Senior Transfer Pricing Economist for PricewaterhouseCoopers LLP
Marios Karayannis is a Partner at PwC in San Jose. He leads the firm's West Region Transfer Pricing Practice and the Global Transfer Pricing Services for Technology Industry clients. He is the Senior Transfer Pricing Economist for PricewaterhouseCoopers LLP on the West Coast with 20 years of experience. He advises multinational companies on matters relating to determining, evaluating, or documenting intercompany pricing arrangements, and resolving controversy issues with U.S. and foreign tax authorities in the Advance Pricing Agreement, Competent Authority, or audit defense environment. He has also been engaged by counsel to provide expert advice on intercompany pricing matters during IRS audits and in bankruptcy proceedings.
His experience covers nearly all areas of intercompany arrangements, with principal focus on transfers of intellectual property transactions, cost sharing arrangements, and transactions related to the design and implementation of business structural change. His principal clients consist of U.S.-based and foreign-based multinational companies in the technology sector, including semiconductor, semiconductor design, networking equipment, electronic manufacturing services, wireless communications, computer software, internet and biotechnology companies.
Dr. Karayannis has published studies and articles on transfer pricing, tax policy, and financial economics, and speaks frequently on related topics at internal and external conferences around the country and internationally. He holds M.A. and Ph.D. degrees from the University of Virginia.