Podcasts about Transfer pricing

Rules and methods for pricing transactions between enterprises under common ownership

  • 106PODCASTS
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  • Oct 1, 2025LATEST
Transfer pricing

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Best podcasts about Transfer pricing

Latest podcast episodes about Transfer pricing

Talking Tax
How Transfer Pricing Can Help Fix a Student Athlete Pay Problem

Talking Tax

Play Episode Listen Later Oct 1, 2025 12:39


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.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 117: Services or something more? Navigating blurred lines in transfer pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Sep 29, 2025 42:08


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

Talking Tax
Companies Face Tariff-Induced Transfer Pricing Audit Risks

Talking Tax

Play Episode Listen Later Sep 12, 2025 12:34


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.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 116: Special Edition – Financial Transactions Transfer Pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Sep 8, 2025 28:02


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 Talk
Transfer Pricing Update: Digging Into Facebook and Coca-Cola

Tax Notes Talk

Play Episode Listen Later Aug 22, 2025 16:21


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

Talking Tax
Pharmaceutical Companies Navigate Transfer Pricing as Tariffs Loom

Talking Tax

Play Episode Listen Later Aug 15, 2025 18:43


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.

EY talks tax
EY talks tax: BorderCrossings.. with EY transfer pricing and tax professionals (July 31, 2025)

EY talks tax

Play Episode Listen Later Aug 12, 2025 64:12


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.

The Capital Table
Transfer Pricing's Impact on M&A Transactions

The Capital Table

Play Episode Listen Later Aug 5, 2025 20:43


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. 

TP Talks - PwC's Global Transfer Pricing podcast
Episode 115: Ready or Not? Navigating the UK's next TP chapter

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Jul 31, 2025 33:46


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

Alter Everything
190: Alteryx Use Cases in the Tax Industry

Alter Everything

Play Episode Listen Later Jul 30, 2025 26:33


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.

PwC Deutschland Transfer Pricing Podcast
Neues Update Zoll & Transfer Pricing: Aktueller Stand und Handlungsoptionen

PwC Deutschland Transfer Pricing Podcast

Play Episode Listen Later Jul 18, 2025 39:28


In der aktuellen Podcast-Folge bieten Dr. Michael Tervooren, Partner und Leiter des PwC-Bereichs Zoll, Verbrauchsteuer und Exportkontrolle, sowie Christoph Richter, Director Transfer Pricing bei PwC Nürnberg, ein umfassendes Update zu den Entwicklungen im Zollstreit mit den USA seit letzter Woche.

PwC Deutschland Transfer Pricing Podcast
Update Zoll & Transfer Pricing: Aktueller Stand und Erfahrungen zu Handlungsoptionen

PwC Deutschland Transfer Pricing Podcast

Play Episode Listen Later Jul 11, 2025 57:34


In der neuesten Folge unseres Podcasts werfen Dr. Michael Tervooren, Partner und Leiter des PwC-Bereichs Zoll, Verbrauchsteuer und Exportkontrolle, und Christoph Richter, Director Transfer Pricing bei PwC Nürnberg, einen detaillierten Blick auf den aktuellen Stand im Zollstreit mit den USA. Sie beleuchten die jüngsten Entwicklungen und teilen wertvolle Erfahrungen zu den möglichen Handlungsoptionen, die Unternehmen in dieser herausfordernden Situation in Betracht ziehen können.

GILTI Conscience
Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion

GILTI Conscience

Play Episode Listen Later Jul 10, 2025 43:08 Transcription Available


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.

Talking Tax
What Latin America Can Teach About Tariffs, Transfer Pricing

Talking Tax

Play Episode Listen Later Jul 9, 2025 13:58


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.

EY talks tax
EY talks tax: BorderCrossings … with EY transfer pricing and tax professionals (May 29, 2025)

EY talks tax

Play Episode Listen Later Jun 7, 2025 66:15


In this episode, panelists continue their prior discussion on some of the technical aspects of Pillar One Amount A as well as the broader historical “formulary apportionment versus arm's length” debates. 

