Professional Profile
Per Hr. Jørgensen is the Managing Director and business economist at TPEC-Global, and provides over 25 years of experience in financial analyses, economic valuations, and comparative benchmarking issues for both multinational and domestic companies. His primary focus is to evaluate intercompany transfer prices, economic profits and risks, and intangible asset values. Mr. Jørgensen has testified as an Expert Witness in a number of U.S. State tax disputes on behalf of taxpayers to defend the arm’s-length nature of their transfer pricing policies for tangible goods, intangible property, management services, and financial arrangements among affiliated entities. As the former National Partner-In-Charge of two of the largest global accounting firms’ Transfer Pricing Practices, he has extensive global knowledge of U.S., OECD, and country-specific transfer pricing regimes.
Expert Testimony:
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GE Petrochemicals, Inc. v. Cynthia Bridges, Secretary Louisiana Department of Revenue, State of Louisiana
Testified as an expert witness in IRC § 482, transfer pricing, and economics with respect to aspects of control and the applicability of IRC § 482 to joint venture relationships, in the GE Petrochemicals, Inc. v. Cynthia Bridges, Secretary Louisiana Department of Revenue, State of Louisiana, B.T.A. Docket No. 6031.
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Petition of The Sherwin-Williams Company
Testified as an expert witness in IRC § 482, transfer pricing, and economics in the Petition of The Sherwin-Williams Company, N.Y. Div. Tax App., Admin. Law Judge Unit, DTA No. 816712 (June 7, 2001).
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Illinois and Wisconsin Departments of Revenue
Submitted deposition testimony on behalf of taxpayers against the Illinois and Wisconsin Departments of Revenue, respectively, concerning whether intercompany payments of royalties, management fees, and interest were arm’s-length among affiliated parties, and was retained to submit deposition and expert testimony for domestic transfer pricing purposes in the State of Maryland.