Ednaldo Silva has a PhD in economics from the University of California (Berkeley) and was the first economic adviser at the Internal Revenue Service Office of Chief Counsel, a drafting member of the US transfer pricing (TP) regulations and first economist in the Advance Pricing Agreement programme. Silva introduced the “comparable profits method” and “best method” rule and is a recognised TP and intangibles valuation expert. He has served as economic expert to government and MNE on corporate income tax and IP litigations, including in GlaxoSmithKline Holdings (Americas) v Commissioner of Internal Revenue.