Podcast der hsp Handels-Software-Partner GmbH
Fremdvergleiche bei Transfer Pricing: Verrechnungspreisdokumentation erstellen, aber entspannter

Podcast der hsp Handels-Software-Partner GmbH

Play Episode Listen Later Jun 6, 2025 13:30


Fremdvergleiche bei Transfer Pricing: Verrechnungspreisdokumentation erstellen, aber entspannter Was Sie in diesem Artikel erwartet Die Anforderungen an die Verrechnungspreisdokumentation durch die Finanzbehörde sind heute streng wie noch nie. Betroffene Unternehmen sind angehalten, dem Thema Transfer Pricing die höchste Priorität einzuräumen. Doch die Erstellung einer Verfahrensdokumentation will gut vorbereitet sein, etwa durch [...] Der Beitrag Fremdvergleiche bei Transfer Pricing: Verrechnungspreisdokumentation erstellen, aber entspannter erschien zuerst auf hsp Handels-Software-Partner GmbH.

GILTI Conscience
Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards

GILTI Conscience

Play Episode Listen Later Jun 4, 2025 39:25 Transcription Available


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.

TP Talks - PwC's Global Transfer Pricing podcast
Special Edition – Financial Transactions Transfer Pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Jun 3, 2025 29:27


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

Weaver: Beyond the Numbers
Speciality Tax Spotlight - Domestic Transfer Pricing

Weaver: Beyond the Numbers

Play Episode Listen Later May 13, 2025 9:39


Weaver: Beyond the Numbers
Speciality Tax Spotlight - Domestic Transfer Pricing

Weaver: Beyond the Numbers

Play Episode Listen Later May 13, 2025 9:39


EY talks tax
EY talks tax: BorderCrossings … with EY transfer pricing and tax professionals (April 24, 2025)

EY talks tax

Play Episode Listen Later May 2, 2025 68:45


In this episode, panelists provide an update on OECD Pillar One and discuss what's next. 

BofA Global Research Podcasts
Medtech transfer pricing, a device for lower tax but higher tariffs

BofA Global Research Podcasts

Play Episode Listen Later May 1, 2025 19:20


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.

Accounting Best Practices with Steve Bragg
ABP #376 - Transfer Pricing

Accounting Best Practices with Steve Bragg

Play Episode Listen Later Apr 24, 2025 9:09


How transfer pricing works.

Future of Tax
Navigating regulatory shifts and effective responses to tax disputes in transfer pricing

Future of Tax

Play Episode Listen Later Apr 3, 2025 10:13


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.

GILTI Conscience
Navigating Permanent Establishments in International Tax Law

GILTI Conscience

Play Episode Listen Later Mar 25, 2025 64:55 Transcription Available


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.

Talking Tax
Tariffs Shake Up Companies' Transfer Pricing Planning

Talking Tax

Play Episode Listen Later Mar 12, 2025 24:32


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

EY talks tax
EY talks tax: BorderCrossings … with EY transfer pricing and tax professionals (February 27, 2025)

EY talks tax

Play Episode Listen Later Mar 10, 2025 68:26


In this episode, panelists provide updates on Canada and the OECD and discuss what the future might hold.  

PwC Africa Podcasts
Transfer Pricing and Management Services

PwC Africa Podcasts

Play Episode Listen Later Feb 17, 2025 24:33


In this episode, we discuss the transfer pricing considerations in the context of management services.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 112: Special Edition – Financial Transactions Transfer Pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Feb 14, 2025 20:01


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

Talking Tax
Companies Mull Gaps in Brazil's Transfer Pricing Rules

Talking Tax

Play Episode Listen Later Feb 12, 2025 10:58


Brazilian taxpayers and practitioners continue to clamor for more guidance on the country's new transfer pricing regime implemented last year. The country switched from a mathematical model to an arm's-length principle for transfer pricing last year, bringing it in line with global standards. That pivot left a lot of questions for the Receita Federal, the country's revenue authority, to answer through guidance, and it's been working to issue rules ever since. Most recently, Brazil issued instructions requiring extensive reporting and documentation of transactions involving commodities and how companies calculate their transfer pricing positions. Transfer pricing involves valuation of transactions between entities within a corporate group. Intragroup transactions must be conducted at arm's length—priced similarly to transactions between unrelated companies. The country's auditors are gearing up to enforce Brazil's new rules, sparking some concerns among practitioners that many new auditors will be learning on the job and that these early examinations won't go smoothly. RSM US senior tax manager Nina Baumbach spoke with reporter Caleb Harshberger about the changes and what they mean for companies. She said companies need more guidance and clarity from the government on intangibles and other topics. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Weaver: Beyond the Numbers
Specialty Tax Spotlight- Economic Substance and Impact on Transfer Pricing

