Podcasts about Transfer pricing

In this episode, panelists examine several trade issues of interest to transfer pricing practitioners, including the current and evolving state of global trade policy, the intersection of transfer pricing and customs valuation rules, and controversy involving the combination of customs and transfer pricing.

Kristina Novak and John Cianfrone sit down with Mona Cairncross for an inside look at global transfer pricing negotiations and lessons from her time as Assistant Director of the IRS APMA Program.Support the show

Jo Crookshank and Kapisha Vyas continue discussing the relationship between transfer pricing adjustments and VAT, following the decision of the CJEU in Stellantis Portugal but without the clarity we were all hoping for. 

Transfer pricing is one of the most important concepts in corporate finance, international tax, and multinational business strategy. In this episode of Corporate Finance Explained, we break down how multinational corporations allocate profits across countries, how profit shifting works, and why transfer pricing disputes involving Apple, Coca-Cola, Amazon, Microsoft, and Starbucks have reshaped global tax policy.You'll learn how transfer pricing works, how the arm's length principle is applied, and why OECD BEPS rules, Country-by-Country Reporting, and Pillar Two are changing the future of international taxation and corporate finance.This episode explores:• What transfer pricing is and why multinational corporations use it• The arm's length principle explained• OECD transfer pricing methods and profit allocation• How Apple structured profits through Ireland• Why Coca-Cola, Amazon, Microsoft, and Starbucks faced tax disputes• OECD BEPS and Country-by-Country Reporting rules• Pillar Two and the global minimum corporate tax• Why economic substance now matters more than tax arbitrage• How transfer pricing impacts valuation, treasury, FP&A, and corporate strategyIf you work in corporate finance, accounting, investment banking, FP&A, tax, treasury, consulting, or multinational operations, understanding transfer pricing is becoming increasingly important as global tax enforcement evolves.Chapters:00:00 Introduction01:45 What transfer pricing actually is04:20 The arm's length principle explained07:10 OECD transfer pricing methods09:20 Apple's €13B EU tax case12:05 Amazon, Starbucks, Coca-Cola, and Microsoft disputes16:00 OECD BEPS and Country-by-Country Reporting19:30 Pillar Two and the global minimum tax21:15 What finance professionals should do nowSubscribe for more videos on corporate finance, valuation, financial modeling, capital markets, accounting, and global business strategy.

This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement.Support the show

New Tax Bites episode out now! Pieter sits down with transfer pricing experts Ann and Brecht, and legal expert Véronique, to explore the changing Belgian TP audit landscape. Discover what happened to the traditional February audit "wave", how audits are evolving and which companies and topics are being targeted. Get practical tips on prevention, managing the audit process, and resolving transfer pricing disputes.Have a look at all our previous episodes and stay up to date on www.pwc.be/tax-bites

This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments.Support the show

In this episode, panelists discuss transfer pricing trends, issues and developments for 2026, including Mutual Agreement Procedures, trends in transfer pricing controversy in the United States, Europe and Asia-Pacific, and policy developments around the taxation of the digital economy.

Wie sieht eine Karriere im Global Tax Umfeld wirklich aus? Was steckt hinter Begriffen wie International Tax und Transfer Pricing – und welche Skills brauchst du, um in diesem komplexen, internationalen Umfeld erfolgreich zu sein? In dieser Folge von career to go ist Dr. Dominik Probst zu Gast, Senior Manager bei Grant Thornton Germany, Steuerberater, Fachberater für Internationales Steuerrecht und Experte für Transfer Pricing. Gemeinsam sprechen wir darüber, wie der Arbeitsalltag in diesem Bereich aussieht, warum internationales Steuerrecht für Unternehmen so relevant ist und wie du den Einstieg in dieses spannende Feld schaffst.

Jo Crookshank and Kapisha Vyas discuss the relationship between transfer pricing adjustments and VAT, focusing on the recent CJEU cases, Arcomet Towercranes and Stellantis Portugal.

