Donna Frye has eighteen years of transfer pricing knowledge serving multinational clients, primarily focused on transfer pricing compliance; planning and controversy services, including responding to IRS notices; filing competent authority; and advance pricing agreements. Donna performs benchmarking analyses to provide an arm’s length intercompany pricing for tangibles, services, and royalties for all industries. She prepares transfer pricing documentation reports and benchmarking memos under the US regulations and OECD guidelines, and for clients for global transactions, maintaining economic consistency while meeting local regulatory requirements.
Donna advises clients in creating models and policies for charging services to global affiliates, and on the transition in preparing the master file and local file documentation under Action 13 of BEPS. She reviews clients’ in-house prepared transfer pricing reports to make comments and recommendations, and works with clients on co-sourcing transfer pricing documentation. She also assists with disputes and controversy including foreign audits.
Donna has previously worked in Big Four accounting firms and a Big Three automotive company. She is also a frequent speaker on transfer pricing topics.