • Operational Transfer Pricing: review transfer pricing outcomes in context of policies including year-end position(s), statutory and book to tax adjustments, inter-company agreements and integration of financial systems; and
  • Controversy management: strategize responses to local country transfer pricing audits including Competent Authority support and Mutual Agreement Procedures (MAP) and where appropriate proactively engage with tax authorities on the use of Advance Pricing Arrangements (APA’s).
He has worked with clients on a wide range of inter-company transactions involving purchase and sale of goods and services, employee secondments, intangible property licensing and transfers, and financing, among others.