Varangana, Punchihev

Varangana Punchihewa

Director, MBA · +1 (949) 222 2999
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Varangana has nearly 15 years of experience advising clients in various transfer pricing compliance and consulting matters, as well as valuation services. Throughout her career she has worked with numerous top global clients in the consumer products, software, medical device, pharmaceutical, natural resources and renewable energy, and media and entertainment industries.

  • Assists clients in setting up transfer pricing policies and documentation including for FIN 48 and ASC 740 income tax provision purposes 
  • Manages the preparation of U.S. and local county reports to document compliance of various intercompany transactions (based on OECD and IRS guidelines), including fact gathering interviews, technical research, economic analyses and modeling 
  • Performs intercompany transaction analysis, comparable industry analysis, industry level economic analysis, and multi-year financial modeling to benchmark client intercompany pricing practices and policies 
  • Advises clients with controversy and planning, including audit defense and negotiation of unilateral and bilateral Advance Pricing Agreements 
  • Guides clients through the processes and operational aspects of transfer pricing 
  • Reviews relevant intercompany transactions and conducts planning analyses to benchmark reasonable range of arm’s length results (e.g. proposed distribution, contract R&D functions, etc.) 
  • Evaluates treaty articles and researches complex tax issues to ensure resolution in collaboration with specialty groups such as VAT, Customs, and International Tax 
  • Educates clients regarding the latest OECD Base Erosion and Profit Sharing (BEPS) action items related to transfer pricing, including performing readiness assessments 
  • Identifies opportunities to optimize tax savings through transfer pricing planning 




Master of Business Administration in finance 

Bachelor of Science in finance and marketing 
California State University, Long Beach