The Fiona Show

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On the Fiona Show, we discuss current issues in the transfer pricing world. Whether you’re new to transfer pricing, or you’ve been around the international tax block, learn about the latest trends in the global regulatory environment and technology in one weekly podcast.

CrossBorder Solutions


    • Jan 12, 2022 LATEST EPISODE
    • infrequent NEW EPISODES
    • 51m AVG DURATION
    • 240 EPISODES


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    Latest episodes from The Fiona Show

    Episode 117: Transfer Pricing New Year's Resolutions

    Play Episode Listen Later Jan 12, 2022 49:50


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

    Episode 117: Transfer Pricing New Year's Resolutions

    Play Episode Listen Later Jan 12, 2022 49:50


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

    Episode 116: Tax Transparency in the U.S.

    Play Episode Listen Later Dec 8, 2021 32:01


    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.

    Episode 116: Tax Transparency in the U.S.

    Play Episode Listen Later Dec 8, 2021 32:01


    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. CrossBorder Solutions

    Episode 115: India's Faceless Audits

    Play Episode Listen Later Nov 19, 2021 43:28


    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 for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination.

    Episode 115: India's Faceless Audits

    Play Episode Listen Later Nov 19, 2021 43:28


    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 for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination. CrossBorder Solutions

    Episode 114: Taking Stock of Stock Based Compensation

    Play Episode Listen Later Oct 6, 2021 55:38


    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 companies can do about them. CrossBorder Solutions

    Episode 114: Taking Stock of Stock Based Compensation

    Play Episode Listen Later Oct 6, 2021 55:38


    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 companies can do about them.

    Episode 113: Taxing the Top 100

    Play Episode Listen Later Sep 14, 2021 67:56


    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 Solutions

    Episode 113: Taxing the Top 100

    Play Episode Listen Later Sep 14, 2021 67:56


    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.

    Episode 112: Germany's Increased Scrutiny

    Play Episode Listen Later Aug 24, 2021 64:58


    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. CrossBorder Solutions

    Episode 112: Germany's Increased Scrutiny

    Play Episode Listen Later Aug 24, 2021 64:58


    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.

    Episode 111: COVID's Impact on Limited-Risk Distributors

    Play Episode Listen Later Aug 17, 2021 51:21


    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.

    Episode 111: COVID's Impact on Limited-Risk Distributors

    Play Episode Listen Later Aug 17, 2021 51:21


    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 Solutions

    Introducing The Fiona Show: R&D Tax Credit

    Play Episode Listen Later Aug 12, 2021 1:59


    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, and lead to paradigm-shifting discoveries across industries. If you don't know R&D tax incentives, you may be part of the tragic majority leaving money on the table. Explore the back catalog of The Fiona Show: R&D Tax Credit to level up your tax knowledge, and subscribe to stay ahead on the latest in global innovation and the tax incentives that very likely come with it.

    Introducing The Fiona Show: R&D Tax Credit

    Play Episode Listen Later Aug 12, 2021 1:59


    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, and lead to paradigm-shifting discoveries across industries. If you don't know R&D tax incentives, you may be part of the tragic majority leaving money on the table. Explore the back catalog of The Fiona Show: R&D Tax Credit to level up your tax knowledge, and subscribe to stay ahead on the latest in global innovation and the tax incentives that very likely come with it. CrossBorder Solutions

    Episode 110: The Impending Global Tax Reform

    Play Episode Listen Later Aug 10, 2021 52:53


    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.

    Episode 110: The Impending Global Tax Reform

    Play Episode Listen Later Aug 10, 2021 52:53


    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 Solutions

    Episode 109: EU Inches Closer to Public Country-by-Country Reporting 

    Play Episode Listen Later Aug 3, 2021 50:55


    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.

    Episode 109: EU Inches Closer to Public Country-by-Country Reporting 

    Play Episode Listen Later Aug 3, 2021 50:55


    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. CrossBorder Solutions

    Episode 108: What Multinationals Need to Know About the ATO

    Play Episode Listen Later Jul 27, 2021 66:12


    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 Solutions

    Episode 108: What Multinationals Need to Know About the ATO

    Play Episode Listen Later Jul 27, 2021 66:12


    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

    Episode 107: A Transfer Pricing Legal Case in its Prime 

    Play Episode Listen Later Jul 20, 2021 55:50


    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.

    Episode 107: A Transfer Pricing Legal Case in its Prime 

    Play Episode Listen Later Jul 20, 2021 55:50


    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 Solutions

    Episode 106: Enriching Your Tax Vocabulary

    Play Episode Listen Later Jul 13, 2021 62:48


    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.

    Episode 106: Enriching Your Tax Vocabulary

    Play Episode Listen Later Jul 13, 2021 62:48


    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 Solutions

    Episode 105: Italy's Mixed Messages

    Play Episode Listen Later Jul 6, 2021 57:35


    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.

    university mixed messages italian supreme court
    Episode 105: Italy's Mixed Messages

    Play Episode Listen Later Jul 6, 2021 57:35


    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 Solutions

    university italy mixed messages italian supreme court
    Episode 104: Denmark's Increased Scrutiny

    Play Episode Listen Later Jun 29, 2021 50:17


    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 Solutions

    Episode 104: Denmark's Increased Scrutiny

    Play Episode Listen Later Jun 29, 2021 50:17


    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.

    Episode 103: Tech and Tax: What's Everyone So Mad About?

