TP Talks - PwC's Global Transfer Pricing podcast Tue, 28 Apr 2026 23:40:06 -0400 http://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts.html en-us Copyright © 2016 PwC. All rights reserved. “PwC” refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. yes Support this Podcast c3626f46-8b6b-58ce-a0ca-9b9e2a3f3da5 PwC episodic no PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.

]]> Buzzsprout (https://www.buzzsprout.com) PwC,transfer,pricing,tax,consulting https://storage.buzzsprout.com/ai08nshmzk2ah4if1x0jkbetarae?.jpg TP Talks - PwC's Global Transfer Pricing podcast http://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts.html PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts provide you not only the latest regulatory changes developments, but also inform you how they can impact your business.Effective insights into the latest transfer pricing developments around the worlddana.hart@pwc.comPwC Episode 123: Data-driven decisions: AI elevates transfer pricing strategy Episode 123: Data-driven decisions: AI elevates transfer pricing strategy This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement.

Support the show

]]> This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement.

Support the show

]]> PwC Buzzsprout-19088852 Tue, 28 Apr 2026 05:00:00 -0400 2116 transfer pricing, AI, podcast 1 123 full false dana.hart@pwc.com (PwC)This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement. Support the show Episode 122: The great services debate: Pricing, people, and profit allocation Episode 122: The great services debate: Pricing, people, and profit allocation This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments.

Support the show

]]> This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments.

Support the show

]]> PwC Buzzsprout-18911758 Thu, 09 Apr 2026 13:00:00 -0400 1581 transfer pricing, oecd, intercompany services, global mobility 1 122 full false dana.hart@pwc.com (PwC)This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments. Support the show Episode 121: Transfer pricing controversy: Planning for the long term Episode 121: Transfer pricing controversy: Planning for the long term This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks.

Support the show

]]> This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks.

Support the show

]]> PwC Buzzsprout-18705655 Thu, 19 Feb 2026 01:00:00 -0500 1661 tptalks, controversy, audit, advance pricing agreements, mutual agreement procedure 1 121 full false dana.hart@pwc.com (PwC)This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks. Support the show Episode 120: Increased scrutiny, higher stakes: Inside Australia’s TP enforcement shift Episode 120: Increased scrutiny, higher stakes: Inside Australia’s TP enforcement shift Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape.

Support the show

]]> Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape.

Support the show

]]> PwC Buzzsprout-18378685 Thu, 18 Dec 2025 07:00:00 -0500 1679 transfer pricing, controversy, advance pricing arrangement, podcast 1 120 full false dana.hart@pwc.com (PwC)Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape. Support the show Episode 119: When tariffs wag the transfer pricing dog Episode 119: When tariffs wag the transfer pricing dog Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing.

Support the show

]]> Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing.

Support the show

]]> PwC Buzzsprout-18277792 Tue, 02 Dec 2025 10:00:00 -0500 1401 transfer pricing, trade, tariffs, supply chain, global trade, tax 1 119 full true dana.hart@pwc.com (PwC)Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing. Support the show Episode 118: Special Edition – Financial Transactions Transfer Pricing Episode 118: Special Edition – Financial Transactions Transfer Pricing David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues.

Support the show

]]> David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues.

Support the show

]]> PwC Buzzsprout-18137345 Fri, 07 Nov 2025 13:00:00 -0500 1741 transfer pricing, financial transactions, tp policy, tp podcast 1 118 full false dana.hart@pwc.com (PwC)David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues. Support the show Episode 117: Services or something more? Navigating blurred lines in transfer pricing Episode 117: Services or something more? Navigating blurred lines in transfer pricing Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.

Support the show

]]> Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.

Support the show

]]> PwC Buzzsprout-17906012 Mon, 29 Sep 2025 16:00:00 -0400 2528 1 117 full false dana.hart@pwc.com (PwC)Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions. Support the show Episode 116: Special Edition – Financial Transactions Transfer Pricing Episode 116: Special Edition – Financial Transactions Transfer Pricing In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.

Support the show

]]> In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.

Support the show

]]> PwC Buzzsprout-17790943 Mon, 08 Sep 2025 10:00:00 -0400 1682 1 116 full false dana.hart@pwc.com (PwC)In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact. Support the show Episode 115: Ready or Not? Navigating the UK’s next TP chapter Episode 115: Ready or Not? Navigating the UK’s next TP chapter Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today.

Support the show

]]> Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today.

Support the show

]]> PwC Buzzsprout-17592839 Thu, 31 Jul 2025 10:00:00 -0400 2026 transfer pricing, podcast, United Kingdom, diverted profits tax, permanent establishment 1 115 full false dana.hart@pwc.com (PwC)Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today. Support the show Special Edition – Financial Transactions Transfer Pricing Special Edition – Financial Transactions Transfer Pricing In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief.

Support the show

]]> In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief.

Support the show

]]> PwC Buzzsprout-17272576 Tue, 03 Jun 2025 15:00:00 -0400 1767 financial transactions, transfer pricing, controversy, audits, podcast 1 114 full false dana.hart@pwc.com (PwC)In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief. Support the show Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025 Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025 In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership changes, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing—particularly under a second Trump administration.

Support the show

]]> In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership changes, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing—particularly under a second Trump administration.

Support the show

]]> PwC Buzzsprout-16903217 Thu, 03 Apr 2025 09:00:00 -0400 2366 1 113 full false dana.hart@pwc.com (PwC)In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership changes, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing—particularly under a second Trump administration. Support the show Episode 112: Special Edition – Financial Transactions Transfer Pricing Episode 112: Special Edition – Financial Transactions Transfer Pricing In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial transactions for transfer pricing purposes, and the broader societal contributions of Islamic finance through Zakat, a wealth-based charitable contribution, and its implications for transfer pricing.



Support the show

]]> In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial transactions for transfer pricing purposes, and the broader societal contributions of Islamic finance through Zakat, a wealth-based charitable contribution, and its implications for transfer pricing.



Support the show

]]> PwC Buzzsprout-16615325 Fri, 14 Feb 2025 04:00:00 -0500 1201 financial transactions, transfer pricing, podcast 1 112 full false dana.hart@pwc.com (PwC)In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial transactions for transfer pricing purposes, and the broader societal contributions of Islamic finance through Zakat, a wealth-based charitable contribution, and its implications for transfer pricing. Support the show Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world In this TP Talks episode, Kristina Novak is joined by Kristin Bohl to discuss the transfer pricing aspects of the current customs and trade environment.

Support the show

]]> In this TP Talks episode, Kristina Novak is joined by Kristin Bohl to discuss the transfer pricing aspects of the current customs and trade environment.

Support the show

]]> PwC Buzzsprout-16375426 Fri, 03 Jan 2025 14:00:00 -0500 1390 transfer pricing, trade, tariffs, podcast, supply chain, 1 111 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak is joined by Kristin Bohl to discuss the transfer pricing aspects of the current customs and trade environment. Support the show Episode 110: Transfer Pricing in the Middle East: Opportunities abound Episode 110: Transfer Pricing in the Middle East: Opportunities abound In this TP Talks episode, Kristina Novak sits down with Steven Cawdron and Zachary Noteman to discuss the evolving transfer pricing environment in the Middle East.

Support the show

]]> In this TP Talks episode, Kristina Novak sits down with Steven Cawdron and Zachary Noteman to discuss the evolving transfer pricing environment in the Middle East.

Support the show

]]> PwC Buzzsprout-16252531 Tue, 10 Dec 2024 09:00:00 -0500 2098 1 110 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak sits down with Steven Cawdron and Zachary Noteman to discuss the evolving transfer pricing environment in the Middle East. Support the show Episode 109: Brazil’s big shift: The new transfer pricing reality Episode 109: Brazil’s big shift: The new transfer pricing reality In this TP Talks episode, Kristina Novak sits down with Marcelo Vieira to discuss the progress of Brazil’s overhaul of its transfer pricing regime.

Support the show

]]> In this TP Talks episode, Kristina Novak sits down with Marcelo Vieira to discuss the progress of Brazil’s overhaul of its transfer pricing regime.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts.html PwC Buzzsprout-16142050 Wed, 20 Nov 2024 14:00:00 -0500 1036 tp talks, podcast, brazil, transfer pricing 1 109 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak sits down with Marcelo Vieira to discuss the progress of Brazil’s overhaul of its transfer pricing regime. Support the show Episode 108: Special Edition – Financial Transactions Transfer Pricing Episode 108: Special Edition – Financial Transactions Transfer Pricing Debt capacity 

In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.

Support the show

]]> Debt capacity 

In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.

Support the show

]]> PwC Buzzsprout-16060449 Thu, 07 Nov 2024 11:00:00 -0500 2668 1 108 full false dana.hart@pwc.com (PwC)Debt capacity  In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers. Support the show Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1

Support the show

]]> This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1

Support the show

]]> PwC Buzzsprout-15896581 Wed, 09 Oct 2024 13:00:00 -0400 1944 transfer pricing, OECD, Pillar One, Amount B 1 107 full false dana.hart@pwc.com (PwC)This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1 Support the show Episode 106: CbCR: The evolving landscape Episode 106: CbCR: The evolving landscape This TP Talks episode addresses the evolution of country-by-country reporting (CbCR) as it relates to the OECD’s Pillar Two Transitional CbCR Safe Harbor and Public CbCR.

Support the show

]]> This TP Talks episode addresses the evolution of country-by-country reporting (CbCR) as it relates to the OECD’s Pillar Two Transitional CbCR Safe Harbor and Public CbCR.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/cbcr-evolving-landscape.html PwC Buzzsprout-15576186 Wed, 14 Aug 2024 09:00:00 -0400 2129 transfer pricing, podcast, country-by-country reporting, CbCR, public CbCR, safe harbor 1 106 full false dana.hart@pwc.com (PwC)This TP Talks episode addresses the evolution of country-by-country reporting (CbCR) as it relates to the OECD’s Pillar Two Transitional CbCR Safe Harbor and Public CbCR. Support the show Episode 105: Special Edition – Financial Transactions Transfer Pricing Episode 105: Special Edition – Financial Transactions Transfer Pricing This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada.

Support the show

]]> This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/financial-transactions-transfer-pricing-2024.html PwC Buzzsprout-15278136 Wed, 19 Jun 2024 13:00:00 -0400 2459 financial transactions, transfer pricing, intercompany loans, audits, debt 1 105 full false dana.hart@pwc.com (PwC)This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada. Support the show Episode 104: Who bears the risk? Navigating HMRC’s guidance Episode 104: Who bears the risk? Navigating HMRC’s guidance In this episode of TP Talks, Kristina Novak sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC on identifying and pricing contributions to risk control by decision-makers.