Weaver: Beyond the Numbers

Play Episode Listen Later Jan 28, 2025 8:50


Weaver: Beyond the Numbers
Specialty Tax Spotlight - Economic Substance and Impact on Transfer Pricing

Weaver: Beyond the Numbers

Play Episode Listen Later Jan 28, 2025 8:50


Weaver: Beyond the Numbers
Transfer Pricing and the Foreign Exchange for Inbound Distributors

Weaver: Beyond the Numbers

Play Episode Listen Later Jan 13, 2025 8:33


Weaver: Beyond the Numbers
Podcast:How IC Discs and Transfer Pricing are the Tax-Saving Game Changers

Weaver: Beyond the Numbers

Play Episode Listen Later Jan 13, 2025 3:37


Welcome to the latest episode of Beyond the Numbers by Weaver, hosted by Vince Houk, the Partner-in-Charge of International Tax Services at Weaver. Joining him is the adept Josh Finfrock, Director of Transfer Pricing Services at Weaver, ready to decode the intricate relationship between the IC Disc regime and transfer pricing.Key Points:Transfer pricing is not just a compliance aspect, but can be strategic and provide opportunities for tax savings and efficient cash management.A strategic review of a company's global structure can help identify transfer pricing opportunities and range of outcomes in different locations.Weaver can assist companies in identifying transfer pricing opportunities and operating their business more efficiently, while also mitigating risks through a holistic view of the company's operations.At the heart of this discussion is the Intercompany Pricing Agreement, commonly referred to as the IC Disc regime, which promises significant tax savings for exporters. But how can one optimize these benefits? And where does transfer pricing fit into this puzzle?IC discs are export incentives that provider for permanent tax savings and can benefit all entities from corporations to partnerships. However, the way most companies have IC discs set up, transfer pricing is often not required and utilized, but companies can benefit tremendously when they do decide to use transfer pricing. "We can take segment by segment, different expenses, and find categories that we think may be over allocating expense to that segment, which is increasing the benefit of the disc when you can find those opportunities," Finfrock explained.Subscribe and listen to future episodes of Weaver: Beyond the Numbers on Apple Podcasts or Spotify.©2023

Weaver: Beyond the Numbers
Strategic Transfer Pricing is the Untapped Goldmine in U.S. Tax Savings and Global Operations

Weaver: Beyond the Numbers

Play Episode Listen Later Jan 13, 2025 4:56


On the latest episode of Beyond the Numbers by Weaver, host Vince Houk, Partner-in-Charge, International Tax Services at Weaver, delves deep into the world of strategic transfer pricing and how businesses can use it to their advantage. Joining him is Josh Finfrock, Director, Transfer Pricing Services at Weaver, an expert with a wealth of knowledge in the field. Key Points: One overlooked opportunity in utilizing FDII is to analyze the expense allocation with GNA expenses and allocate accordingly based on genuine benefit, which can help derive a better benefit. Other opportunities include looking at services provided by the U.S. company that may qualify for the FDII benefit and reviewing the IP structure to potentially move IP into the U.S. The U.S. provides a jurisdiction with substance, a good treaty network, and potentially lower tax rates compared to other countries, making it an attractive option for IP ownership and maintaining key operations. How can firms shift their perception and utilize transfer pricing as an asset rather than a burden? And what lies beyond the surface of transfer pricing, and how can businesses harness its potential to enhance their global operations? Clients often overlook how strategic transfer pricing can be and how it can be a tax saver and assist in cash management efficiency. For example, there is cash repatriation leakage that can be planned around with transfer pricing. Rate differentials between countries can be another challenge that transfer pricing adjustments can help save. Finfrock stated, “If we can do a strategic transfer pricing review with the company, we're going to come in and be able to look at, get a holistic view of the company, the global structure, understand where all the moving pieces are. That way, then we really know where those levers are, what our range of outcomes can be in different places, and then we can find those opportunities for savings.” Subscribe and listen to future episodes of Beyond the Numbers on Apple Podcasts or Spotify. ©2023

TP Talks - PwC's Global Transfer Pricing podcast
Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Jan 3, 2025 23:10


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

KPMG Tax Now
Intangible assets, transfer pricing and anti-avoidance - how did we get here?

