Commons Transfer Pricing Pitfalls: How to Correct Them Before It’s Too Late

November 6, 2025 12:00pm ET

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Learning Objectives

Identify common pitfalls companies face when designing and implementing transfer pricing policies

Recognize key indicators that transfer pricing policies may be misaligned with operational realities.

Explore practical strategies for course-correcting when transfer pricing goes off track, including real-world examples.

Understand how tax authorities evaluate transfer pricing documentation and what makes an analysis robust and defensible across jurisdictions.

Speakers

Susana Pujalt

Team Lead Sr Manager, Transfer Pricing

Susana Pujalt is a transfer pricing expert in Exactera’s professional services group, specializing in international tax transfer pricing planning and compliance. Creator of strategic transfer pricing policy and guidelines for one of Canada’s major international banks, Pujalt served as a consultant at PwC. She has more than 20 years of experience in transfer pricing compliance and holds a bachelor’s degree in economics and a diploma in finance from the London School of Economics.

Chris Mangrobang

Senior Manager

Chris Mangrobang has 17 years of transfer pricing experience, working at global accounting firms and on staff at a large automotive parts manufacturer, where he documented U.S. and Canadian transfer pricing transactions. His expertise includes audit defense, double-tax elimination submissions, due diligence discussions, and transfer pricing risk assessments. Mangrobang is a CFA charterholder and economist.

Sean Faulkner

Transfer Pricing Specialist

Sean Faulkner is a seasoned transfer pricing specialist with over two decades of experience. Before joining Armanino, Faulkner spent 15 years at Valentiam, a boutique transfer pricing firm. His diverse background includes both in-house experience at a major pharmaceutical company and advisory roles at KPMG and Duff & Phelps. Faulkner’s career has spanned multiple continents, including five years of practice in Australia and China. He has advised numerous Fortune 500 and multinational clients across a broad spectrum of industries. His deep expertise in transfer pricing is particularly strong in sectors such as industrial manufacturing, specialty chemicals, pharmaceuticals, medical devices, and publishing/media.

Nghi Huynh

Partner-In-Charge, Transfer Pricing at Armanino

Nghi Huynh leads Armanino’s Transfer Pricing practice and is a key member of the firm’s National Tax Office (NOW!). With deep expertise developed over years at Big Four firms, Nghi brings strategic insight and practical solutions to clients navigating complex global transfer pricing matters. She has advised multinational companies across a wide array of industries, with particular specialization in technology and manufacturing and distribution clients. Nghi has extensive experience in intellectual property (IP) valuation for transfer pricing, including valuations for licensing, cost-sharing arrangements, and business restructurings. She frequently advises clients undergoing global business restructurings, helping them realign intercompany pricing, manage risks, and optimize tax and operational outcomes. Her work spans entity rationalization, functional reallocation, and IP migration strategies in compliance with U.S. and OECD guidelines. In addition to her client work, Nghi is a frequent speaker at national and regional tax conferences, including the TEI-SJSU High Tech Tax Institute. Her thought leadership spans topics such as global IP structuring, intercompany pricing strategies, and evolving OECD guidance. As a member of the American Institute of Certified Public Accountants, she earned her master’s degree in taxation from Golden Gate University and her bachelor’s degree from the University of California, Berkeley.