Support the show

]]> In this episode of TP Talks, Kristina Novak sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC on identifying and pricing contributions to risk control by decision-makers.

Support the show

]]> PwC Buzzsprout-15073051 Thu, 16 May 2024 08:00:00 -0400 1764 1 104 full false dana.hart@pwc.com (PwC)In this episode of TP Talks, Kristina Novak sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC on identifying and pricing contributions to risk control by decision-makers. Support the show Episode 103: Pricing intercompany loans: why implicit support matters Episode 103: Pricing intercompany loans: why implicit support matters This TP Talks episode features a discussion of the recent IRS administrative guidance  regarding implicit support and its impact on the pricing of intercompany loan transactions, both from a US and global perspective.

Support the show

]]> This TP Talks episode features a discussion of the recent IRS administrative guidance  regarding implicit support and its impact on the pricing of intercompany loan transactions, both from a US and global perspective.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/pricing-intercompany-loans.html PwC Buzzsprout-14827366 Thu, 04 Apr 2024 11:00:00 -0400 1803 podcast, tp talks, transfer pricing, implicit support, intercompany loans, glam, administrative guidance, irs 1 103 full false dana.hart@pwc.com (PwC)This TP Talks episode features a discussion of the recent IRS administrative guidance  regarding implicit support and its impact on the pricing of intercompany loan transactions, both from a US and global perspective. Support the show Episode 102: Stock-based compensation: One size does not fit all Episode 102: Stock-based compensation: One size does not fit all In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways.

Support the show

]]> In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways.

Support the show

]]> PwC Buzzsprout-14446152 Mon, 05 Feb 2024 18:00:00 -0500 1484 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways. Support the show Episode 101: The time is now: year-end TP adjustments in China Episode 101: The time is now: year-end TP adjustments in China In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Jessica Yin (Transfer Pricing Partner, PwC Shanghai), Rong Zhen (Corporate Tax and Forex Partner, PwC Shanghai), and Nancy Chen (Transfer Pricing Senior Manager, PwC Shanghai) discuss why many MNCs operating in China have been more attentive to year-end transfer pricing adjustments (TPAs), what TPAs Chinese subsidiaries might need to undertake, the challenges cross-border TPAs present in China, and options available for MNCs to implement year-end adjustments. The speakers also address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry.

Support the show

]]> In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Jessica Yin (Transfer Pricing Partner, PwC Shanghai), Rong Zhen (Corporate Tax and Forex Partner, PwC Shanghai), and Nancy Chen (Transfer Pricing Senior Manager, PwC Shanghai) discuss why many MNCs operating in China have been more attentive to year-end transfer pricing adjustments (TPAs), what TPAs Chinese subsidiaries might need to undertake, the challenges cross-border TPAs present in China, and options available for MNCs to implement year-end adjustments. The speakers also address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry.

Support the show

]]> PwC Buzzsprout-14132209 Tue, 12 Dec 2023 05:00:00 -0500 838 transfer pricing, year-end adjustments, podcast, china, foreign exchange, forex, limited risk distributor, mnc, 1 101 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Jessica Yin (Transfer Pricing Partner, PwC Shanghai), Rong Zhen (Corporate Tax and Forex Partner, PwC Shanghai), and Nancy Chen (Transfer Pricing Senior Manager, PwC Shanghai) discuss why many MNCs operating in China have been more attentive to year-end transfer pricing adjustments (TPAs), what TPAs Chinese subsidiaries might need to undertake, the challenges cross-border TPAs present in China, and options available for MNCs to implement year-end adjustments. The speakers also address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry. Support the show Episode 100: Perspectives on China and India Episode 100: Perspectives on China and India This TP Talks episode features a discussion of the transfer pricing developments in India and China.

Support the show

]]> This TP Talks episode features a discussion of the transfer pricing developments in India and China.

Support the show

]]> PwC Buzzsprout-14011923 Wed, 22 Nov 2023 15:00:00 -0500 1426 transfer pricing, china, india, advance pricing agreement, audit, supply chain, diversification, podcast 1 100 full false dana.hart@pwc.com (PwC)This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show Episode 99: More pain? A review of the transfer pricing controversy environment Episode 99: More pain? A review of the transfer pricing controversy environment In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more.

Support the show

]]> In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more.

Support the show

]]> PwC Buzzsprout-13784318 Mon, 16 Oct 2023 04:00:00 -0400 2434 transfer pricing, controversy, tax controversy, podcast, APA, dispute resolution 1 99 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more. Support the show Episode 98: Pillar One Amount B: Reading the tea leaves Episode 98: Pillar One Amount B: Reading the tea leaves In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation.
Timestamps:
1:17 - What is Pillar 1 and what is Amount B under Pillar 1?
3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B?
5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document?  
12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives?
18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that?
20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 
25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works?
31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most?
35:30 - What are some takeaways that you can offer our listeners?

Support the show

]]> In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation.
Timestamps:
1:17 - What is Pillar 1 and what is Amount B under Pillar 1?
3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B?
5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document?  
12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives?
18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that?
20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 
25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works?
31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most?
35:30 - What are some takeaways that you can offer our listeners?

Support the show

]]> PwC Buzzsprout-13490160 Tue, 29 Aug 2023 08:00:00 -0400 2437 transfer pricing, oecd, Amount B, public consultation, podcast 1 98 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation. Timestamps: 1:17 - What is Pillar 1 and what is Amount B under Pillar 1? 3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B? 5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document?   12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives? 18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that? 20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors?  25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works? 31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most? 35:30 - What are some takeaways that you can offer our listeners? Support the show Episode 97: Transfer Pricing: Exploring the past, present, and future Episode 97: Transfer Pricing: Exploring the past, present, and future In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice) and Greg Ossi (former Principal in PwC’s US National Tax Practice) discuss some of the historical transformative milestones that have reshaped transfer pricing. They also examine the current transfer pricing landscape and take a look forward, exploring some of the possibilities and challenges that lie ahead for transfer pricing practitioners and taxpayers.

Support the show

]]> In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice) and Greg Ossi (former Principal in PwC’s US National Tax Practice) discuss some of the historical transformative milestones that have reshaped transfer pricing. They also examine the current transfer pricing landscape and take a look forward, exploring some of the possibilities and challenges that lie ahead for transfer pricing practitioners and taxpayers.

Support the show

]]> PwC Buzzsprout-13250036 Wed, 19 Jul 2023 04:00:00 -0400 929 transfer pricing, podcast, controversy, advance pricing agreement, section 482 1 97 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice) and Greg Ossi (former Principal in PwC’s US National Tax Practice) discuss some of the historical transformative milestones that have reshaped transfer pricing. They also examine the current transfer pricing landscape and take a look forward, exploring some of the possibilities and challenges that lie ahead for transfer pricing practitioners and taxpayers. Support the show Episode 96: Operational Transfer Pricing: A catalyst to unlock potential in tax and beyond Episode 96: Operational Transfer Pricing: A catalyst to unlock potential in tax and beyond In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Andrew Hwang (Americas Operational Transfer Pricing Leader, PwC US), and Antonino De Benedictis (EMEA Operational Transfer Pricing Leader, PwC UK) discuss why Operational Transfer Pricing (OTP) is increasingly becoming a priority for in-house tax and finance professionals, the value and benefits OTP offers the broader finance function and C-Suite, scalability of OTP to accommodate small to large scale transformations, and practical considerations for implementing OTP.

Support the show

]]> In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Andrew Hwang (Americas Operational Transfer Pricing Leader, PwC US), and Antonino De Benedictis (EMEA Operational Transfer Pricing Leader, PwC UK) discuss why Operational Transfer Pricing (OTP) is increasingly becoming a priority for in-house tax and finance professionals, the value and benefits OTP offers the broader finance function and C-Suite, scalability of OTP to accommodate small to large scale transformations, and practical considerations for implementing OTP.

Support the show

]]> PwC Buzzsprout-13130687 Thu, 29 Jun 2023 05:00:00 -0400 1096 transfer pricing, podcast, OTP, operational transfer pricing, tp talks, transformation 1 96 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Andrew Hwang (Americas Operational Transfer Pricing Leader, PwC US), and Antonino De Benedictis (EMEA Operational Transfer Pricing Leader, PwC UK) discuss why Operational Transfer Pricing (OTP) is increasingly becoming a priority for in-house tax and finance professionals, the value and benefits OTP offers the broader finance function and C-Suite, scalability of OTP to accommodate small to large scale transformations, and practical considerations for implementing OTP. Support the show Episode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023) Episode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023) FTTP Q2 2023:  Debt capacity and transfer pricing

In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt serviceability, and reassessment of debt capacity and double taxation.

Support the show

]]> FTTP Q2 2023:  Debt capacity and transfer pricing

In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt serviceability, and reassessment of debt capacity and double taxation.

Support the show

]]> PwC Buzzsprout-13064735 Mon, 19 Jun 2023 05:00:00 -0400 1322 transfer pricing, debt capacity, financial transactions, podcast 1 95 full false dana.hart@pwc.com (PwC)FTTP Q2 2023:  Debt capacity and transfer pricing In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt serviceability, and reassessment of debt capacity and double taxation. Support the show Episode 94: Brazil’s transfer pricing rules: A shift to international standards Episode 94: Brazil’s transfer pricing rules: A shift to international standards In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Michela Chin (Transfer Pricing leader for PwC Brazil), and Matias Pedevilla (Transfer Pricing Principal with PwC US and global leader of PwC's Global Coordinated Documentation service) discuss the overhaul of Brazil’s transfer pricing system, focusing on the main changes that have been introduced, the implications of the pending rules for multinationals, and what companies should be doing now.

Support the show

]]> In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Michela Chin (Transfer Pricing leader for PwC Brazil), and Matias Pedevilla (Transfer Pricing Principal with PwC US and global leader of PwC's Global Coordinated Documentation service) discuss the overhaul of Brazil’s transfer pricing system, focusing on the main changes that have been introduced, the implications of the pending rules for multinationals, and what companies should be doing now.