    Play Episode Listen Later Jun 22, 2021 43:06


    What's the relationship between tech and tax? How will the Biden administration's latest tax proposals impact U.S. tech giants? Chief Economist Mimi Song and Vice President of Global Projects at the Tax Foundation Daniel Bunn unpack these questions and more. CrossBorder Solutions

    Episode 103: Tech and Tax: What's Everyone So Mad About?

    Play Episode Listen Later Jun 22, 2021 43:06


    What's the relationship between tech and tax? How will the Biden administration's latest tax proposals impact U.S. tech giants? Chief Economist Mimi Song and Vice President of Global Projects at the Tax Foundation Daniel Bunn unpack these questions and more.

    Episode 102: The G7's Global Minimum Tax Announcement and What it Means for Transfer Pricing

    Play Episode Listen Later Jun 15, 2021 57:33


    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 prepare.

    Episode 102: The G7's Global Minimum Tax Announcement and What it Means for Transfer Pricing

    Play Episode Listen Later Jun 15, 2021 57:33


    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 prepare. CrossBorder Solutions

    Episode 101: Audits on the Rise in Vietnam

    Play Episode Listen Later Jun 8, 2021 48:15


    Over the last two years, few jurisdictions have heightened their transfer pricing scrutiny with the enthusiasm of Vietnam. CrossBorder Solutions Chief Economist Mimi Song and Duke University professor Eddy Malesky discuss how MNEs can brace themselves for impact. CrossBorder Solutions

    Episode 101: Audits on the Rise in Vietnam

    Play Episode Listen Later Jun 8, 2021 48:15


    Over the last two years, few jurisdictions have heightened their transfer pricing scrutiny with the enthusiasm of Vietnam. CrossBorder Solutions Chief Economist Mimi Song and Duke University professor Eddy Malesky discuss how MNEs can brace themselves for impact.

    Episode 100: Our 100th Episode!

    Play Episode Listen Later Jun 1, 2021 53:05


    How much do we love transfer pricing? Every single of the 100 episodes that make up 'The Fiona Show: Transfer Pricing' podcast lets us count the ways, but to celebrate our centennial episode, we boiled down 10 essential lessons our guests have taught us about how transfer pricing is an art -- not a science. 

    Episode 100: Our 100th Episode!

    Play Episode Listen Later Jun 1, 2021 53:05


    How much do we love transfer pricing? Every single of the 100 episodes that make up 'The Fiona Show: Transfer Pricing' podcast lets us count the ways, but to celebrate our centennial episode, we boiled down 10 essential lessons our guests have taught us about how transfer pricing is an art -- not a science.  CrossBorder Solutions

    Episode 99: The Value of the Value Chain Analysis

    Play Episode Listen Later May 25, 2021 60:57


    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. CrossBorder Solutions

    Episode 99: The Value of the Value Chain Analysis

    Play Episode Listen Later May 25, 2021 60:57


    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.

    Episode 98: HMRC Crackdown

    Play Episode Listen Later May 18, 2021 50:06


    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 more scrutiny.

    Episode 98: HMRC Crackdown

    Play Episode Listen Later May 18, 2021 50:06


    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 more scrutiny. CrossBorder Solutions

    Episode 97: The Biden Tax Plan and Its Effect on Low-Tax Jurisdictions

    Play Episode Listen Later May 11, 2021 58:22


    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.

    Episode 97: The Biden Tax Plan and Its Effect on Low-Tax Jurisdictions

    Play Episode Listen Later May 11, 2021 58:22


    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. CrossBorder Solutions

    Episode 96: Joint Audits and Transfer Pricing

    Play Episode Listen Later May 4, 2021 57:54


    CrossBorder Solutions Chief Economist Mimi Song and Dr. Diana Criclivaia discuss everything you need to know about joint audits, and why they're rising in prevalence. CrossBorder Solutions

    Episode 96: Joint Audits and Transfer Pricing

    Play Episode Listen Later May 4, 2021 57:54


    CrossBorder Solutions Chief Economist Mimi Song and Dr. Diana Criclivaia discuss everything you need to know about joint audits, and why they're rising in prevalence.

    Episode 95: The EU Commission and State Aid Cases

    Play Episode Listen Later Apr 27, 2021 54:40


    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 cases against the biggest household names among MNEs.

    Episode 95: The EU Commission and State Aid Cases

    Play Episode Listen Later Apr 27, 2021 54:40


    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 cases against the biggest household names among MNEs. CrossBorder Solutions

    Episode 94: Fiscal Year 2020 and Transfer Pricing Compliance in 2021

    Play Episode Listen Later Apr 20, 2021 59:08


    Anticipating the tax scrutiny for FY 2020, CrossBorder Solutions Chief Economist Mimi Song offers her expert strategies for helping MNEs stay compliant in her latest article in Treasury and Risk.

    Episode 94: Fiscal Year 2020 and Transfer Pricing Compliance in 2021

    Play Episode Listen Later Apr 20, 2021 59:08


    Anticipating the tax scrutiny for FY 2020, CrossBorder Solutions Chief Economist Mimi Song offers her expert strategies for helping MNEs stay compliant in her latest article in Treasury and Risk. CrossBorder Solutions

    Episode 93: Transfer Pricing & Tariffs

    Play Episode Listen Later Apr 13, 2021 57:46


    As the last few years have shown, tariffs can have a big impact on a multinational's transfer pricing. CrossBorder Solutions Chief Economist Mimi Song and transfer pricing expert Hasker Hoogenberg discuss recent trends and the ways Customs enforcement agencies look at their jobs differently than international tax authorities.

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