The importance of transfer pricing lies in its impact on multinational corporations' tax strategies and compliance. Properly established transfer pricing policies ensure arm's length profit allocation, minimize tax risks, and enhance transparency, ultimately contributing to a company's financial health reputation.
Expert Tax and Transfer Pricing Consultants
Optimize your effective tax rate
Unlock the full potential of your business with TPright's expert transfer pricing consultants. Our team specializes in providing strategic transfer pricing, tax planning and compliance services tailored to your needs. With our in-depth knowledge of tax and transfer pricing laws and regulations, we ensure that you maximize tax savings while staying fully compliant. Trust TPright to optimize your tax strategy and minimize liabilities.
Our transfer pricing advisory services offer a range of services tailored to your industry and business practices, including:
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Functional, risk, & market analyses
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Economic and benchmarking analyses
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Operational Transfer Pricing Software
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Transfer Pricing documentation, BEPS Action Item 13 (Masterfile, Local Files, and CBCR)
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Planning and implementation of transfer pricing policies consistent with the arm’s-length principle
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Arms length pricing of IC Financial transactions
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Debt capacity analyses
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Dispute resolution, including assistance with transfer pricing exams, arbitration, MAP, APA and litigation support
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Advisory and preparation of IC Agreements
About Us
For all of Your Transfer Pricing Needs
Founded by Ami Goldenstein,
With more than 22 years of experience in transfer pricing and international taxation, Ami Goldenstein has built a career at the intersection of tax strategy, operational execution, and business transformation. Over the course of his career, Ami has advised multinational enterprises on complex global transfer pricing matters, international tax planning, operational transfer pricing, and cross-border business structures across a wide range of industries, with a particular focus on the pharmaceutical and life sciences sectors.
Ami spent more than 16 years in senior in-house transfer pricing leadership roles within global pharmaceutical and IT organizations, including UST, Takeda and Teva Pharmaceutical Industries, where he supported highly complex international supply chains, intellectual property structures, IC financing arrangements, and global tax operating models. His experience combines deep technical expertise with a strong understanding of finance, systems, operations, and the practical realities multinational groups face when implementing transfer pricing policies across jurisdictions.
Prior to his in-house leadership roles, Ami began his career in public accounting with EY, Deloitte and later PwC, where he advised multinational clients on transfer pricing planning, documentation, controversy, and international tax matters. This combination of Big 4 advisory experience and extensive corporate leadership has provided him with a unique perspective on both strategic tax planning and operational implementation.
Throughout his career, Ami has collaborated closely with business leaders, finance teams, legal departments, treasury functions, supply chain organizations, and external advisors to identify and implement tax-efficient structures and operational improvements. His work has contributed to approximately $1.7 million in annual corporate income tax savings and more than $5.2 million in annual cash tax savings through the design and execution of strategic planning initiatives and operational efficiencies.
Ami has extensive experience across a broad range of transfer pricing and international tax disciplines, including:
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Operational Transfer Pricing
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Intellectual Property Valuation
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BEPS and OECD Transfer Pricing Guidance
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Transfer Pricing Policy Design
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Transfer Pricing Documentation
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Business Restructuring
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Effective Tax Rate (ETR) Optimization
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Intercompany Financing
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TP Audit Defense and Controversy Management
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Advance Pricing Agreements (APAs)
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GILTI, FDII, BEAT, ASC 740, and CFC Analysis
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Customs and Trade Compliance
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International Tax Strategy
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Financial Modeling and Scenario Analysis
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Tax Technology and Process Automation
In addition to technical tax expertise, Ami has significant experience leveraging technology and automation to modernize transfer pricing processes and improve visibility into multinational intercompany transactions. He has worked extensively with enterprise systems and analytics tools including SAP, Alteryx, and Power BI, and has a strong interest in applying AI technology and intelligent automation to operational transfer pricing and global tax management.
Among his notable achievements, Ami successfully supported a U.S./Belgian and Indian/UK Advance Pricing Agreement process, achieved a favorable settlement with the Swiss tax authorities in connection with an intercompany finance transfer pricing audit, and played a key role in the planning and implementation of a Swiss principal company structure. He has also led and supported numerous operational transfer pricing initiatives involving complex intercompany supply chains, service arrangements, and financing structures across multiple jurisdictions.
Known for his analytical mindset, practical business approach, and creative problem-solving abilities, Ami brings a balanced perspective that combines technical precision with operational feasibility. He is particularly passionate about helping multinational organizations bridge the gap between transfer pricing policy, accounting execution, tax compliance, and technology enablement.
Ami holds an Executive MBA from Ono Academic College and a Bachelor of Economics with Honors from York University.
Today, Ami continues to focus on helping multinational organizations navigate increasingly complex global tax and transfer pricing environments while driving practical, technology-enabled solutions that create transparency, efficiency, and business value.