Support the show

]]> PwC Buzzsprout-12865823 Wed, 17 May 2023 05:00:00 -0400 1018 tp, transfer pricing, brazil, rules, international standard, arm's length standard 1 94 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Michela Chin (Transfer Pricing leader for PwC Brazil), and Matias Pedevilla (Transfer Pricing Principal with PwC US and global leader of PwC's Global Coordinated Documentation service) discuss the overhaul of Brazil’s transfer pricing system, focusing on the main changes that have been introduced, the implications of the pending rules for multinationals, and what companies should be doing now. Support the show Episode 93: The endgame begins – Navigating TP implications in the Pillar Two world Episode 93: The endgame begins – Navigating TP implications in the Pillar Two world This TP Talks episode is part 3 of a three-part series on Pillar Two, where Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the latest Pillar Two developments, country level developments, and what companies need to  prioritize from a transfer pricing perspective.

See also: 

Support the show

]]> This TP Talks episode is part 3 of a three-part series on Pillar Two, where Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the latest Pillar Two developments, country level developments, and what companies need to  prioritize from a transfer pricing perspective.

See also: 

Support the show

]]> PwC Buzzsprout-12664128 Mon, 17 Apr 2023 04:00:00 -0400 2139 transfer pricing, OECD, Pillar Two, podcast, part 3 1 93 full false dana.hart@pwc.com (PwC)This TP Talks episode is part 3 of a three-part series on Pillar Two, where Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the latest Pillar Two developments, country level developments, and what companies need to  prioritize from a transfer pricing perspective. See also: The opening – Transfer pricing is a critical piece of the Pillar Two chessboardThe middlegame – Pillar Two strategy for transfer pricing evolvesPwC's Pillar Two Country Tracker Support the show Episode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023) Episode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023) FTTP Q1 2023:  A looking ahead (and back) on financial markets and what to expect from tax authorities

In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look back at 2022.

Support the show

]]> FTTP Q1 2023:  A looking ahead (and back) on financial markets and what to expect from tax authorities

In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look back at 2022.

Support the show

]]> PwC Buzzsprout-12475610 Mon, 20 Mar 2023 09:00:00 -0400 1308 financial transactions, transfer pricing, controversy, podcast 1 92 full false dana.hart@pwc.com (PwC)FTTP Q1 2023:  A looking ahead (and back) on financial markets and what to expect from tax authorities In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look back at 2022. Support the show Episode 91. Business transformation – when ESG, value chain, and transparency converge Episode 91. Business transformation – when ESG, value chain, and transparency converge In this TP Talks episode, new podcast host Ugo Cannavale (Transfer Pricing Leader, PwC Italy) is joined by Monica Cohen-Dumani (International Tax Services Partner, PwC Switzerland), and Brad Slattery (Global VCT Transfer Pricing Leader, PwC US) to discuss the role ESG and transparency play in driving value in operating model transformation and how transfer pricing plays a key part. The speakers focus on the EU Corporate Sustainability Directive and how tax and transfer pricing is tied into the Directive and ESG overall, the value chain implications as a result of increased transparency, and considerations around the procurement function. The speakers finish with key takeaways.

Contacts: Ugo Cannavale, Monica Cohen-Dumani, Brad Slattery

Support the show

]]> In this TP Talks episode, new podcast host Ugo Cannavale (Transfer Pricing Leader, PwC Italy) is joined by Monica Cohen-Dumani (International Tax Services Partner, PwC Switzerland), and Brad Slattery (Global VCT Transfer Pricing Leader, PwC US) to discuss the role ESG and transparency play in driving value in operating model transformation and how transfer pricing plays a key part. The speakers focus on the EU Corporate Sustainability Directive and how tax and transfer pricing is tied into the Directive and ESG overall, the value chain implications as a result of increased transparency, and considerations around the procurement function. The speakers finish with key takeaways.

Contacts: Ugo Cannavale, Monica Cohen-Dumani, Brad Slattery

Support the show

]]> PwC Buzzsprout-12272925 Fri, 17 Feb 2023 09:00:00 -0500 1383 ESG, transfer pricing, value chain transformation, transparency, operating model 1 91 full false dana.hart@pwc.com (PwC)In this TP Talks episode, new podcast host Ugo Cannavale (Transfer Pricing Leader, PwC Italy) is joined by Monica Cohen-Dumani (International Tax Services Partner, PwC Switzerland), and Brad Slattery (Global VCT Transfer Pricing Leader, PwC US) to discuss the role ESG and transparency play in driving value in operating model transformation and how transfer pricing plays a key part. The speakers focus on the EU Corporate Sustainability Directive and how tax and transfer pricing is tied into the Directive and ESG overall, the value chain implications as a result of increased transparency, and considerations around the procurement function. The speakers finish with key takeaways. Contacts: Ugo Cannavale, Monica Cohen-Dumani, Brad Slattery Support the show Episode 90: Transfer pricing in Africa from a bird’s-eye view Episode 90: Transfer pricing in Africa from a bird’s-eye view In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Osman Mollagee and Michael Butler (PwC Transfer Pricing Partners based in South Africa) to discuss the business environment in regions across Africa, the tax and transfer pricing landscape, general audit processes and avenues available with respect to dispute resolution, and what developing countries are looking for from Pillars One and Two of the OECD’s global tax reform project.

Support the show

]]> In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Osman Mollagee and Michael Butler (PwC Transfer Pricing Partners based in South Africa) to discuss the business environment in regions across Africa, the tax and transfer pricing landscape, general audit processes and avenues available with respect to dispute resolution, and what developing countries are looking for from Pillars One and Two of the OECD’s global tax reform project.

Support the show

]]> PwC Buzzsprout-11878854 Thu, 15 Dec 2022 10:00:00 -0500 1948 transfer pricing, africa, south africa, podcast, controversy, oecd, pillar one, pillar two 1 90 full false dana.hart@pwc.com (PwC)In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Osman Mollagee and Michael Butler (PwC Transfer Pricing Partners based in South Africa) to discuss the business environment in regions across Africa, the tax and transfer pricing landscape, general audit processes and avenues available with respect to dispute resolution, and what developing countries are looking for from Pillars One and Two of the OECD’s global tax reform project. Support the show Episode 89: EU and UK TP controversy trends and outlook Episode 89: EU and UK TP controversy trends and outlook In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more. 

Support the show

]]> In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more. 

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/eu-and-uk-transfer-pricing-controversy-trends-outlook.html PwC Buzzsprout-11600676 Tue, 01 Nov 2022 11:00:00 -0400 2317 transfer pricing, pillar two, pillar one, beps 2.0 1 89 full false dana.hart@pwc.com (PwC)In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more.  Support the show Episode 88: US TP controversy trends and outlook Episode 88: US TP controversy trends and outlook In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Kristina Novak and Andrew Kim (Transfer Pricing Principals in PwC’s US National Tax Services practice) to discuss recent trends and outlook with respect to US transfer pricing controversy, and steps taxpayers should consider to avoid potential risks.  

Support the show

]]> In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Kristina Novak and Andrew Kim (Transfer Pricing Principals in PwC’s US National Tax Services practice) to discuss recent trends and outlook with respect to US transfer pricing controversy, and steps taxpayers should consider to avoid potential risks.  

Support the show

]]> PwC Buzzsprout-11351187 Tue, 20 Sep 2022 08:00:00 -0400 1590 transfer pricing, controversy, advance pricing agreement APMA 1 88 full false dana.hart@pwc.com (PwC)In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Kristina Novak and Andrew Kim (Transfer Pricing Principals in PwC’s US National Tax Services practice) to discuss recent trends and outlook with respect to US transfer pricing controversy, and steps taxpayers should consider to avoid potential risks.   Support the show Episode 87: Winds of change: New Dutch transfer pricing and PE rules that can impact your business Episode 87: Winds of change: New Dutch transfer pricing and PE rules that can impact your business In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Niek van der Put (Transfer Pricing Director, PwC Netherlands), Neil Schaatsbergen (Transfer Pricing Director, PwC Netherlands), and Aleks Davydov (Transfer Pricing Senior Manager, PwC Netherlands). They discuss two decrees recently published by the Dutch tax authorities related to transfer pricing and the attribution of profits to permanent establishments, exploring what’s in the decrees, the potential impact for companies, and what actions taxpayers should take.  

See also: Dutch Ministry of Finance publishes new transfer pricing decree

Contacts: David Ernick, Niek van der Put, Neil Schaatsbergen, Aleks Davydov

Support the show

]]> In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Niek van der Put (Transfer Pricing Director, PwC Netherlands), Neil Schaatsbergen (Transfer Pricing Director, PwC Netherlands), and Aleks Davydov (Transfer Pricing Senior Manager, PwC Netherlands). They discuss two decrees recently published by the Dutch tax authorities related to transfer pricing and the attribution of profits to permanent establishments, exploring what’s in the decrees, the potential impact for companies, and what actions taxpayers should take.  

See also: Dutch Ministry of Finance publishes new transfer pricing decree

Contacts: David Ernick, Niek van der Put, Neil Schaatsbergen, Aleks Davydov

Support the show

]]> PwC Buzzsprout-11112653 Wed, 10 Aug 2022 02:00:00 -0400 1068 transfer pricing, permanent establishment, dutch, Netherlands, decree 1 87 full false dana.hart@pwc.com (PwC)In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Niek van der Put (Transfer Pricing Director, PwC Netherlands), Neil Schaatsbergen (Transfer Pricing Director, PwC Netherlands), and Aleks Davydov (Transfer Pricing Senior Manager, PwC Netherlands). They discuss two decrees recently published by the Dutch tax authorities related to transfer pricing and the attribution of profits to permanent establishments, exploring what’s in the decrees, the potential impact for companies, and what actions taxpayers should take.   See also: Dutch Ministry of Finance publishes new transfer pricing decree Contacts: David Ernick, Niek van der Put, Neil Schaatsbergen, Aleks Davydov Support the show Episode 86: The middlegame – Pillar Two strategy for transfer pricing evolves Episode 86: The middlegame – Pillar Two strategy for transfer pricing evolves In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the Pillar Two discussion, focusing on the  commentary published in March and how it has slightly reinterpreted the role of transfer pricing in Pillar Two; developments in Europe, including the UK stakeholder consultation and the ECOFIN progress regarding implementation of Pillar Two within the European Union; US developments; and the transfer pricing implications in instances of double taxation in the Pillar Two system.

Stay tuned for future TP Talks podcasts covering Pillar Two developments. 

Support the show

]]> In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the Pillar Two discussion, focusing on the  commentary published in March and how it has slightly reinterpreted the role of transfer pricing in Pillar Two; developments in Europe, including the UK stakeholder consultation and the ECOFIN progress regarding implementation of Pillar Two within the European Union; US developments; and the transfer pricing implications in instances of double taxation in the Pillar Two system.

Stay tuned for future TP Talks podcasts covering Pillar Two developments. 

