Nilanjan Nag

Transfer pricing director n.nag@taxcube.lt

Professional background

• Lead Transfer Pricing Manager | iVC Consulting, Vilnius (2024)
• Transfer Pricing Lead | PKF Finconta (part of PKF Global), Bucharest (2018–2024)
• Transfer Pricing Assistant Manager/ Deputy Manager/ Manager | Deloitte India (2011–2018)
• Transfer Pricing Manager | PwC Malaysia (2016)
• Transfer Pricing Associate | PwC India (2007–2009)

Experience and practice area

Nilanjan Nag has over 18 years of extensive professional experience in Transfer Pricing compliance, planning engagements and litigation, spanning industries such as finance, retail, manufacturing, and services. With a career across four countries—India, Malaysia, Romania, and Lithuania—he has cultivated a diverse skill set and a deep understanding of international regulatory environments.

Key competencies

• Transfer Pricing documentation and planning.
• Litigation and audit support.
• Strategic advisory.
• DAC6 compliance.

Key projects and contributions

Value chain analysis and formulation of remuneration model for global chocolate brand

• Formulated and defended a sophisticated remuneration model, highlighting the nuanced interplay of intangibles, R&D contributions, and supply chain efficiencies within the group’s operational framework.
• Conducted a comprehensive value chain analysis (VCA), mapping significant people functions, decision-making centers, and the exploitation of unique intangibles to justify the profit allocation mechanisms under the arm’s length principle.

Development of co-entrepreneurship model for European supermarket chain

• Designed and implemented a comprehensive co-entrepreneurship framework to align the client’s intercompany arrangements with its global business objectives, ensuring compliance with the arm’s length principle.
• Analyzed the value contributions of multiple entities across jurisdictions, factoring in shared entrepreneurial risks, significant decision-making functions and contributions to the development of intangibles.
• Established mechanisms for allocating profits and losses based on a detailed evaluation of economic substance, addressing BEPS concerns and ensuring defensibility in tax audits.

Implementation of TP methodology for global beverage corporation

• Designed and implemented a multi-layered transfer pricing methodology selection process.
• Collaborated with cross-border teams to harmonize intercompany pricing policies.

Audit defense for multinational in paper and packaging Industry

• Engineered a sophisticated defense, identifying and addressing key conceptual and methodological flaws in the tax authorities’ approach.
• Developed an integrated audit response framework, incorporating sensitivity analyses, scenario planning, and real-time economic adjustments to pre-emptively counteract aggressive tax authority assertions.
• Led a multi-phase resolution process, including high-stakes negotiations, the preparation of comprehensive legal submissions, and the facilitation of expert roundtables, achieving substantial reductions in tax liabilities and penalties.

Thought leadership and contributions

• Delivered presentations as a speaker at seminars and conferences on transfer pricing, sharing insights on industry trends and regulatory updates.
• Authored numerous articles and publications addressing contemporary transfer pricing issues, contributing to thought leadership in the field.