The Supreme Court's decision to nix a wide swath of the Trump administration's tariffs comes with some big tax and transfer pricing questions for tax executives as companies battle to collect refunds from the government. The court's 6-3 ruling sets up what would be a messy refund process, though the justices basically said nothing about it, leaving companies to take their claims to court. If the refunds come in, businesses will have to figure out how to apportion funds across subsidiaries —sometimes across borders — without breaking transfer pricing rules, which govern the pricing of affiliate transactions and ultimately determine where taxes are owed. The rules say related-party transfers must be priced as though they were done at arm's length, in the open marketplace. Companies that don't do it right risk a tax agency audit. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses the sticky tax and transfer pricing issues surrounding tariffs and the possibility of refunds. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like “fixed place of business”. The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts. The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.See omnystudio.com/listener for privacy information.

While the Supreme Court has ruled that President Donald Trump's use of the 1977 International Emergency Economic Powers Act to impose tariffs is unconstitutional, experts warn that the administration has other means to extract from American businesses and consumers what would amount to import taxes. Space businesses are not immune, but they do have opportunities to shield their bottom lines. Laura Winter speaks with Bailey Reichelt, Founder and Attorney at Aegis Law; and Nick Baker, Managing Director of Transfer Pricing practice, and co-Lead of the Trade and Customs practice at Kroll.

This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks.Support the show

In this episode, panelists discuss how tax and trade policy changes that occurred in 2025 and are anticipated in 2026 might affect cross-border transactions and how to navigate those changes.

We're off for the New Year holiday, so we're serving up an encore presentation of a Talking Tax podcast about challenges with paying student athletes. Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. The athletes can now be compensated for their name, image, and likeness—or NIL—but schools still can't directly pay them for playing. Instead, athletes can receive compensation when merchandise with their name or number is sold, or for showing up in advertisements or social media posts for businesses. But the line between legitimate NIL and illegitimate pay-for-play can get blurry. On this episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kristina Novak is joined by Nick Houseman, PwC Australia's Transfer Pricing Leader, to discuss Australia's tax and transfer pricing enforcement landscape.Support the show

Episode: Simply Trade #413 Hosts: Andy Shiles & Lalo Solorzano Guest(s): Alex Martin, Transfer Pricing Specialist, KBKG Published: December 18, 2025 Length: ~37 minutes Presented by: Global Training Center Episode Summary Tariffs have changed everything — and many companies are still missing the second-order effects. In this episode, Andy and Lalo sit down with Alex Martin of KBKG to unpack one of the most misunderstood (and increasingly risky) intersections in global trade: transfer pricing and customs valuation. As tariffs rise from single digits to 25%, 50%, and beyond, decisions once made solely by tax or finance teams now carry massive customs consequences. Alex explains how multinational companies are getting “whipsawed” between Customs and the IRS — one pushing values up for duty, the other pushing values down for income tax. This conversation makes one thing crystal clear: customs, tax, finance, and compliance can no longer operate in silos. Whether you're an importer, trade compliance professional, CFO, or tax leader, this episode highlights why cross-functional coordination is now essential — not optional. Key Takeaways Transfer pricing impacts both customs duties and income tax — often in conflicting ways Rising tariffs have turned valuation into a material financial risk, not an academic exercise Customs looks at transactions line-by-line, while tax authorities focus on annual results CFOs and tax directors must now actively engage with trade compliance teams Poor coordination can increase audit risk, cash-flow pressure, and margin erosion Programs like FTZs, bonded warehouses, drawback, and cost bifurcation can help mitigate exposure Asking for transfer pricing documentation is a powerful first step for trade teams Who Needs to Be at the Table? This episode stresses the importance of assembling a multi-disciplinary team, including: Trade Compliance Tax & Transfer Pricing Finance / CFO leadership Accounting (AP / AR) Pricing & Sourcing International affiliates and parent companies If tariffs have changed your margins, they've already changed your tax picture — whether you've addressed it or not.  