Support the show

]]> PwC Buzzsprout-11004052 Thu, 21 Jul 2022 04:00:00 -0400 2203 transfer pricing, financial transactions, podcast, strategy, transfer pricing evolves, OECD/G20 Pillar, two model rules 1 86 full false dana.hart@pwc.com (PwC)In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the Pillar Two discussion, focusing on the  commentary published in March and how it has slightly reinterpreted the role of transfer pricing in Pillar Two; developments in Europe, including the UK stakeholder consultation and the ECOFIN progress regarding implementation of Pillar Two within the European Union; US developments; and the transfer pricing implications in instances of double taxation in the Pillar Two system. Stay tuned for future TP Talks podcasts covering Pillar Two developments.  Support the show Episode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022) Episode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022) In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing. 

Support the show

]]> In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing. 

Support the show

]]> PwC Buzzsprout-10790275 Tue, 14 Jun 2022 07:00:00 -0400 1286 transfer pricing, financial transactions, podcast, sustainable financing, 1 85 full false dana.hart@pwc.com (PwC)In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing.  Support the show Episode 84: US § 174 – getting your arms around the new R&D capitalization rules Episode 84: US § 174 – getting your arms around the new R&D capitalization rules In this TP Talks episode, Erin March (Transfer Pricing Principal, PwC US), Dennis Tingey (Tax Services Partner, PwC US), and Marco Fiaccadori (Transfer Pricing Principal, PwC US National Tax Services) discuss the R&D capitalization requirements under the new US § 174 regulations, focusing on transfer pricing-related questions and issues, including the definition of amortization under Section 174, primary issues taxpayers are dealing with post-Q1, impact on key U.S. international tax provisions, contract R&D/R&E arrangements, and the interplay of Section 174 capitalization and the cost sharing rules under Section 1.482-7.

Support the show

]]> In this TP Talks episode, Erin March (Transfer Pricing Principal, PwC US), Dennis Tingey (Tax Services Partner, PwC US), and Marco Fiaccadori (Transfer Pricing Principal, PwC US National Tax Services) discuss the R&D capitalization requirements under the new US § 174 regulations, focusing on transfer pricing-related questions and issues, including the definition of amortization under Section 174, primary issues taxpayers are dealing with post-Q1, impact on key U.S. international tax provisions, contract R&D/R&E arrangements, and the interplay of Section 174 capitalization and the cost sharing rules under Section 1.482-7.

Support the show

]]> PwC Buzzsprout-10611886 Fri, 13 May 2022 09:00:00 -0400 1556 transfer pricing, section 174, capitalization, research & development, podcast 84 1 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Erin March (Transfer Pricing Principal, PwC US), Dennis Tingey (Tax Services Partner, PwC US), and Marco Fiaccadori (Transfer Pricing Principal, PwC US National Tax Services) discuss the R&D capitalization requirements under the new US § 174 regulations, focusing on transfer pricing-related questions and issues, including the definition of amortization under Section 174, primary issues taxpayers are dealing with post-Q1, impact on key U.S. international tax provisions, contract R&D/R&E arrangements, and the interplay of Section 174 capitalization and the cost sharing rules under Section 1.482-7. Support the show Episode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022) Episode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022) In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency.

Support the show

]]> In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency.

Support the show

]]> PwC Buzzsprout-10381035 Tue, 05 Apr 2022 05:00:00 -0400 1702 PwC, Transfer Pricing, Tax, Financial Transaction, Episode 83, OECD Pillar, Pillar Two taxation, David Ledure, Dan Pybus, Edwin Baghdasarayan, Bob Ritter 1 83 full false dana.hart@pwc.com (PwC)In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency. Support the show Episode 82: The opening – Transfer pricing is a critical piece of the Pillar Two chessboard Episode 82: The opening – Transfer pricing is a critical piece of the Pillar Two chessboard This TP Talks podcast features discussion of the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation.

Support the show

]]> This TP Talks podcast features discussion of the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/special-financial-transactions-transfer-pricing.html PwC Buzzsprout-10121043 Tue, 22 Feb 2022 05:00:00 -0500 1369 PwC, Transfer Pricing, Tax, Financial Transaction, Episode 82, OECD Pillar, Pillar Two taxation, Horacio Peña,Kartikeya Singh, Giorgia Maffini 1 82 full false dana.hart@pwc.com (PwC)This TP Talks podcast features discussion of the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation. Support the show Episode 81: Special Edition – Financial Transactions Transfer Pricing Episode 81: Special Edition – Financial Transactions Transfer Pricing In this Financial Transactions Transfer Pricing quarterly podcast, Bob Ritter (PwC’s US Financial Transactions Transfer Pricing leader) is joined by Laura Valestin (Partner in PwC’s National Tax practice in Washington DC, specializing in financial products), and Chad Clark (Director in PwC’s Financial Markets and Real Estate practice, based in Austin, TX) to discuss LIBOR and the final regulations released by the IRS and US Treasury that provide tax guidance with respect to alterations to debt instruments, derivative contracts, and other contracts that replace interbank offered rates with qualified replacement rates, or fallback replacement rate provisions. They also highlight changes from the proposed regulations and provide key considerations for companies. 

Support the show

]]> In this Financial Transactions Transfer Pricing quarterly podcast, Bob Ritter (PwC’s US Financial Transactions Transfer Pricing leader) is joined by Laura Valestin (Partner in PwC’s National Tax practice in Washington DC, specializing in financial products), and Chad Clark (Director in PwC’s Financial Markets and Real Estate practice, based in Austin, TX) to discuss LIBOR and the final regulations released by the IRS and US Treasury that provide tax guidance with respect to alterations to debt instruments, derivative contracts, and other contracts that replace interbank offered rates with qualified replacement rates, or fallback replacement rate provisions. They also highlight changes from the proposed regulations and provide key considerations for companies. 

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/special-financial-transactions-transfer-pricing.html PwC Buzzsprout-10089392 Thu, 17 Feb 2022 12:00:00 -0500 1406 PwC, Transfer Pricing, Tax, Financial Transaction, Episode 81, LIBOR, Bob Ritter, Laura Valestin, Chad Clark 1 81 full false dana.hart@pwc.com (PwC)In this Financial Transactions Transfer Pricing quarterly podcast, Bob Ritter (PwC’s US Financial Transactions Transfer Pricing leader) is joined by Laura Valestin (Partner in PwC’s National Tax practice in Washington DC, specializing in financial products), and Chad Clark (Director in PwC’s Financial Markets and Real Estate practice, based in Austin, TX) to discuss LIBOR and the final regulations released by the IRS and US Treasury that provide tax guidance with respect to alterations to debt instruments, derivative contracts, and other contracts that replace interbank offered rates with qualified replacement rates, or fallback replacement rate provisions. They also highlight changes from the proposed regulations and provide key considerations for companies.  Support the show Episode 80: Putting the TP into ESG Episode 80: Putting the TP into ESG In this episode, we feature an excerpt from PwC’s Global Transfer Pricing Conference, focusing on ESG factors as drivers of value creation and levers to manage risks, concentrating on supply chain/value chain analysis, tax transparency, intercompany financial transactions, and deals. The panelists included Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), Jayde Thompson (Transfer Pricing partner – PwC Australia), Noor Sanders (Transfer Pricing partner – PwC Netherlands), and Shane McEvoy (Transfer Pricing partner – PwC US). 

Support the show

]]> In this episode, we feature an excerpt from PwC’s Global Transfer Pricing Conference, focusing on ESG factors as drivers of value creation and levers to manage risks, concentrating on supply chain/value chain analysis, tax transparency, intercompany financial transactions, and deals. The panelists included Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), Jayde Thompson (Transfer Pricing partner – PwC Australia), Noor Sanders (Transfer Pricing partner – PwC Netherlands), and Shane McEvoy (Transfer Pricing partner – PwC US). 

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/putting-the-tp-into-esg.html PwC Buzzsprout-9962454 Thu, 27 Jan 2022 09:00:00 -0500 1563 transfer pricing, financial transactions, podcast, changing regulatory environment, managing risk, oilfield, Ronan Finn, Jayde Thompson, Noor Sanders, Shane McEvoy, ESG, value creation, 1 80 full false dana.hart@pwc.com (PwC)In this episode, we feature an excerpt from PwC’s Global Transfer Pricing Conference, focusing on ESG factors as drivers of value creation and levers to manage risks, concentrating on supply chain/value chain analysis, tax transparency, intercompany financial transactions, and deals. The panelists included Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), Jayde Thompson (Transfer Pricing partner – PwC Australia), Noor Sanders (Transfer Pricing partner – PwC Netherlands), and Shane McEvoy (Transfer Pricing partner – PwC US).  Support the show Episode 79: Special Edition – TP in the oilfield services industry (Part 2) Episode 79: Special Edition – TP in the oilfield services industry (Part 2) In this TP Talks episode, Lauren Dangelmayr (Principal, Transfer Pricing - PwC US), Hamish McElwee (Partner, Transfer Pricing - PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), Ivan Williams (Partner, Transfer Pricing -  PwC Canada), and Thushara Corea (Director,Transfer Pricing - PwC Canada) discuss the oilfield services industry, focusing on planning related to leasing and IP, ESG, as well as pragmatic approaches to transfer pricing documentation.

Support the show

]]> In this TP Talks episode, Lauren Dangelmayr (Principal, Transfer Pricing - PwC US), Hamish McElwee (Partner, Transfer Pricing - PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), Ivan Williams (Partner, Transfer Pricing -  PwC Canada), and Thushara Corea (Director,Transfer Pricing - PwC Canada) discuss the oilfield services industry, focusing on planning related to leasing and IP, ESG, as well as pragmatic approaches to transfer pricing documentation.

Support the show

]]> PwC Buzzsprout-9773169 Wed, 22 Dec 2021 04:00:00 -0500 1303 transfer pricing, financial transactions, podcast, changing regulatory environment, managing risk, oilfield, Lauren Dangelmayr, Hamish McElwee, Szymon Wlazlowski, Ivan Williams, Thushara Corea 1 79 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Lauren Dangelmayr (Principal, Transfer Pricing - PwC US), Hamish McElwee (Partner, Transfer Pricing - PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), Ivan Williams (Partner, Transfer Pricing -  PwC Canada), and Thushara Corea (Director,Transfer Pricing - PwC Canada) discuss the oilfield services industry, focusing on planning related to leasing and IP, ESG, as well as pragmatic approaches to transfer pricing documentation. Support the show Episode 78: Special Edition – TP in the oilfield services industry (Part 1) Episode 78: Special Edition – TP in the oilfield services industry (Part 1) In this TP Talks episode, Lauren Dangelmayr (Transfer Pricing Principal, PwC US), Hamish McElwee (Transfer Pricing Partner, PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), and Ivan Williams (Transfer Pricing Partner, PwC Canada) discuss the changing regulatory environment around the world and the impact on the oilfield services industry.  The speakers also discuss the controversy environment and how companies in the industry are managing risk.

