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 showBởi 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,…

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 atte…

This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the showBởi 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 lan…

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 …

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 th…

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 profession…

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 …

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 chang…

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 lev…

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 Part…

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 …

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 …

Here, a few best practices for 2022 that every transfer pricing professional should embrace. CrossBorder SolutionsBởi CrossBorder Solutions

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. Cro…

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…

This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico. Support the showBởi 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 showBởi PwC

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…

Global tax reform is underway, creating a new framework that comes with constant contradictions. On today's episode, Dr. Lorraine Eden returns to discuss her takeaways from proposals to tax only the 'top 100' companies in Pillar One negotiations. CrossBorder SolutionsBởi CrossBorder Solutions

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

Part two of our series on BEPS 2.0. This episode is recorded in Arabic.Bởi PwC Middle East Transfer Pricing team

Part two of our mini series on BEPS 2.0. This episode is recorded in EnglishBởi PwC Middle East Transfer Pricing team

This episode is recorded in EnglishBởi PwC Middle East Transfer Pricing team

Part 1 is recorded in ArabicBởi PwC Middle East Transfer Pricing team

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. C…

CrossBorder Chief Economist Mimi Song and transfer pricing expert Johann Muller take a closer look at the impacts of COVID-19 for low-risk distributors. Should these entities be able to absorb losses? Listen here to find out. CrossBorder SolutionsBởi CrossBorder Solutions

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…

Getting the world to agree on a global tax plan is no easy job. This podcast discussion reveals what’s triggering global tax debates, and how MNEs can avoid getting caught in the middle. CrossBorder SolutionsBởi CrossBorder Solutions

This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany. Support the showBởi PwC

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.…

This episode explores the landmark Glencore versus the Australian Taxation Office case, and what it means for the future of compliance. Former ATO member Geoff Morris and CrossBorder Solutions’ Director Solutions Engineer Doug Darling discuss CrossBorder SolutionsBởi CrossBorder Solutions

Chief Economist Mimi Song joins University of Connecticut Professor of Law Richard Pomp to examine Amazon’s latest win against the European Commission and the key transfer pricing takeaways for multinationals. CrossBorder SolutionsBởi CrossBorder Solutions

Chief Economist Mimi Song defines key tax terms, from tax scrutiny to “the race to the bottom,” and explains how they translate in the global tax conversation. CrossBorder SolutionsBởi CrossBorder Solutions

Why did the Italian Supreme Court administer two different rulings on inter-company transactions? What can taxpayers learn from it? Chief Economist Mimi Song and University of Ferrara Professor of Law Marco Greggi discuss. CrossBorder SolutionsBởi CrossBorder Solutions

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. CrossBorder So…

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…