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Juan Carlos Ceballos BSc MBA

Transfer Pricing Partner

San Diego, California, USA

Consulting Firm

Professional Summary

Resourceful, collaborative, self-motivated, bilingual, and passionate professional with over 15 years of experience in Transfer Pricing (TP), international tax, supply chain, and applied economics. Proven track record improving the design, implementation, and management of the TP policy based on process improvement, and better use of systems aligning with business, finance and tax priorities. Extensive experience with TP disputes and APAs as an in-house specialist and advisor.

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  • English
  • Spanish




  • Spending time with family/kids
  • Golf
  • Entrepreneurship


August 30

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San Diego, California, USA 92174
Transfer Pricing Partner
Consulting Firm
2019 - Present
We are devoted to helping our clients take control of their transfer pricing risk and compliance requirements. We have been ‘in the trenches’ as in-house transfer pricing specialists and combine our team’s knowledge, foresight, contacts and industry expertise to develop practical solutions that pay for themselves.
Aptis Global
San Diego, California, USA 92122
Consulting Firm
2017 - 2019
- Provide independent professional in a wide range of transfer pricing services for clients in the medical industry, transportation, defense, gaming and payment industries practicing careful risk management.
̈- Assist in determining the scope of transfer pricing projects, participate in client interviews, establish project budgets and timelines, draft proposals, and assist with presenting the firm’s transfer pricing approach to prospective clients.
- Maintain active communication with clients to manage expectations, ensure satisfaction, make sure deadlines are met, and lead change efforts on process improvement as a business advisor to the client.
- Oversee the supervision and mentoring of staff at the Mexico office.
Life Technologies (Thermo Fisher)
Carlsbad, California, USA 92008
Head of Transfer Pricing
Corporation - Publicly-Held
2009 - 2016
- Lead the TP function and advised tax and finance leadership on TP strategy, compliance and risk
- Ensured that TP policies worked on an operational level for Thermo Fisher's Life Sciences Group (LSG) including:
- Managed profitability of legal entity and segment reporting for testing during quarterly and annual reviews. o Coordinate the completion of appropriate TP documentation or support.
-- Substantially collaborated with multi-competency teams to ensure control and consistency of TP processes including complex projects in-house such as ERP consolidation, cost-sharing unwinding, multiple acquisitions, a spinoff, company reorganizations and the termination of a consignment warehouse and a commissionaire structure. o Oversaw regional intragroup service charges, cost allocations, licensing and intercompany financing.
-- Created and maintained intercompany agreements ensuring that intangible property was properly structured and shared across the group.
- Significantly contributed to the interview process with the commercial and operations teams for the preparation of analyses of relevant functions, assets, markets, and risks.
- Actively managed relationships with external TP advisors.
- Coordinated and negotiated three bilateral APAs and a Competent Authority case.
- Significantly contributed to defending the company's TP and customs practices in the U.S., Argentina, Canada, Austria, France, Germany, Italy, Spain, U.K., China, India, Japan, Korea, Singapore, and Taiwan.
Irvine, California, USA 92612
Consulting Firm
2007 - 2008
-Lead the preparation of documentation studies for U.S. tax purposes mainly involving tangible products, intangible property, and intra-group service intercompany transactions.
-Participated in state, federal and global tax planning, restructuring supply chains and TP models/policies consistent with U.S. federal income tax and/or OECD guidelines.
-Contributed with tax provision work and TP risk assessments
Toronto, Canada
Consulting Firm
2004 - 2007
-Lead the preparation of Canadian and OECD documentation studies specializing on tangible and intangible property types of intercompany transactions.
-Effectively performed numerous foreign TP documentation reviews from a Canadian perspective and global TP risk assessments
-Highly contributed in engagements involving TP audit defense, particularly in dealing with transfer-pricing issues associated with the lack of contemporaneous TP documentation/support, IP and permanent establishment
-Developed specific valuation models, profit/cost-sharing allocations, sensitivity models and segmented financial data for purposes of identifying opportunities such as cash repatriation or tax/customs savings
-Employed econometric and statistic tools in the development of analyses, conclusions, and recommendations
-Developed the Canadian practice internal procedures to conduct and document comparable agreement searches using SEC filling databases, royaltystat, royaltysource and other tools.
Tijuana, Mexico 22420
Senior Analyst
Consulting Firm
2000 - 2004
-Responsible for preparing TP documentation for Mexican Income Tax Law compliance
-Contributed to the provision of ad hoc economic and corporate finance consulting such as antidumping and business valuations
-Coordinated an annual investment forum organized by Deloitte Mexico and ICEX, Spanish Institute of Foreign Trade
-Supervised and coordinated transfer activities involving transfer pricing quality controls, engagement letter templates, and training materials
-Analyzed financial statements, searched for comparable companies, and created financial models
-Contributed to preparing APA’s and TP analyses for clients with maquiladora operations


BS, Economics 1999
Universidad Autonoma de Guadalajara
Guadalajara, Jalisco, Mexico
MBA, Finance 2008
Instituto Tecnologico y de Estudios Superiores de Monterrey
Monterrey, Nuevo Leon, Mexico

Associations and Societies

  • Mexico Society of CPAs -BC Chapter (President of the Transfer Pricing Group)

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