Support the show

]]> In this TP Talks episode, Lauren Dangelmayr (Transfer Pricing Principal, PwC US), Hamish McElwee (Transfer Pricing Partner, PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), and Ivan Williams (Transfer Pricing Partner, PwC Canada) discuss the changing regulatory environment around the world and the impact on the oilfield services industry.  The speakers also discuss the controversy environment and how companies in the industry are managing risk.

Support the show

]]> PwC Buzzsprout-9731001 Thu, 16 Dec 2021 07:00:00 -0500 1319 transfer pricing, financial transactions, podcast, changing regulatory environment, managing risk, oilfield, Lauren Dangelmayr, Hamish McElwee, Szymon Wlazlowski, Ivan Williams 1 78 full false dana.hart@pwc.com (PwC)In this TP Talks episode, Lauren Dangelmayr (Transfer Pricing Principal, PwC US), Hamish McElwee (Transfer Pricing Partner, PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), and Ivan Williams (Transfer Pricing Partner, PwC Canada) discuss the changing regulatory environment around the world and the impact on the oilfield services industry.  The speakers also discuss the controversy environment and how companies in the industry are managing risk. Support the show Episode 77: Special Edition – Financial Transactions Transfer Pricing (September 2021) Episode 77: Special Edition – Financial Transactions Transfer Pricing (September 2021) This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico.

Support the show

]]> This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico.

Support the show

]]> PwC Buzzsprout-9482226 Wed, 03 Nov 2021 06:00:00 -0400 1611 transfer pricing, financial transactions, podcast, new world tax system, David Ledure, Lynn Tay, Fabien Fontaine, Edgar Ahrens 1 77 full false dana.hart@pwc.com (PwC)This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico. Support the show Episode 76: The new world tax system – what it means for your company Episode 76: The new world tax system – what it means for your company This episode features an excerpt from our recent Global Transfer Pricing Conference, discussing the OECD global tax agreement, where we are now and where things are heading.

Support the show

]]> This episode features an excerpt from our recent Global Transfer Pricing Conference, discussing the OECD global tax agreement, where we are now and where things are heading.

Support the show

]]> PwC Buzzsprout-9400822 Wed, 20 Oct 2021 06:00:00 -0400 983 transfer pricing, financial transactions, podcast, new world tax system, Ian Dykes, Giorgia Maffini, Will Morris 1 76 full false dana.hart@pwc.com (PwC)This episode features an excerpt from our recent Global Transfer Pricing Conference, discussing the OECD global tax agreement, where we are now and where things are heading. Support the show Episode 75: Pillar One update: details of the OECD/G20 Inclusive Framework Statement Episode 75: Pillar One update: details of the OECD/G20 Inclusive Framework Statement This TP Talks episode features a discussion of Pillar One transfer pricing issues related to the July 1 Statement by the OECD/G20 Inclusive Framework on BEPS on a two-pillar solution to address the taxation of the digitalization of the economy.

Support the show

]]> This TP Talks episode features a discussion of Pillar One transfer pricing issues related to the July 1 Statement by the OECD/G20 Inclusive Framework on BEPS on a two-pillar solution to address the taxation of the digitalization of the economy.

Support the show

]]> PwC Buzzsprout-9165070 Thu, 09 Sep 2021 06:00:00 -0400 2278 transfer pricing, financial transactions, podcast, Pillar One transfer pricing 1 75 full false dana.hart@pwc.com (PwC)This TP Talks episode features a discussion of Pillar One transfer pricing issues related to the July 1 Statement by the OECD/G20 Inclusive Framework on BEPS on a two-pillar solution to address the taxation of the digitalization of the economy. Support the show Episode 74: A dialog on German transfer pricing developments Episode 74: A dialog on German transfer pricing developments This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany.

Support the show

]]> This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany.

Support the show

]]> PwC Buzzsprout-8997876 Mon, 09 Aug 2021 06:00:00 -0400 1441 transfer pricing, financial transactions, podcast, 1 74 full false dana.hart@pwc.com (PwC)This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany. Support the show Episode 73: Financial Transactions Transfer Pricing – June 2021 Episode 73: Financial Transactions Transfer Pricing – June 2021 This Financial Transactions Transfer Pricing quarterly podcast features a discussion of the end of LIBOR, focusing on why and when the majority of LIBOR term rates will expire and the replacement rates; certain exceptions with regard to US dollar LIBOR tenors; the general tax and transfer pricing considerations; potential challenges converting from the old overnight LIBOR to the new overnight reference rates, and available options for reference rates with a longer maturity; developments across Asia-Pac region; and key takeaways.

Support the show

]]> This Financial Transactions Transfer Pricing quarterly podcast features a discussion of the end of LIBOR, focusing on why and when the majority of LIBOR term rates will expire and the replacement rates; certain exceptions with regard to US dollar LIBOR tenors; the general tax and transfer pricing considerations; potential challenges converting from the old overnight LIBOR to the new overnight reference rates, and available options for reference rates with a longer maturity; developments across Asia-Pac region; and key takeaways.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8782200 Tue, 29 Jun 2021 09:00:00 -0400 959 transfer pricing, financial transactions, podcast, US, audit, fttp, transfer pricing, LIBOR, 1 73 full false dana.hart@pwc.com (PwC)This Financial Transactions Transfer Pricing quarterly podcast features a discussion of the end of LIBOR, focusing on why and when the majority of LIBOR term rates will expire and the replacement rates; certain exceptions with regard to US dollar LIBOR tenors; the general tax and transfer pricing considerations; potential challenges converting from the old overnight LIBOR to the new overnight reference rates, and available options for reference rates with a longer maturity; developments across Asia-Pac region; and key takeaways. Support the show Episode 72: Domestic US Transfer Pricing - what state taxing authorities have on their agenda Episode 72: Domestic US Transfer Pricing - what state taxing authorities have on their agenda In this TP Talks podcast, Drew Kim (Partner, PwC’s State and Local Tax practice), Jana Lessne (Transfer Pricing Managing Director, PwC’s Washington National Tax Services), and Matthew Lindeman (Director, PwC’s State and Local Tax practice) discuss the current landscape related to domestic US transfer pricing, including how state tax authorities are looking to raise revenue and increasingly scrutinizing domestic intercompany transactions. They also highlight considerations for companies related to developing effective state audit defense strategies and provide key takeaways. 

Support the show

]]> In this TP Talks podcast, Drew Kim (Partner, PwC’s State and Local Tax practice), Jana Lessne (Transfer Pricing Managing Director, PwC’s Washington National Tax Services), and Matthew Lindeman (Director, PwC’s State and Local Tax practice) discuss the current landscape related to domestic US transfer pricing, including how state tax authorities are looking to raise revenue and increasingly scrutinizing domestic intercompany transactions. They also highlight considerations for companies related to developing effective state audit defense strategies and provide key takeaways. 

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8736829 Mon, 21 Jun 2021 06:00:00 -0400 1325 transfer pricing, financial transactions, podcast, US, audit, documentation 1 72 full false dana.hart@pwc.com (PwC)In this TP Talks podcast, Drew Kim (Partner, PwC’s State and Local Tax practice), Jana Lessne (Transfer Pricing Managing Director, PwC’s Washington National Tax Services), and Matthew Lindeman (Director, PwC’s State and Local Tax practice) discuss the current landscape related to domestic US transfer pricing, including how state tax authorities are looking to raise revenue and increasingly scrutinizing domestic intercompany transactions. They also highlight considerations for companies related to developing effective state audit defense strategies and provide key takeaways.  Support the show Episode 71: China transfer pricing updates – a focus on clarity and simplification Episode 71: China transfer pricing updates – a focus on clarity and simplification In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. For more information, see our Tax Insights: China issues Q&A regarding the administration on forex cash in-flows and out-flows of TP adjustments and China STA issues consultation draft on simplified procedure for unilateral APAs.

Support the show

]]> In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. For more information, see our Tax Insights: China issues Q&A regarding the administration on forex cash in-flows and out-flows of TP adjustments and China STA issues consultation draft on simplified procedure for unilateral APAs.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8519772 Fri, 14 May 2021 09:00:00 -0400 1150 transfer pricing, financial transactions, podcast 1 71 full false dana.hart@pwc.com (PwC)In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. For more information, see our Tax Insights: China issues Q&A regarding the administration on forex cash in-flows and out-flows of TP adjustments and China STA issues consultation draft on simplified procedure for unilateral APAs. Support the show Episode 70: Keeping pace with changes to UK transfer pricing documentation rules Episode 70: Keeping pace with changes to UK transfer pricing documentation rules This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider.

Support the show

]]> This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8376035 Wed, 21 Apr 2021 06:00:00 -0400 1296 transfer pricing, financial transactions, podcast 1 70 full false dana.hart@pwc.com (PwC)This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider. Support the show Episode 69: Financial Transactions Transfer Pricing – March 2021 Episode 69: Financial Transactions Transfer Pricing – March 2021 In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing.  The group also discusses debt capacity and controversy generally.

Support the show

]]> In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing.  The group also discusses debt capacity and controversy generally.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8247244 Wed, 31 Mar 2021 10:00:00 -0400 1697 transfer pricing, financial transactions, podcast 1 69 full false dana.hart@pwc.com (PwC)In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing.  The group also discusses debt capacity and controversy generally. Support the show Episode 68: Advance Pricing Arrangements – a reliable tool for managing TP risk on the path forward Episode 68: Advance Pricing Arrangements – a reliable tool for managing TP risk on the path forward In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan.  The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways. 

Support the show

]]> In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan.  The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways. 

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-8187754 Mon, 22 Mar 2021 10:00:00 -0400 1516 PwC, transfer pricing, automation, podcast 1 68 full false dana.hart@pwc.com (PwC)In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan.  The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways.  Support the show Episode 67: TP Automation – efficiencies for projects of any size Episode 67: TP Automation – efficiencies for projects of any size This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations.

Support the show

]]> This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-7897324 Tue, 16 Feb 2021 06:00:00 -0500 924 PwC, transfer pricing, automation, podcast 1 67 full false dana.hart@pwc.com (PwC)This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations. Support the show Episode 66: Financial Transactions Transfer Pricing – December 2020 Episode 66: Financial Transactions Transfer Pricing – December 2020 This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR.

