Patricio Alvarez Dunn
Role: Manager, Transfer Pricing
Years in Tax Field: 6 years
Area of Expertise: Transfer Pricing, Financial Services Transactions, Benchmarking & Comparables Analysis, Transfer Pricing Documentation (Local File / Master File), DEMPE & Value Chain Analysis, Controversy & Audit Defense, Tax Technology & AI-Enabled Tooling
Notable Experience:
- Advises multinational groups on transfer pricing across 13+ jurisdictions, aligning US §482 and OECD guidelines and navigating the overlaps between them for services, tangible goods, intangibles, and financial transactions across multiple industries.
- Specializes in intercompany financial transactions — loans, cash pooling, fund management activities, guarantees, debt capacities and captive/reinsurance arrangements — applying credit-rating, interest-rate benchmarking, and modelling to support arm’s-length outcomes.
- Serves as the transfer pricing subject-matter expert for Exactera’s AI-enabled transfer pricing software, defining the transaction taxonomy, the transfer pricing frameworks, and comparables-screening methodology that underpin the product.
- Designs and builds internal and external analytical tooling — including an interest-rate benchmarking tool on loans and bonds market data and TNMM comparables-screening engines — that brings automation and consistency to transfer pricing analysis.
- Delivers benchmarking studies and audit-ready documentation across US, Canada, EU, APAC, and LATAM.
Overview
Professional Bio
Patricio Alvarez Dunn is a Transfer Pricing Manager at Exactera, where he advises multinational groups on intercompany pricing across the US (§482) and OECD frameworks in more than a dozen jurisdictions spanning the US, Canada, EU, APAC, and LATAM. His clients work covers the full documentation lifecycle — Local File, and Master File— alongside complex financial-transactions analysis, functional and value-chain studies, design of transfer pricing policies and audit defense. Alongside client delivery, Patricio serves as the transfer pricing subject-matter expert behind Exactera’s AI-enabled transfer pricing software, translating technical practice into the methodology, data architecture, and workflows that power the product. He combines deep economic and benchmarking expertise with hands-on technical skills in programming and modern data tooling, bridging the gap between transfer pricing doctrine and the technology that scales it.
Perspectives
What I’ve learned about transfer pricing:
Transfer pricing is far more than a compliance exercise — it’s where a company’s economics, operations, and tax position all meet. The most defensible analyses are the ones grounded in how a business actually creates value, not just in a benchmarking range. I’ve also learned that the discipline rewards both rigor and adaptability: the same transaction can be viewed very differently across jurisdictions, and part of the job is holding those perspectives together in a way that stands up to scrutiny.
What surprised me the most about my field:
How quickly transfer pricing is being reshaped by data and technology. What used to take days of manual benchmarking and document assembly can increasingly be structured, automated, and made more consistent with the right tooling. Sitting at the intersection of transfer pricing and product development, I’ve been surprised by how much upside there is when deep technical expertise is paired with modern data and AI — it doesn’t replace judgment, it gives you more room to apply it.
My greatest strengths are:
A rare combination of technical transfer pricing depth and genuine fluency with data and technology. I can move from an OECD or §482 policy question to a financial model or a benchmarking dataset without losing either the economic substance or the practical detail. I’m analytical and methodical by nature, comfortable with complex financial transactions, and equally at home explaining an analysis to a client, mentoring a team, or designing the software workflow that makes the analysis repeatable at scale.
