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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 …
 
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 env…
 
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 t…
 
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 rec…
 
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 i…
 
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. T…
 
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 …
 
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, focus…
 
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 showBởi 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 Aust…
 
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 …
 
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) di…
 
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 …
 
Since the introduction of BEPS, "tax transparency" has become a buzz phrase around the globe. What does transparency look like in the U.S.? And how is the IRS beefing up efforts to promote it here at home? In this episode of The Fiona Show, transfer pricing expert and former IRS competent authority analyst, Barbara Mantegani makes it all clear.…
 
With the introduction of faceless audits in India last year, a new era in tax transparency appears to have dawned – and just in time to compensate for a global lockdown. Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law, joins today's Fiona Show podcast to discuss what the practice could mean fo…
 
Stock based compensation is a way of paying company members with equity in the business, which is great for companies and employees. From a transfer pricing perspective, however, it can cause problems. Here, David Chamberlain of California Polytechnic State University-San Luis Obispo explains some of the issues that can arise and what multinational…
 
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 showBởi PwC
 
Germany's recent compliance initiatives are picking up more speed than the Autobahn. On today's episode, CrossBorder Solutions Tax Director Hasker Hoogenberg and independent German-based transfer pricing specialist Oliver Treidler examine the transforming audit environment in Germany, and how MNEs can insulate themselves from further examination.…
 
We know you love our expert coverage of the transfer pricing landscape, but did you know we bring that same level of informative analysis to the world of research and development tax incentives? On The Fiona Show: R&D Tax Credit, we—along with leading tax experts—explore how these incentives reward companies for innovation, fuel economic growth, an…
 
Public country-by-country reporting is very close to becoming a reality in the European Union. How would this transparency initiative impact multinationals and the global tax community? CrossBorder Solutions’ Transfer Pricing Director Pamesh Sharma and Queen Mary University of London Tax Law Professor Christiana HJI Panayi explore the implications.…
 
The Danish Tax Authority’s recent win against Tetra Pak Processing Systems can only mean one thing: increased scrutiny for taxpayers. Chief Economist Mimi Song and international corporate income tax expert Johann Muller analyze how the Tetra Pak win could bolster the tax authority’s confidence, leading to a likely increase in audits.…
 
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…
 
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…
 
It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best…
 
The value chain analysis is essential for planning and defending a multinational's transfer pricing. International corporate income tax expert Johann Muller joins CrossBorder Solutions Chief Economist Mimi Song on today's episode to answer every question on value chains and transfer pricing you're too afraid to ask.…
 
With new initiatives by the HMRC to claim the £34 billion that it says MNEs owe the UK in unpaid taxes, the message to taxpayers is painstakingly clear: transfer pricing compliance in the UK is an order, not a request. CrossBorder Chief Economist Mimi Song and UK-based transfer pricing expert Pamesh Sharma talk about how MNEs can best prepare for m…
 
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 Consu…
 
CrossBorder Solutions Director of International Tax Michael Desimone joins Chief Economist Mimi Song to discuss what the Biden administration's 'Made in America' tax plan has in store for MNEs, especially those with operations in low-tax jurisdictions.Bởi CrossBorder Solutions
 
While the EU Commission cannot determine tax rates for individual jurisdictions, they do have other weapons in their arsenal to fight BEPS. David Chamberlain, assistant professor of Accounting and Tax at California Polytechnic State University, joins CrossBorder Solutions Chief Economist Mimi Song to discuss the commission's deluge of state aid cas…
 
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