Support the show

]]> This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-6948710 Mon, 21 Dec 2020 10:00:00 -0500 1357 PwC, transfer pricing, financial transactions, podcast 1 66 full false dana.hart@pwc.com (PwC)This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR. Support the show Episode 65: TP Readiness amid economic uncertainty – Using third-party behavior to support business decisions Episode 65: TP Readiness amid economic uncertainty – Using third-party behavior to support business decisions This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term.

Support the show

]]> This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-6895082 Thu, 17 Dec 2020 10:00:00 -0500 788 impact of the pandemic, economic disruption, transfer pricing, Diego Muro, Carolyn Fanaroff, Anthony Tufo 1 65 full false dana.hart@pwc.com (PwC)This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term. Support the show Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.

Support the show

]]> This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-6527683 Tue, 24 Nov 2020 05:00:00 -0500 1953 transfer pricing, oecd, pillar one, blueprint, 1 64 full false dana.hart@pwc.com (PwC)This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options. Support the show Episode 63: TP readiness amid economic uncertainty — Tax controversy: Is transfer pricing low hanging fruit for tax authorities? Episode 63: TP readiness amid economic uncertainty — Tax controversy: Is transfer pricing low hanging fruit for tax authorities? TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities? 

This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential transfer pricing audits.

Support the show

]]> TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities? 

This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential transfer pricing audits.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tax-controversy.html PwC Buzzsprout-6307006 Tue, 10 Nov 2020 09:00:00 -0500 1280 pwc, tp talks, episode 63, tax controversy 1 63 full false dana.hart@pwc.com (PwC)TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities?  This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential transfer pricing audits. Support the show Episode 62: TP readiness amid economic uncertainty: Comparability considerations and challenges Episode 62: TP readiness amid economic uncertainty: Comparability considerations and challenges In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate.

Support the show

]]> In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/comparability.html PwC Buzzsprout-5080730 Fri, 21 Aug 2020 10:00:00 -0400 1795 pwc, tp talks, episode 62, comparability 1 62 full false dana.hart@pwc.com (PwC)In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate. Support the show Episode 61: TP readiness amid economic uncertainty: Financial Transactions Episode 61: TP readiness amid economic uncertainty: Financial Transactions In this TP Talks Special Edition podcast, Bob Ritter (PwC US Financial Transactions Transfer Pricing Leader), Edwin Baghdasarayan (PwC Australia Transfer Pricing Partner), and Jessica Yin (PwC China Transfer Pricing Partner) discuss issues and solutions related to existing intercompany financing arrangements arising as a result of the pandemic, considerations for new intercompany financing arrangements, and some key main focus areas.

Support the show

]]> In this TP Talks Special Edition podcast, Bob Ritter (PwC US Financial Transactions Transfer Pricing Leader), Edwin Baghdasarayan (PwC Australia Transfer Pricing Partner), and Jessica Yin (PwC China Transfer Pricing Partner) discuss issues and solutions related to existing intercompany financing arrangements arising as a result of the pandemic, considerations for new intercompany financing arrangements, and some key main focus areas.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/financial-transactions.html PwC Buzzsprout-4670711 Thu, 23 Jul 2020 10:00:00 -0400 1612 tp talks, podcast, episode 61, pwc 1 61 full false dana.hart@pwc.com (PwC)In this TP Talks Special Edition podcast, Bob Ritter (PwC US Financial Transactions Transfer Pricing Leader), Edwin Baghdasarayan (PwC Australia Transfer Pricing Partner), and Jessica Yin (PwC China Transfer Pricing Partner) discuss issues and solutions related to existing intercompany financing arrangements arising as a result of the pandemic, considerations for new intercompany financing arrangements, and some key main focus areas. Support the show Episode 60: TP readiness amid economic uncertainty: Transfer pricing and policies Episode 60: TP readiness amid economic uncertainty: Transfer pricing and policies This TP Talks Special Edition podcast features a discussion of immediate, short, and long-term transfer pricing planning and controversy considerations in light of today’s business disruptions.

Support the show

]]> This TP Talks Special Edition podcast features a discussion of immediate, short, and long-term transfer pricing planning and controversy considerations in light of today’s business disruptions.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/transfer-pricing-policies.html PwC Buzzsprout-4045355 Tue, 09 Jun 2020 00:00:00 -0400 1075 episode 60, pwc, tp talks, transfer pricing, policies, june 2020 1 60 full false dana.hart@pwc.com (PwC)This TP Talks Special Edition podcast features a discussion of immediate, short, and long-term transfer pricing planning and controversy considerations in light of today’s business disruptions. Support the show Episode 59: TP readiness amid economic uncertainty: Customs and trade Episode 59: TP readiness amid economic uncertainty: Customs and trade In this podcast, Chris Desmond (PwC US Transfer Pricing Partner), Lionel Van Reet (PwC Belgium Customs and International Trade Partner), and Maytee Pereira (PwC US Customs and International Trade Managing Director) discuss transfer pricing and the interrelationship with customs and trade, focusing on the impact on consumer markets - markdown vs drawback optimization, managed margin and trade impact considerations, as well as key takeaways.

Support the show

]]> In this podcast, Chris Desmond (PwC US Transfer Pricing Partner), Lionel Van Reet (PwC Belgium Customs and International Trade Partner), and Maytee Pereira (PwC US Customs and International Trade Managing Director) discuss transfer pricing and the interrelationship with customs and trade, focusing on the impact on consumer markets - markdown vs drawback optimization, managed margin and trade impact considerations, as well as key takeaways.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/customs-trade.html PwC Buzzsprout-3673969 Mon, 11 May 2020 11:00:00 -0400 1273 tp talks, pwc podcast, transfer pricing, episode 59, customs and trade, tp readiness, economic uncertainty 1 59 full false dana.hart@pwc.com (PwC)In this podcast, Chris Desmond (PwC US Transfer Pricing Partner), Lionel Van Reet (PwC Belgium Customs and International Trade Partner), and Maytee Pereira (PwC US Customs and International Trade Managing Director) discuss transfer pricing and the interrelationship with customs and trade, focusing on the impact on consumer markets - markdown vs drawback optimization, managed margin and trade impact considerations, as well as key takeaways. Support the show Episode 58: TP readiness amid economic uncertainty: Operations and supply chain Episode 58: TP readiness amid economic uncertainty: Operations and supply chain In this podcast, Andrew Fairfoull (Transfer Pricing Partner, PwC Singapore), Stehan Rasch, (Transfer Pricing Partner, PwC Germany), Jie Hong Liao (Transfer Pricing Partner, PwC Singapore), and Marc Philipp, (Management Consulting Partner, PwC South East Asia Consulting) discuss how multinational corporations are responding to the business disruption from an operations and supply chain management perspective, as well as the transfer pricing aspects of operations and supply chain from a short and medium-term perspective.

Support the show

]]> In this podcast, Andrew Fairfoull (Transfer Pricing Partner, PwC Singapore), Stehan Rasch, (Transfer Pricing Partner, PwC Germany), Jie Hong Liao (Transfer Pricing Partner, PwC Singapore), and Marc Philipp, (Management Consulting Partner, PwC South East Asia Consulting) discuss how multinational corporations are responding to the business disruption from an operations and supply chain management perspective, as well as the transfer pricing aspects of operations and supply chain from a short and medium-term perspective.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/operations-and-supply-chain.html PwC Buzzsprout-3400180 Mon, 20 Apr 2020 15:00:00 -0400 1301 tp talks, podcast, pwc, big 4, readiness, economic uncertainty, operations 1 58 full false dana.hart@pwc.com (PwC)In this podcast, Andrew Fairfoull (Transfer Pricing Partner, PwC Singapore), Stehan Rasch, (Transfer Pricing Partner, PwC Germany), Jie Hong Liao (Transfer Pricing Partner, PwC Singapore), and Marc Philipp, (Management Consulting Partner, PwC South East Asia Consulting) discuss how multinational corporations are responding to the business disruption from an operations and supply chain management perspective, as well as the transfer pricing aspects of operations and supply chain from a short and medium-term perspective. Support the show Episode 57: Mexican tax reform from a transfer pricing perspective Episode 57: Mexican tax reform from a transfer pricing perspective In this podcast, PwC professionals discuss important transfer pricing considerations related to the General Anti-avoidance rule (GAAR), permanent establishment, new limitations on payments to “preferred regimes,” and reportable transactions.

Support the show

]]> In this podcast, PwC professionals discuss important transfer pricing considerations related to the General Anti-avoidance rule (GAAR), permanent establishment, new limitations on payments to “preferred regimes,” and reportable transactions.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/mexican-tax-reform-from-transfer-pricing-perspective.html Marta Milewska, Edgar Ahrens, Fernando Lorenzo, Mario Gutierrez, Lili Kazemi Buzzsprout-3286417 Fri, 10 Apr 2020 00:00:00 -0400 1628 episode 57, tptalks, mexican tax reform, transfer pricing, podcast, pwc 1 57 full false dana.hart@pwc.com (PwC)In this podcast, PwC professionals discuss important transfer pricing considerations related to the General Anti-avoidance rule (GAAR), permanent establishment, new limitations on payments to “preferred regimes,” and reportable transactions. Support the show Episode 56: TP readiness amid economic uncertainty - Liquidity and cash management Episode 56: TP readiness amid economic uncertainty - Liquidity and cash management In this podcast, PwC professionals discuss liquidity from a macroeconomic point of view, addresses current intercompany liquidity considerations, and consider the impact of the current economic environment on debt valuation and pricing.

Support the show

]]> In this podcast, PwC professionals discuss liquidity from a macroeconomic point of view, addresses current intercompany liquidity considerations, and consider the impact of the current economic environment on debt valuation and pricing.

