Exploring Transfer Pricing

Beyond Controversy: The collaborative landscape of transfer pricing disputes. In the complex world of transfer pricing, setting the right price for intercompany transactions is both a science and a subjective process. But how does this play out in the face of international disputes? Where do treaty-based resolutions like the Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) fit into this puzzle? And just how pivotal are these tools in providing certainty and preventing double taxation? Join our host, Brittany Hardin Tanguay, as she navigates this fascinating discussion with Lillie Sullivan (Senior Manager, KPMG US: Washington National Tax - Controversy and Dispute Resolution), and Joshua McConkey (Managing Director, KPMG US: Washington National Tax Controversy and Dispute Resolution).

Cupid's arrow has struck the heart of many curious people, leading them to transfer pricing. Prepare to be smitten as we delve into the hearts of multiple transfer pricing professionals, the matchmakers of the corporate world, who work to harmonize the rhythm of regulatory compliance with the melody of business objectives in a symphony of economic strategy. Whether it was love at first sight or a slow-burning passion, their stories are a testament to the dynamic, challenging, and rewarding nature of a career in transfer pricing. So, grab a box of chocolates and join us as we pen a love letter to transfer pricing, and perhaps inspire the next generation of romantics in this crucial and captivating sector of the global economy. In this very special episode of Exploring Transfer Pricing, our host Brittany Hardin Tanguay revisits some of her heartfelt conversations with previous guests of the program, including Robin Archer (Director, KPMG UK), Enrique Martin (Principal, KPMG US), Sayantani Ghose (Principal, KPMG US), Diana Shkodina (Principal, KPMG US), Nick Stavrakis (Managing Director, KPMG US), Brad Parker (Principal, KPMG US), and David Unger (Managing Director, KPMG US).

Charting out the OECD's 2022 Mutual Agreement Procedure (MAP) Statistics to appreciate how effective MAP is in resolving transfer pricing disputes. The OECD released the 2022 Mutual Agreement Procedure (MAP) Statistics and announced its much heralded MAP Awards, the Transfer Pricing equivalent of the Oscars. When a multinational is subject to a transfer pricing adjustment, MAP is a process the taxpayer can invoke to avoid double taxation. The MAP statistics provide multinationals with important insights into how well MAP relationships are working. Our host Brittany Hardin Tanguay is joined by Phil Roper, a Partner from KPMG UK, and Thomas Bettge, a Senior Manager in Washington National Tax, to discuss their impressions from the latest release of MAP Statistics.

Our host Brittany Hardin Tanguay is joined by Maggie Fritz, a Tax Principal and the global banking leader for transfer pricing, and Brie Siciliano, a Managing Director for Tax specializing in financial services. Together, they'll unravel the complexities that the banking industry encounters when enacting transfer pricing.

2023 has been a rollercoaster in the world of international tax and transfer pricing - and 2024 looks to be more of the same. As 2023 draws to a close, we delve into the key tax initiatives that have shaped the transfer pricing landscape over the past year. This episode navigates through topics ranging from the OECD's Pillar One and Pillar Two, to the adoption of the OECD Guidelines by Brazil and the impact of economic uncertainty and evolving business models on transfer pricing. Our host Brittany Hardin Tanguay is joined by Jessie Coleman, a Principal in Washington National Tax, to discuss highlights from the previous year, as well as the challenges and opportunities that lie ahead in the realm of transfer pricing.

Hammering out transfer pricing challenges in the building, construction, and real estate industry. Building on our Transfer Pricing Industries Series, we have constructed an episode on the specialized transfer pricing issues faced by the building, construction, and real estate, BCRE, industry. The uniqueness of the underlying assets influence how transactions are valued, and how to price the associated transactions around it. With a large diversity in the types of transactions and assets, transfer pricing practitioners must rely more heavily on sound economic principles. Our host Brittany Hardin Tanguay is joined by Weston Krider, a KPMG Transfer Pricing Managing Director based in Los Angeles and rejoined by Sharon Liu, a KPMG Transfer Pricing Principal in Economic and Valuation Services to discuss some of the key issues of transfer pricing within the building and construction industry.

Our host Brittany Hardin Tanguay is joined by Stephen Giordano, KPMG Partner, Washington National Tax, focused on Business Tax Services - Passthroughs, and Sharon Liu, KPMG Principal, Tax - Transfer Pricing, to discuss some of the key issues of transfer pricing within the REITs realm.

Our host Brittany Hardin Tanguay is joined by Diane Shkodina, Managing Director, Tax - Transfer Pricing, and Nick Stavrakis, Managing Director, Tax - Transfer Pricing to discuss the challenges transfer pricing practitioners are facing with developing an arm's-length transfer pricing range for North American retail distribution companies and beyond

Going Dutch on testing financial transactions! In this episode we explore the Chapter 10 OECD Guidelines involving financial transactions with our KPMG Netherlands colleagues. The Netherlands has long been known as a financial services transaction hub and integral for multinational enterprises' treasury functions - why has this historically been the case? What are some of the major transfer pricing issues involving these Dutch financial entities? How does the Dutch Tax Authority reconcile the OECD Guidelines vs. Dutch Tax Laws? What role does risk play in determining the type of financial entity? If you are interested in financial services hubs, OECD Guidelines, and beautiful fields of never-ending tulips, strap on your clogs!

If Amount B is supposed to simplify transfer pricing, why does it seem so complicated? Listen as we break it down. In this episode we explore the major announcement regarding Amount B released this week by the OECD with our KPMG knowledge leader from London. On Monday July 17, we got the latest update from the OECD on its efforts to simplify transfer pricing through Amount B, part of its BEPS 2.0 initiative to address the tax challenges of digitalization. What will this mean for multi-nationals cross-border transaction, transfer pricing policy, and future transfer pricing planning? Will Amount B actually apply to digital businesses? With all of the news regarding Amount B, we will break down the announcement and address some of the potential implications.

Your transfer pricing is in good hands, because we've seen a situation or two. The insurance industry and its representatives exist to make people's bad days less bad. Insurance provides protection for what matters most, but how do you transfer price for managing risk? If you're unsure how reinsurance works for cross-border intercompany transactions, we've got you covered! As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.

Why can't all my profit just go to an offshore haven? KPMG explains Asset Management transfer pricing in a post-BEPS world. Investment committees, sub-advisors and referral fees - Oh My! How should asset management tax practices battle the nuances of splitting highly lucrative asset management returns across their global footprints? In an industry which faces commercial pressure, non-tax regulators, and a minefield of BEPS exclusions, navigating the specific intercompany relationships within asset management may seem daunting. Tax authorities are taking very different approaches to the asset management industry, and conquering the compliance and planning opportunities has never been more timely. As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.

Perform a check-up on your company's financial health before stressing it with debt. We've established that everybody borrows, meaning that multinational enterprises in every industry are likely to engage in some level of intercompany financing. But how is it actually done? What parts of the business need to work together, and what considerations often get overlooked when setting interest rates on these loans between related parties? Join us to learn more, and to appreciate some of the nuances that must be reflected in each transfer pricing analysis. Resources: KPMG Transfer Pricing

Listen in to learn why some subsidiaries can be viewed as the black sheep of the family, while others as the next in line to run the business. Contacts: Sayantani Ghose Bob Clair Brittany Hardin Tanguay