TP Talks - PwC's Global Transfer Pricing podcast

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 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 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 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 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 Marcelo Vieira to discuss the progress of Brazil's overhaul of its transfer pricing regime.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

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

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

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

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), 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

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

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) 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, 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

FTTP Q2 2023:  Debt capacity and transfer pricingIn 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

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

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 TrackerSupport the show

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

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 SlatterySupport 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

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 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 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 decreeContacts: David Ernick, Niek van der Put, Neil Schaatsbergen, Aleks DavydovSupport 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

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 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 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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

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.html)

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.html)

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.html)

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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

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.html)