Hardi Kuvadia

Transfer Pricing leader with 14+ years of experience designing and leading global transfer pricing strategies for multinational organizations across industries. Proven track record of building and executing end-to-end transfer pricing frameworks spanning operating model design, supply chain and IP/R&D structuring, cost allocation, business restructuring, TP carve-outs, M&A integration, audit defense, and global compliance. Experienced in partnering with C-suite executives and cross-functional leadership teams to align transfer pricing policies with business strategy, value creation, and financial outcomes.

Adept at developing innovative, practical solutions to complex business challenges and building trusted relationships with colleagues, clients, and executive stakeholders. Demonstrated success in building, hiring, onboarding, training, and leading high-performing teams, overseeing multiple concurrent engagements and ensuring quality delivery across workstreams.

Senior Manager – International Tax and Transaction Services - Ernst & Young U.S. LLP

(2022-06 - 2026-08)

• Led transfer pricing strategy and execution for multinational clients, designing operating models and intercompany pricing frameworks aligned with business substance, value creation, and global tax requirements.
• Advised clients across media & entertainment, medical devices, consumer products, and industrial manufacturing on end-to-end transfer pricing frameworks, including IP structuring, supply chain design, and global policy alignment.
• Prepared valuations for intangible assets such as trademarks, patents, and manufacturing know-how.
• Leveraged advanced data analytics and AI-enabled workflows to enhance efficiency and defensibility of transfer pricing analyses.
• Directed functional and value chain analyses with senior leadership (C-suite, department heads) to inform TP policy and operating model decisions.
• Led and coordinated transfer pricing support for M&A and business transformation initiatives, including carve-outs, restructuring adjustments, and alignment of intercompany pricing with evolving operational and legal entity structures.
• Provided strategic advisory for global consumer products clients, aligning intercompany pricing with customs valuation requirements, including royalty unbundling and risk mitigation across tax and customs frameworks generating significant tariff savings.
• Led multiple global transfer pricing documentation projects including conducting functional interviews, economic and industry analyses.
• Supported ASC-740 and FIN-48 year-end transfer pricing related processes and supporting documentation.
• Advised on BEAT and Services Cost Method ("SCM") positions, validating technical conclusions, and assessing SCM eligibility for intercompany service and cost-sharing charges.
• Advised on OTP processes, including mapping of intercompany transactions, aligning transfer pricing policies with ERP systems, and supporting development of process documentation to enable scalable and compliant execution.
• Reviewed and developed process memos supporting qualified CbCR positions, including methodologies and data flows for Transitional CbCR Safe Harbour ("TCSH") calculations.
• Partnered with senior client stakeholders across Finance, Tax, Legal, Operations to align transfer pricing strategies with broader business objectives and transformation initiatives.
• Served as performance manager and career counselor for 4-5 professionals, leading recruiting, onboarding, coaching, technical training, performance development, and progression planning.
• Directed end-to-end project management for client engagements, responsible for planning, scheduling, milestone tracking, and deliverables to consistently meet timelines.
• Selected as the Atlantic Geo TP lead, driving regional go-to-market strategy and identifying operating model transformation opportunities in partnership with senior market leaders.

Manager – Economics and Valuation Services - KPMG LLP

(2019-02 - 2022-05)

• Managed global TP Compliance of renowned multinational companies from various sectors like consumer goods, oil and gas, automotive, life-sciences, financial services, and technology companies etc.
• Advised various U.S./multinational clients on global TP matters relating to setting of transfer pricing policy, cost allocation, intangibles, business restructuring, etc.
• Managed supply chain and intangible property restructuring projects for large multinationals.
• Supported complex transfer pricing initiatives, including bilateral APA projects (PFC, APA applications, opening conference presentations), and headquarter cost allocation analyses.
• Assisted client with navigating tax audit including responding to data requests and preparing witness statements with a series of litigation in Mauritius.
• Directed end-to-end project management for client engagements, responsible for planning, scheduling, milestone tracking, and deliverables to consistently meet timelines.
• Chosen as an affiliate of the Washington National Tax practice for 2021 ("WNT Affiliate"), In my role as a WNT Affiliate, I developed technical content and also led KPMG's national trainings at both Manager and staff level.
• Supported the Partner and Director in winning new accounts for the practice and coordinating with the team members of other service lines on client matters to deliver joint proposals.
• Assisted the Partner/Director in drafting Tax advisor article June Tax Clinic.

Manager – Global Transfer Pricing Services - BSR & Co. LLP (a network firm of KPMG in India)

(2012-06 - 2018-02)

• Managed transfer pricing compliance and documentation for multinational clients across diverse industries including automobile, IT, shipping, telecommunications, chemicals, and industrial markets.
• Independently handled transfer pricing audits and represented clients before tax authorities.
• Prepared submissions and appeals across first and second-level appellate proceedings.
• Coordinated with tax and legal counsel on litigation strategy and representation.
• Led preparation and strategy for APA applications, including participation in APA hearings.
• Conducted functional analysis interviews with senior management to assess business models and value drivers.
• Prepared FIN 48 memoranda supporting transfer pricing positions and risk assessments.
• Assisted the Partner/Director in drafting article published by Taxsutra (Link: http://www.tp.taxsutra.com).
• Nominated for the "Economic Times Young Leadership Programme 2017"

Bachelor of Commerce - University of Mumbai (2010-07)

Associate Chartered Accountant - Indian CPA - The Institute of Chartered Accountants of India (2011-11)