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Al Adalla
Read MoreA complete spectrum of legal services across jurisdictions in the Middle East & North Africa.
Giorgi Macharashvili
Transfer Pricing Lead
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.
Giorgi’s proven track record includes serving as a transfer pricing official for the Georgian Tax Authorities, where he played a key role in drafting and implementing transfer pricing legislation. He was also a member of the OECD BEPS Project Working Party 6, focusing on BEPS Actions 8-10 related to transfer pricing issues. Additionally, Giorgi has actively participated in transfer pricing workshops and training sessions organized by the OECD, IOTA, and the World Bank, focusing on critical transfer pricing aspects and the latest international developments
In addition to his public sector experience, Giorgi has spent over eight years leading transfer pricing practices within Big Four firm, including the last two years based in the Dubai office. His expertise spans advisory and compliance services, helping multinational clients navigate complex transfer pricing regulations and optimize their tax strategies.
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.
Language(s)
- Georgian
- Russian
- English
Education
- 2008 –Bachelor of Business administration, Tbilisi State University, Georgia
- 2018 – Master of business administration. Ilia state University, Tbilisi, Georgia
Practice(s)
Sector(s)
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