Support the show

]]> https://www.pwc.com/gx/en/services/tax/transfer-pricing/podcasts/tp-readiness-amid-economic-uncertainty.html Paige Hill, Krishnan Chandrasekhar, and Dan Pybus Buzzsprout-3286369 Fri, 03 Apr 2020 00:00:00 -0400 828 tptalks, episode 56, tp readiness, economic uncertainty, liquidity, cash management 1 56 full false dana.hart@pwc.com (PwC)In this podcast, PwC professionals discuss liquidity from a macroeconomic point of view, addresses current intercompany liquidity considerations, and consider the impact of the current economic environment on debt valuation and pricing. Support the show Episode 55: Special Edition - Impact of OECD final FT paper - Americas region Episode 55: Special Edition - Impact of OECD final FT paper - Americas region


Support the show

]]>


Support the show

]]> Dan Pybus, Jeff Rogers, Bob Ritter, Marta Milewska, Ivon Marlen Saenz, and Jose Maria Segura https://download.pwc.com/gx/tp-podcasts/055-tptalks.mp3 Wed, 25 Mar 2020 20:00:00 -0400 2559 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 54: Special Edition - Impact of OECD final FT paper - Asia Pacific region Episode 54: Special Edition - Impact of OECD final FT paper - Asia Pacific region Support the show

]]> Support the show

]]> Edwin Baghdasarayan, Jessica Yin, Peter Brewin, Lynn Tay, Dan Pybus https://download.pwc.com/gx/tp-podcasts/054-tptalks.mp3 Sun, 08 Mar 2020 20:00:00 -0400 2201 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 53: Special Edition - Impact of OECD final FT paper - EMEA region Episode 53: Special Edition - Impact of OECD final FT paper - EMEA region Support the show

]]> Support the show

]]> Dan Pybus, David Ledure, J�rg H�lshorst, Omar Moerer, or Michael Butler https://download.pwc.com/gx/tp-podcasts/053-tptalks.mp3 Fri, 28 Feb 2020 07:00:00 -0500 2614 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 52: TP implications of the Final and Proposed BEAT regulations Episode 52: TP implications of the Final and Proposed BEAT regulations Support the show

]]> Support the show

]]> Paige Hill, Kartikeya Singh and Lili Kazemi https://download.pwc.com/gx/tp-podcasts/052-tptalks.mp3 Tue, 04 Feb 2020 07:00:00 -0500 1334 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 51: OECD proposal for profit allocation under Pillar One Episode 51: OECD proposal for profit allocation under Pillar One Support the show

]]> Support the show

]]> Isabel Verlinden, Giorgia Maffini, and Stephan Rasch https://download.pwc.com/gx/tp-podcasts/051-tptalks.mp3 Thu, 19 Dec 2019 07:00:00 -0500 1147 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 50: India transfer - what does the future hold? Episode 50: India transfer - what does the future hold? Support the show

]]> Support the show

]]> Kunj Vaidya and Manish Sabharwal https://download.pwc.com/gx/tp-podcasts/050-tptalks.mp3 Fri, 29 Nov 2019 07:00:00 -0500 1543 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 49: Latest developments in the Middle East transfer pricing landscape Episode 49: Latest developments in the Middle East transfer pricing landscape Support the show

]]> Support the show

]]> Mohamed Serokh, Saumyanil Deb https://download.pwc.com/gx/tp-podcasts/049-tptalks.mp3 Fri, 01 Nov 2019 08:00:00 -0400 1005 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 48: Key changes in Hong Kong transfer pricing Episode 48: Key changes in Hong Kong transfer pricing Support the show

]]> Support the show

]]> Cecilia SK Lee, Peter Brewin https://download.pwc.com/gx/tp-podcasts/048-tptalks.mp3 Tue, 22 Oct 2019 08:00:00 -0400 828 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 47: US transfer pricing - a review of top developments in 2019 Episode 47: US transfer pricing - a review of top developments in 2019 Support the show

]]> Support the show

]]> Paige Hill, Chris Desmond, Jozef Kavuliak, Lili Kazemi https://download.pwc.com/gx/tp-podcasts/047-tptalks.mp3 Thu, 19 Sep 2019 14:00:00 -0400 1419 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 46: Impact of today's issues on your transfer pricing Episode 46: Impact of today's issues on your transfer pricing Support the show

]]> Support the show

]]> Isabel Verlinden, Gaby Bes https://download.pwc.com/gx/tp-podcasts/046-tptalks.mp3 Fri, 16 Aug 2019 14:00:00 -0400 1477 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 45: ATO PCG on inbound distribution arrangements - what it means for multinationals operating in Australia Episode 45: ATO PCG on inbound distribution arrangements - what it means for multinationals operating in Australia Support the show

]]> Support the show

]]> Edwin Baghdasarayan, Sarah Stevens, Karim Rapha�l https://download.pwc.com/gx/tp-podcasts/045-tptalks.mp3 Tue, 16 Jul 2019 14:00:00 -0400 1296 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 44: Swiss tax reform - key transfer pricing considerations Episode 44: Swiss tax reform - key transfer pricing considerations Support the show

]]> Support the show

]]> Benjamin Koch, Armin Marti, Flora Marin https://download.pwc.com/gx/tp-podcasts/044-tptalks.mp3 Mon, 17 Jun 2019 14:00:00 -0400 941 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 43: Intra-group services in the post-BEPS era: A look at Japan and Vietnam Episode 43: Intra-group services in the post-BEPS era: A look at Japan and Vietnam Support the show

]]> Support the show

]]> Ken Kurokawa, Chihiro Takeuchi, James Radford, and Shimpei Imai https://download.pwc.com/gx/tp-podcasts/043-tptalks.mp3 Thu, 16 May 2019 14:00:00 -0400 572 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 42: BREXIT from a transfer pricing lens Episode 42: BREXIT from a transfer pricing lens Support the show

]]> Support the show

]]> Loic Webb-Martin, Susan Edwards, or Steven Brown https://download.pwc.com/gx/tp-podcasts/042-tptalks.mp3 Tue, 16 Apr 2019 14:00:00 -0400 1361 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 41: Taxing Digitalisation Episode 41: Taxing Digitalisation Support the show

]]> Support the show

]]> Aamer Rafiq, Will Morris, Gioriga Maffini https://download.pwc.com/gx/tp-podcasts/041-tptalks.mp3 Tue, 19 Mar 2019 14:00:00 -0400 2205 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 40: Special Edition - Digital solutions and transfer pricing - developments going on in the ERP landscape Episode 40: Special Edition - Digital solutions and transfer pricing - developments going on in the ERP landscape Support the show

]]> Support the show

]]> Lorenz Bernhardt, Jeroen Peerbooms, Jim Matthews https://download.pwc.com/gx/tp-podcasts/040-tptalks.mp3 Thu, 21 Feb 2019 13:00:00 -0500 892 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 39: Special Edition - Transfer pricing compliance - A look at TP documentation and CbC reporting Episode 39: Special Edition - Transfer pricing compliance - A look at TP documentation and CbC reporting Support the show

]]> Support the show

]]> Lorenz Bernhardt, Jim Matthews https://download.pwc.com/gx/tp-podcasts/039-tptalks.mp3 Wed, 20 Feb 2019 13:00:00 -0500 723 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 38: Draft TP By-Laws published in Saudi Arabia - a landmark moment Episode 38: Draft TP By-Laws published in Saudi Arabia - a landmark moment Support the show

]]> Support the show

]]> Mohamed Serokh, Lav Chadha, and Wael Osman https://download.pwc.com/gx/tp-podcasts/038-tptalks.mp3 Fri, 15 Feb 2019 13:00:00 -0500 1640 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 37: Transfer Pricing - catalyst or speedbump on the global trade highway? Episode 37: Transfer Pricing - catalyst or speedbump on the global trade highway? Support the show

]]> Support the show

]]> Isabel Verlinden, Jeff Yuan, William Marshall, and Pascal Janssens https://download.pwc.com/gx/tp-podcasts/037-tptalks.mp3 Wed, 16 Jan 2019 13:00:00 -0500 1147 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 36: US Transfer pricing - The year in review Episode 36: US Transfer pricing - The year in review


Support the show

]]>


Support the show

]]> Paige Hill, Jozef Kavuliak, and Chris Desmond https://download.pwc.com/gx/tp-podcasts/036-tptalks.mp3 Tue, 18 Dec 2018 13:00:00 -0500 1707 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 35: Special Edition - Big data and the global value chain Episode 35: Special Edition - Big data and the global value chain Support the show

]]> Support the show

]]> Lorenz Bernhardt, Stefaan de Baets https://download.pwc.com/gx/tp-podcasts/035-tptalks.mp3 Fri, 14 Dec 2018 13:00:00 -0500 723 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 34: Transforming and enabling the senior executive intercompany TP strategy Episode 34: Transforming and enabling the senior executive intercompany TP strategy Support the show

]]> Support the show

]]> Laura Ferine, Peter Pescatore, and Ben Brewer https://download.pwc.com/gx/tp-podcasts/034-tptalks.mp3 Thu, 15 Nov 2018 13:00:00 -0500 836 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 33: Special Edition - Guarantees Episode 33: Special Edition - Guarantees Support the show

]]> Support the show

]]> Jeff Rogers and Dan Pybus http://download.pwc.com/gx/tp-podcasts/033-tptalks-special-edition-guarantees.mp4 Tue, 16 Oct 2018 14:00:00 -0400 756 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 32: Special Edition - Cash Pooling Episode 32: Special Edition - Cash Pooling Support the show

]]> Support the show

]]> David Ledure, Michel van der Breggen and Dan Pybus https://download.pwc.com/gx/tp-podcasts/032-tptalks-special-edition-cash-pooling.mp4 Tue, 09 Oct 2018 14:00:00 -0400 936 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 31: Special Edition - Interest Rate Pricing Episode 31: Special Edition - Interest Rate Pricing Support the show

]]> Support the show

]]> Nick Houseman and Dan Pybus https://download.pwc.com/gx/tp-podcasts/031-tptalks-special-edition-interest-rate-pricing.mp4 Tue, 02 Oct 2018 14:00:00 -0400 1073 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 30: Special Edition - Delineation Episode 30: Special Edition - Delineation Support the show

]]> Support the show

]]> Krishnan Chandrasekhar and Dan Pybus https://download.pwc.com/gx/tp-podcasts/030-tptalks-special-edition-delineation.mp4 Tue, 25 Sep 2018 14:00:00 -0400 769 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 29: Special Edition - Captive Insurance Episode 29: Special Edition - Captive Insurance Support the show

]]> Support the show

]]> Loic Webb-Martin and Dan Pybus https://download.pwc.com/gx/tp-podcasts/029-tptalks-special-edition-captive-insurance.mp4 Tue, 18 Sep 2018 14:00:00 -0400 1050 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 28: Transfer pricing developments in Vietnam and Thailand Episode 28: Transfer pricing developments in Vietnam and Thailand Support the show

]]> Support the show

]]> Joseph Vu and Panachai Anontanut https://download.pwc.com/gx/tp-podcasts/028-tptalks-vietnam-thailand.mp3 Fri, 14 Sep 2018 14:00:00 -0400 714 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 27: Transfer Pricing Aspects of Financial Transactions in the post-BEPS era Episode 27: Transfer Pricing Aspects of Financial Transactions in the post-BEPS era Support the show

