Giorgi Macharashvili

Biography

Giorgi has over 15 years of extensive experience working across public and private organizations, specializing in complex transfer pricing and international taxation matters. He is a skilled professional managing advisory projects across numerous industries, with deep expertise in transfer pricing issues related to financial transactions, intra-group services, supply chains, profit allocation to the permanent establishments, etc.

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Recent Experience

• Successfully won a transfer pricing dispute for a Middle East-based apparel industry company concerning working capital adjustments, securing a favorable outcome in negotiations with tax authorities.
• Advised a major oil and gas industry group on the structuring and strategic planning of their transfer pricing framework to ensure compliance with local and international regulations.
• Developed comprehensive transfer pricing policies related to royalty payments, corporate guarantees, swaps, and derivatives for financial institutions and non-financial clients based in the Middle East.
• Provided ongoing advisory services on global transfer pricing compliance to a UAE-headquartered multinational group, ensuring adherence to evolving local legislation and OECD guidelines.
• Assisted a multinational manufacturing company in benchmarking and documentation processes to support intercompany pricing for cost-sharing arrangements.
• Conducted transfer pricing risk assessments and gap analyses for large conglomerates to identify potential audit exposure and mitigation strategies.