A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026. President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits. At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards. That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing.Support the show

David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues.Support the show

Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. While the athletes can now be compensated for their name, image, and likeness—or NIL—schools still can't directly pay them for playing, and the NCAA has rejected any notion of "pay-for-play." Instead, athletes can receive compensation when merchandise with their name or number is sold or for showing up in advertisements or social media posts for businesses. But the line between NIL and pay-for-play can get blurry. A business owner who wants to support the team could overpay an athlete in an NIL deal, raising a question: Is it a bona fide business deal? On this week's episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can help show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.Support the show

President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit. Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties. The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good. These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures. In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

In this podcast, PwC's David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.Support the show

Tax Notes contributing editor Ryan Finley discusses the current transfer pricing landscape, including where things stand in the Facebook and Coca-Cola cases. For more coverage, read the following from Finley in Tax Notes:Analysis: The CUT Method: It's Not What It Used to BeAnalysis: The CUT Method: Same as It Ever Was?Analysis: On Periodic Adjustments, Facebook Opinion Suggests A Middle RoadAnalysis: For the IRS, Facebook Is a Reminder to Stick to the ScriptAnalysis: Medtronic II: Do the Transfer Pricing Regs Swallow Themselves? Follow us on X:Ryan Finley: @RyanMFinleyDavid Stewart: @TaxStewTax Notes: @TaxNotes**CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Pharmaceutical companies are scrambling to respond to the Trump administration's tariff threats, seeking to mitigate duties on their products while keeping the impact on their tax bills to a minimum.   The industry has long leveraged complex transfer pricing arrangements to cut down on its tax bills, but now the looming tariffs could spark a major rethink for where companies make their drugs and the location of their crown jewel: the intellectual property. Pharmaceuticals were exempt from the initial wave of tariffs announced earlier this year, but subsequent months have seen threats of heavy fines and taxes from the administration and a looming national security investigation, which could result in heavy duties on the industry.   In this week's Talking Tax podcast, Cronus Consulting founder Nick Shipley talked with reporter Caleb Harshberger about how pharmaceutical companies are navigating the chaos, and what it could mean for their tax planning and operations. Shipley is a consultant for the pharmaceutical industry. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

This episode focuses on tariffs. Panelists give an update on the administration's trade policy, examine how trade policy impacts cross-border movements of products and intellectual property, and discuss the role of tax and transfer pricing in duty-management activities.

In this episode, host Steve Brady, Market Leader of Transaction Advisory at Withum, is joined by Marina Gentile, Lead of Global Transfer Pricing Strategies, and Boris Pogil, Tax Senior Manager. Together, they explore the key impacts and challenges of transfer pricing in M&A transactions. 

Kristina Novak (Principal in PwC's US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government's proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC's expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today.Support the show

Unlock the power of Alteryx for tax professionals in this insightful episode of Alter Everything! Join us in an interview with Adrian Steller, Director of Tax Technology at Ryan, to explore how Alteryx revolutionizes tax processes, automates data workflows, and enhances efficiency for tax teams. Discover real-world Alteryx use cases in VAT compliance, transfer pricing, and automation, and learn practical tips for transitioning from Excel to Alteryx. Whether you're a tax analyst, data professional, or business leader, this episode provides actionable insights on leveraging Alteryx for tax data transformation, reporting, and analytics.Panelists: Adrian Steller, Director @ International Tax Technology - LinkedInMegan Bowers, Sr. Content Manager @ Alteryx - @MeganBowers, LinkedInShow notes: Ryan (Company)Ryan Tax Lab (Podcast)Alteryx Community BlogsAlteryx Help Docs Interested in sharing your feedback with the Alter Everything team? Take our feedback survey here!This episode was produced by Megan Bowers, Mike Cusic, and Matt Rotundo. Special thanks to Andy Uttley for the theme music.

Changes in the luxury fashion industry are reshaping transfer pricing considerations, says Giuseppe Abatista vice president at Banca Popolare di Puglia e Basilicata. In this conversation with Skadden tax partner David Farhat and associate Stefane Victor, Giuseppe shares his insights about how price increases, supply chain centralization and tariff uncertainties are creating new transfer pricing complexities in an industry known for high profitability and strong IP.