]]> Support the show

]]> Wouter Moelands, Kathryn O�Brien, Omar Moerer, and Daniel Pybus https://download.pwc.com/gx/tp-podcasts/027-tptalks-tp-aspects-of-ft-post-beps.mp3 Thu, 16 Aug 2018 14:00:00 -0400 1122 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 26: Building trust through transparency Episode 26: Building trust through transparency Support the show

]]> Support the show

]]> Eric Mehta, Blanca Kovari, and Andrew Packman https://download.pwc.com/gx/tp-podcasts/026-tp-podcast-transparency.mp3 Mon, 16 Jul 2018 14:00:00 -0400 818 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 25: Global reaction to US tax reform Episode 25: Global reaction to US tax reform Support the show

]]> Support the show

]]> Adam Katz, Lorenz Bernhardt, and Nick Houseman https://download.pwc.com/gx/tp-podcasts/025-tptalks-global-reaction-to-us-tax-reform.mp3 Fri, 15 Jun 2018 14:00:00 -0400 990 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 24: China and Hong Kong transfer pricing updates Episode 24: China and Hong Kong transfer pricing updates Support the show

]]> Support the show

]]> Paul Tang, Cecilia Lee, and Marjorie Zhang https://download.pwc.com/gx/tp-podcasts/024-tptalks-china-hk-tp-update.mp3 Tue, 29 May 2018 14:00:00 -0400 1555 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 23: US Tax reform and the impact on operating models Episode 23: US Tax reform and the impact on operating models Support the show

]]> Support the show

]]> Ken Kuykendall, Christine Saliba, Alex Voloskho, Rajiv Jetli https://download.pwc.com/gx/tp-podcasts/023-tptalks-op-models.mp3 Sat, 21 Apr 2018 14:00:00 -0400 1378 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 22: The new FDII provision Episode 22: The new FDII provision Support the show

]]> Support the show

]]> Michael DiFronzo, Hsuany Shan, Paige Hill, Michael Olecki https://download.pwc.com/gx/tp-podcasts/022-tptalks-fdii-03142018.mp3 Wed, 14 Mar 2018 14:00:00 -0400 472 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 21: Recent developments in Digital Taxation Episode 21: Recent developments in Digital Taxation Support the show

]]> Support the show

]]> Emma Purdy, Will Morris https://download.pwc.com/gx/tp-podcasts/021-tptalks-digital-taxation-022618.mp3 Tue, 06 Mar 2018 13:00:00 -0500 1212 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 20: Transfer Pricing trends and updates in Japan Episode 20: Transfer Pricing trends and updates in Japan Support the show

]]> Support the show

]]> Michael Polashek, Goro Mizushima, Ashlyn Kayoboke https://download.pwc.com/gx/tp-podcasts/020-tptalks-japantptrends-011918.mp3 Mon, 22 Jan 2018 13:00:00 -0500 864 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 19: Indian Master File Rules Episode 19: Indian Master File Rules Support the show

]]> Support the show

]]> Liz Sweigart, Kunj Vaidya https://download.pwc.com/gx/tp-podcasts/019-tptalks-indiamasterfile-121217.mp3 Mon, 18 Dec 2017 13:00:00 -0500 867 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 18: Digital Labor Episode 18: Digital Labor Support the show

]]> Support the show

]]> Michelle Lee, Mike Engle, Andrew Hwang https://download.pwc.com/gx/tp-podcasts/018-tptalks-digital-labor-090817.mp3 Fri, 08 Sep 2017 14:00:00 -0400 828 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 17: Tax Analytics - AI and Machine Learning Episode 17: Tax Analytics - AI and Machine Learning



Support the show

]]>



Support the show

]]> Bjarne Berg, Brian Burt https://download.pwc.com/gx/tp-podcasts/017-tptalks-ai-machine-learning-072717.mp3 Thu, 27 Jul 2017 14:00:00 -0400 580 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 16: Tax Analytics - Predictive Analytics Episode 16: Tax Analytics - Predictive Analytics Support the show

]]> Support the show

]]> Bjarne Berg, Teresa Peacock https://download.pwc.com/gx/tp-podcasts/016-tptalks-predictive-analytics-061917.mp3 Mon, 19 Jun 2017 14:00:00 -0400 689 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 15: Impact of VAT adoption in Middle East on Transfer Pricing Episode 15: Impact of VAT adoption in Middle East on Transfer Pricing Support the show

]]> Support the show

]]> Mohamed Serokh https://download.pwc.com/gx/tp-podcasts/015-tptalks-vat-and-tp-in-me-061317.mp3 Tue, 13 Jun 2017 14:00:00 -0400 499 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 14: BEPS Action 13 - Update on the complexities around related documentation requirements and importance of technology solutions Episode 14: BEPS Action 13 - Update on the complexities around related documentation requirements and importance of technology solutions Support the show

]]> Support the show

]]> Matias Pedevilla, Michael Walter, Ogniana Todorova, Brian Shaw https://download.pwc.com/gx/tp-podcasts/014-tptalks-beps-action-13-update-06082017.mp3 Fri, 02 Jun 2017 14:00:00 -0400 1065 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 13: Tax Analytics - The Art of the Possible Episode 13: Tax Analytics - The Art of the Possible Support the show

]]> Support the show

]]> Mike Moreland, Laurent Bellay, Anthony Tennariello https://download.pwc.com/gx/tp-podcasts/013-tptalks-art-of-the-possible-052317.mp3 Mon, 22 May 2017 14:00:00 -0400 937 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 12: Recent changes to Vietnam's Transfer Pricing regulations Episode 12: Recent changes to Vietnam's Transfer Pricing regulations Support the show

]]> Support the show

]]> Joseph Vu https://download.pwc.com/gx/tp-podcasts/012-tptalks-vietnam-podcast-041217.mp3 Wed, 12 Apr 2017 14:00:00 -0400 607 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 10: Impact of U.S. tax reform on Transfer pricing between the U.S. and Mexico - Part 1 Episode 10: Impact of U.S. tax reform on Transfer pricing between the U.S. and Mexico - Part 1 Support the show

]]> Support the show

]]> Raul Sicilia, Jorge Castellon, Mike Danilack https://download.pwc.com/gx/tp-podcasts/010-tptalks-tax-reform-podcast-0316170.mp3 Thu, 16 Mar 2017 14:00:00 -0400 1142 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 11: Impact of U.S. tax reform on Transfer pricing between the U.S. and Mexico - Part 2 Episode 11: Impact of U.S. tax reform on Transfer pricing between the U.S. and Mexico - Part 2 Support the show

]]> Support the show

]]> Raul Sicilia, Jorge Castellon, Mike Danilack https://download.pwc.com/gx/tp-podcasts/011-tptalks-tax-reform-podcast-0316170.mp3 Thu, 16 Mar 2017 14:00:00 -0400 971 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 9: Transfer Pricing challenges in the Technology sector Episode 9: Transfer Pricing challenges in the Technology sector Support the show

]]> Support the show

]]> Marios Karayannis, Matthew Haag https://download.pwc.com/gx/tp-podcasts/009-tp-podcast-technology-020417.mp3 Sat, 04 Feb 2017 13:00:00 -0500 648 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 8: The intersection of State Aid and Transfer Pricing Episode 8: The intersection of State Aid and Transfer Pricing Support the show

]]> Support the show

]]> Isabel Verlinden, Loek de Preter, Pieter Der�, Stefaan de Baets https://download.pwc.com/gx/tp-podcasts/008-state-aid-podcast-122116.mp3 Wed, 21 Dec 2016 13:00:00 -0500 1166 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 7: Country-by-Country Reporting and the ever increasing data transparency requirements Episode 7: Country-by-Country Reporting and the ever increasing data transparency requirements Support the show

]]> Support the show

]]> Jerry Klopfer, Liz Sweigart, Garrick Robinson https://download.pwc.com/gx/tp-podcasts/007-tp-podcast-country-by-country-data-121516.mp3 Wed, 14 Dec 2016 13:00:00 -0500 961 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 6: Food for Thought - Action 13 Today. Part 2 - Master file and Local file documentation Episode 6: Food for Thought - Action 13 Today. Part 2 - Master file and Local file documentation


Support the show

]]>


Support the show

]]> Matias Pedevilla, Ogniana Todorova, Michael Walter https://download.pwc.com/gx/tp-podcasts/006-tp-podcast-action-13-part-2-podcast-101816.mp3 Thu, 20 Oct 2016 14:00:00 -0400 843 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 5: Food for Thought - Action 13 Today. Part 1 - A global overview and Country-by-Country Reporting Episode 5: Food for Thought - Action 13 Today. Part 1 - A global overview and Country-by-Country Reporting Support the show

]]> Support the show

]]> Matias Pedevilla, Ogniana Todorova, Michael Walter https://download.pwc.com/gx/tp-podcasts/005-tp-podcast-action-13-part-1-podcast-101816.mp3 Wed, 19 Oct 2016 14:00:00 -0400 782 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 4: Recent Tax and Transfer Pricing trends and developments in the Middle East Episode 4: Recent Tax and Transfer Pricing trends and developments in the Middle East Support the show

]]> Support the show

]]> Mohamed Serokh https://download.pwc.com/gx/tp-podcasts/004-tp-podcast-middle-east-podcast-102016.mp3 Tue, 18 Oct 2016 14:00:00 -0400 510 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 3: Navigating Transfer Pricing Challenges in Asia with a focus on India and China Episode 3: Navigating Transfer Pricing Challenges in Asia with a focus on India and China Support the show

]]> Support the show

]]> Sanjay Tolia, Jeff Yuan, and Steven Tseng https://download.pwc.com/gx/tp-podcasts/003-tp-podcast-asia-tax-developments-101816.mp3 Mon, 17 Oct 2016 14:00:00 -0400 949 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 2: An overview of Value Chain Analysis Episode 2: An overview of Value Chain Analysis Support the show

]]> Support the show

]]> Steven Tseng and John Burgess https://download.pwc.com/gx/tp-podcasts/002-tp-podcast-overview-of-value-chain-analysis-100516.mp3 Wed, 05 Oct 2016 14:00:00 -0400 434 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show Episode 1: Insights on the new Chinese Transfer Pricing regulations Episode 1: Insights on the new Chinese Transfer Pricing regulations Support the show

]]> Support the show

]]> Jeff Yuan and Paul Tang https://download.pwc.com/gx/tp-podcasts/001-tp-podcast-new-chinese-tp-regulations-092816.mp3 Wed, 28 Sep 2016 14:00:00 -0400 1082 PwC,transfer,pricing,tax,consulting full false dana.hart@pwc.com (PwC)Support the show