Theodor van Stephoudt has extensive experience working with clients in providing assistance in the development of transfer pricing documentation, the planning of appropriate intercompany prices and the valuation of intangibles, tangible assets and entities for tax purposes. Mr. Van Stephoudt has defended clients in tax audits conducted by the U.S. Internal Revenue Service (IRS) and tax authorities in Europe and in Asia. His clients include multinational companies with cross-border, intra-group transactions. Mr. Van Stephoudt has advised clients of all sizes, from smaller startup companies to very large, well-known global multinational corporations. He has analyzed intercompany pricing and fee structures for various industry sectors, including manufacturing, high-tech and financial services, and provided analyses regarding royalty rates, including brand name royalties and related tax and transfer pricing advice.
Mr. Van Stephoudt has developed management fee systems for clients in a number of industries and has assisted clients in determining the most advantageous location for intangibles/value drivers. He has also advised clients in obtaining advance pricing agreements on a bilateral and unilateral basis. Mr. Van Stephoudt advised on bilateral advance pricing agreements with Switzerland, Germany, Denmark and Norway. He has valued trademarks, technologies, startup companies, other tangible and intangible assets and entire corporations. Mr. Van Stephoudt has assisted in due diligence processes to evaluate potential transfer pricing risks. He has presented at tax and transfer pricing forums, and his articles on transfer pricing have been published in both English and German magazines.
Mr. Van Stephoudt is a graduate of Dartmouth College (M.B.A., 1996) and RWTH Aachen University (1985).