Multinational corporations have been hustling to make sense of the flurry of US tariff policy changes this year, and figure out how to factor that into their transfer pricing. One place that's been in this situation before: Latin America. For decades, companies there have been navigating tariffs and the impacts on their tax planning—including transfer pricing, or how companies value transactions between their related entities. This week on the Talking Tax podcast, Webridge Technology Global Tax Adviser Hernan Katz talks about the lessons companies can take away from the experience of Latin American countries. These include making sure staff across departments are working together to tackle issues of trade and transfer pricing, how tax authorities try to crack down on companies they suspect aren't following the rules, and explaining how intercompany dealings are motivated by business reasons—not tax or trade. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Machado Meyer tax partner Fernando Colucci joins Skadden's David Farhat, Loren Ponds, Eman Cuyler and Stefane Victor to explore Brazil's historic shift from a 27-year formulaic transfer pricing system to full OECD compliance. As he explains, “We moved from a very strict, very formulaic approach to a simple, a direct import of the arm's-length principle.” Tune in for his insights on dramatic changes facing multinational enterprises and Brazil's notorious 75% penalty system that raises the stakes on compliance decisions.

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

Looming tariffs lead to renewed focus on transfer pricing Multinational companies have used transfer pricing as a way to reduce tax bills. Transferring a product from a lower tax jurisdiction allows profits to be taxed at the lower corporate rate, so a higher price can mean greater tax savings. But tariffs would be based on the higher price, meaning that some of the same companies using this practice to lower tax bills will also face higher levies. Travis Steed discusses what this means for medtech, the impact transfer pricing has had on tax rates, whether practices could change under a tariff regime and why the group is still a compelling, defensive investment   You may also enjoy listening to the Merrill Perspectives podcast, featuring conversations on the big stories, news and trends affecting your everyday financial life.   "Bank of America" and “BofA Securities” are the marketing names for the global banking businesses and global markets businesses (which includes BofA Global Research) of Bank of America Corporation. Lending, derivatives, and other commercial banking activities are performed globally by banking affiliates of Bank of America Corporation, including Bank of America, N.A., Member FDIC. Securities, trading, research, strategic advisory, and other investment banking and markets activities are performed globally by affiliates of Bank of America Corporation, including, in the United States, BofA Securities, Inc. a registered broker-dealer and Member of FINRA and SIPC, and, in other jurisdictions, by locally registered entities. ©2025 Bank of America Corporation. All rights reserved.

How transfer pricing works.

Future of Tax & Legal podcast episode featuring: Cameron Taheri, Global Leader for Transfer Pricing Dispute Resolution, KPMG International, and Principal, Washington National Tax at KPMG in the US, and Graeme Webster, Transfer Pricing Partner at KPMG in the UK.

When goods, services and rights go back and forth within a company, how do you attribute profit or loss to one part of the company versus another? Former OECD head of tax treaties and transfer pricing Mary Bennett and EY's Mike McDonald join this episode of “GILTI Conscience” for a detailed discussion on the attribution of profits to permanent establishments. Skadden tax partners David Farhat and Nate Carden and associate Stefane Victor host the discussion, which explores, among other topics, critical differences between Articles 7 and 9 of the OECD Model Tax Convention and why these distinctions matter for multinational businesses.

Tax departments at multinational companies are scrambling to keep up with the Trump administration's tariff announcements as the updates pile in day to day and sudden shifts complicate transfer pricing calculations. Tariffs raise companies' costs, and those can't always be passed on to consumers—meaning businesses have to choose where to allocate the costs in their supply chains. While the importing entity pays the tariffs, the company can adjust the transfer price to pass that cost to other, related entities. That can present opportunities to reduce the impact of tariffs—but also may lead to risks of audits from tax and customs agencies. And with so much unknown, it's become hard for companies to find tax certainty, said Summer Austin, partner at Baker McKenzie. Austin and Baker McKenzie partner Jennifer Revis talked to Bloomberg Tax reporter Caleb Harshberger about what the tariffs mean for transfer pricing and how companies should respond. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

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