KPMG Tax Now

Play Episode Listen Later Dec 17, 2024 39:03


With investment in intangible assets by multinational entities continuing to grow throughout the world, KPMG Australia's Peter Oliver - along with Jeremy Capes, Jennifer Ta, James Alsop and Rosie El Khoury - explore how companies are meeting their tax obligations when it comes to intangibles, such as software royalties, what cross-border issues are arising and current level of activity and guidance coming from tax administrators. For further updates, please register for KPMG Tax Now. 

TP Talks - PwC's Global Transfer Pricing podcast
Episode 110: Transfer Pricing in the Middle East: Opportunities abound

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Dec 10, 2024 34:58


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

EY talks tax
EY talks tax: BorderCrossings...with EY transfer pricing and tax professionals (October 31, 2024)

EY talks tax

Play Episode Listen Later Nov 21, 2024 64:55


In this episode, panelists discuss Loper Bright Enterprises v. Raimondo and provide an OECD update.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 109: Brazil's big shift: The new transfer pricing reality

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Nov 20, 2024 17:16


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

TP Talks - PwC's Global Transfer Pricing podcast
Episode 108: Special Edition – Financial Transactions Transfer Pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Nov 7, 2024 44:28


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

Simply Trade
How Transfer Pricing and Customs Valuation Can Make or Break Your Global Empire - Aprio

Simply Trade

Play Episode Listen Later Nov 7, 2024 37:15


Discover the critical intersection between #transferpricing and #customs #valuation , and how to navigate this complex landscape for optimal compliance. Join experts Carl and Jay as they share insights on aligning your pricing strategies, minimizing risks, and maximizing efficiency across your #globaloperations . Don't miss this essential #guide to optimizing your transfer pricing and customs valuation processes. Click to learn more!   Resources: Aprio - https://www.aprio.com/ Jay Cho - https://www.linkedin.com/in/jay-cho/ Carl Budenski - https://www.linkedin.com/in/carl-budenski/   Connect with Simply Trade Podcast: - Subscribe: https://www.youtube.com/channel/UCdmyGU5foKm4aFlpo7Oms4g?sub_confirmation=1 - LinkedIn: https://www.linkedin.com/showcase/simply-trade-podcast/ - Twitter: https://twitter.com/SimplyTradePod - Website: https://globaltrainingcenter.com/simply-trade-podcast/   Contact Us/ Suggest Topics Contact SimplyTrade@GlobalTrainingCenter.com   Credits: Host: Andy Shiles: https://www.linkedin.com/in/andyshiles/ Host/Producer: Lalo Solorzano: https://www.linkedin.com/in/lalosolorzano/ Co-Producer/Editor: Mara Marquez: https://www.linkedin.com/in/maramarquez85/

Eversheds Sutherland – Legal Insights (audio)
Tax Talk Episode 4 - Latest developments in Transfer Pricing

Eversheds Sutherland – Legal Insights (audio)

Play Episode Listen Later Nov 5, 2024 63:12


In our latest Tax Talk, Global tax team provides an update on both Pillars I and II and BEPS, and provides examples of practical approaches to preparing for and managing a tax audit, including US and European considerations. In addition, this program includes an overview of transfer pricing audit trends in the US and Europe, lessons learned, as well as a discussion on alternative dispute resolution mechanisms.

Climate Finance Podcast
Robert Eccles - Visiting Professor at Oxford University and Founding Chairman of SASB - Sustainability Accounting Standards Board

