Daniela Ielceanu

Director, PricewaterhouseCoopers LLP

MST Course:

BUS 225U - Fundamentals of Transfer Pricing


Daniela Ielceanu is a transfer pricing economist and a Director in PricewaterhouseCoopers' San Jose office. Daniela assists in advising multinational companies on matters related to determining, evaluating, planning for, and documenting intercompany pricing arrangements including but not limited to: transfers of intangible property and cost sharing arrangements, in particular in association with the design and implementation of structural business changes; management service fee allocations; intercompany guarantee fees; investment management fee splits; and various revenue and profit split analyses for intercompany services. She has been involved in the negotiation of Advanced Pricing Agreements with the IRS and matters related to resolving controversy issues with tax authorities in audit defense environments. Daniela's experience includes work with companies in the semiconductor, semiconductor design, software,bio pharma, medical devices, and financial services industries.

Daniela is a member of the American Society of Appraisers. She holds a Ph.D. degree in Economics (Game Theory) from the University of North Carolina at Chapel Hill, U.S.

Recent working papers/publications include:

  • "Transfer Pricing for Financial Services Companies," Adam Katz; Aamer Rafiq; Stanley J. Hales; Ryann Thomas; Daniela Ielceanu and others; book in progress, to be published by PricewaterhouseCoopers in 2011

  • "Estimating Guarantee Fees under the Loss Given Default Framework," Stanley J. Hales, Dan Axelsen, and Daniela Ielceanu, 2008; Tax Management International Journal, Vol.39, No.8, August 13, 2010
  • "On the Economics of the Fees Charged by Investment Managers of Separate Managed Accounts - Does Performance Matter?" PricewaterhouseCoopers' PKN United States, March 2009; Stanley J. Hales, Mac Calva, and Daniela Ielceanu
  • "Industry Analyses for Transfer Pricing Purposes: A New Look at the Old Porter Five Framework" (co-author); internal PricewaterhouseCoopers training materials; 2008
  • “Comments on Proposed Regulation §1.482-7” (co-author), submitted to the Department of the Treasury and the Internal Revenue Service and prepared on behalf of the Membership of the United States Council for International Business on the proposed U.S. regulations on cost sharing of intellectual property development among controlled parties; 2006
  • "The "What," the "Why," and the "How" of Capital Intensity Adjustments and Inventory Accounting Method Adjustments in Transfer Pricing Analyses" (co-author), internal PricewaterhouseCoopers training material; 2006

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