BarbaraBio3squarewebWhat We Do

As a transfer pricing advisor with more than twenty years of experience in both the private sector and the Internal Revenue Service Competent Authority office (now known as the Advance Pricing and Mutual Agreement office), I advise multinational enterprises regarding a wide range of transfer pricing matters, and bring to my advice the perspective of both the tax authority and the taxpayer. 

Among the services Mantegani Tax PLLC can provide are:
  • Transfer Pricing Risk Assessment •  including review of current and planned structures, analysis of current transfer pricing internal documents and formal documentation, identification of potential transfer pricing exposures and recommendations for risk mitigation.
  • Conflict Resolution
    • Treaty-Related Projects • including Mutual Agreement Procedure cases involving the United States and any of its treaty partners, where I work closely with clients and foreign advisors to develop and advance desirable positions for resolution.
    • Advance Pricing Agreement Projects • where I can partner with transfer pricing economists to identify a strategy and develop appropriate and acceptable transfer pricing methods for the relevant intercompany transactions, prepare the APA request, and work with the relevant governments to achieve resolution.
  • Document Review and Analysis • particularly the review of a company’s global transfer pricing policies, documentation reports, Master File, Local File and Country by Country Reports, to identify and address inconsistencies and conflicts in data, which in turn minimizes the risk of having to defend inconsistent positions in transfer pricing audits across different countries and regions.
  • General Transfer Pricing Advice • including providing training to internal tax and finance department personnel, and advising on transfer pricing issues arising during the start-up phase of a business, acquisitions and dispositions.


As a transfer pricing advisor with more than twenty years of experience in both the private sector and the Internal Revenue Service, Barbara advises multinational enterprises regarding a wide range of transfer pricing matters, from basic risk assessment to dispute resolution. Barbara has worked with enterprises of various sizes and geographic scope, and in various industries, including pharmaceuticals, technology, electronics, automotive, e-commerce and financial services.

Barbara served as a Competent Authority Analyst and APA Team Leader from 2009-2013 at the Internal Revenue Service U.S. Competent Authority office and Advance Pricing and Mutual Agreement Office. Her duties included negotiating the settlement of numerous double tax cases and advance pricing agreements with tax authorities from Japan, India, Denmark, Belgium and Canada. In these negotiations Barbara gained valuable knowledge and understanding regarding how to frame and advocate for positions with a high degree of success.

As a tax advisor both at a global law firm and at Big 4 accounting firms, Barbara has advised multinational enterprises regarding planning and development of a global transfer pricing strategy, documentation, cost sharing arrangements, global restructuring, and treaty-based dispute resolution, i.e., competent authority assistance and advance pricing agreements. With her strong background in technical writing and analysis, Barbara has published articles on a wide range of transfer pricing topics, including advance pricing agreements, mutual agreement procedures, and transfer pricing documentation (including country-by-country documentation). She has been a speaker at numerous tax conferences and seminars, including meetings sponsored by the Tax Executives Institute, the American Bar Association, the International Fiscal Association, and Bloomberg BNA.


  • Master of Laws in Taxation, Georgetown University Law Center, 1990
  • Juris Doctor, University of Maine School of Law, 1980
  • Bachelor of Arts, Boston College, 1976
  • Advanced Certificate, Graduate School of Conflict Analysis and Resolution, George Mason University, 2012