Climate Finance Podcast

Play Episode Listen Later Oct 12, 2024 57:31


Purchase the Climate Finance Course at www.climatefinancecourse.com Robert G. Eccles is a leading ESG integration academic focusing on sustainable corporate and investment strategies. His work focuses on how capital markets can contribute to ensuring a sustainable society for generations to come. Dr. Eccles is a Visiting Professor of Management Practice at the Said Business School, University of Oxford. He was a Tenured Professor at Harvard Business School. Eccles has also been a Visiting Lecturer at the Massachusetts Institute of Technology, Sloan School of Management, and a Berkeley Social Impact Fellow at the Haas School of Business, University of California, Berkeley. He was the founding chairman of the Sustainability Accounting Standards Board (SASB) and one of the founders of the International Integrated Reporting Council (IIRC). He is also the first Chair of KKR's “Sustainability Expert Advisory Council” and was an Eminent Academic Advisor to the Boston Consulting Group on Global ESG Integration and Reporting. He is notably a prolific commentator on Forbes, having published over 150 articles. Dr. Eccles received an S.B. in Mathematics and an S.B. in Humanities and Science from the Massachusetts Institute of Technology and an A.M. and Ph.D. in Sociology from Harvard University. Topics discussed: Dr. Eccles's early intellectual evolution was from studying mathematics and humanities at MIT to doing a Ph.D. in sociology focusing on the construction industry. How writing books on Transfer Pricing and Investment Banking Dealmaking earned Dr. Eccles tenureship at Harvard Business School. Transition from Academia to Consulting in Disclosure and Performance in the 1990s 1991: The Performance Measurement Manifesto 1992: Creating a Comprehensive System to Measure Performance 1993: Consulting: Has the Solution Become Part of the Problem? 1995: Improving the Corporate Disclosure Process Book Publications on Value & Integrated Reporting in the 2000s: 2001: The Value Reporting Revolution: Moving beyond the earnings game 2002: Building Public Trust: the Future of Corporate Reporting 2010: One Report: Integrated Reporting for a Sustainable Strategy Founding Leadership Journey with IIRC (International Integrated Reporting Council) and SASB (Sustainability Accounting Standards Board). Post-SASB Book Publication: The Integrated Reporting Movement: Meaning, Momentum, Motives, and Materiality (2014). Importance of Materiality: Materiality in Corporate Governance: The Statement of Significant Audiences and Materiality (2016). A Preliminary Analysis of SASB Reporting: Disclosure Topics, Financial Relevance, and the Financial Intensity of ESG Materiality (2020). How material is a material issue? Stock returns and the financial relevance and financial intensity of ESG materiality (2020). Thoughts on IIRC & SASB Consolidations to ISSB-IFRS A Debate At The Oxford Union: Should FASB And IASB Set Standards For Nonfinancial Information? (2018 - Forbes; SSRN).  The International Sustainability Standards Board As An Ideological Rorschach Test (2021 - Forbes). Historical Origins of ESG and Sustainability Reporting Exploring social origins in the construction of ESG measures (2018). The Social Origins of ESG: An Analysis of Innovest and KLD (2020) From “Who Cares Wins” To Pernicious Progressivism: 18 Years Of ESG (2022) Political Backlash and Regulation on ESG: Some Constructive Feedback To 23 Red States On Their Anti-ESG Campaigns (August 2023). A Color Spectrum Analysis Of The Redness Of 23 Red States (July 2023). Written Statement for the House Financial Services Committee June 12, 2023 Hearing entitled "Protecting Investor Interests: Examining Environmental and Social Policy in Financial Regulation" Anti-ESG Fund Analysis: Drilling Into DRLL's Top 10 Holdings: A Woke Analysis (2022) Global SDG Funding Gap: How to close the $2.5 trillion annual funding gap (Jan 2018).  $2.5trn in need is not $2.5trn in opportunities (September 2023). Advice to Future ESG and Sustainable Finance Academics, Practitioners, Financiers, and Investors. Note: This podcast is for informational purposes only and should not be considered as investment advice. The interview took place on 26 September 2023.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Oct 9, 2024 32:24


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

The Brainy Business | Understanding the Psychology of Why People Buy | Behavioral Economics
431. Is Your Work Worth It? Exploring Purpose with Christopher Wong Michelson

The Brainy Business | Understanding the Psychology of Why People Buy | Behavioral Economics

Play Episode Listen Later Sep 25, 2024 48:34


In this episode of The Brainy Business podcast, host Melina Palmer welcomes Christopher Wong Michelson, co-author of Is Your Work Worth It?. Christopher, a philosopher with 25 years of experience advising business leaders, explores the profound questions surrounding the meaning and value of work. With a PhD in philosophical ethics and aesthetics, Christopher has held significant roles at PwC and academic positions at the Wharton School and NYU's Stern School of Business. His extensive background provides a rich foundation for exploring how work contributes to our sense of purpose and identity. Throughout the episode, Christopher shares insights from his journey, including his transition from academia to management consulting, and the experiences that shaped his understanding of meaningful work. He discusses the impact of 9/11 on people's perceptions of work and life, and how the pandemic has similarly prompted many to reassess their professional and personal priorities. The conversation touches on the philosophical aspects of work, the balance between job, career, and calling, and the inherent trade-offs in pursuing meaningful work. In this episode, you will learn: The philosophical questions that drive our understanding of work's meaning. How significant events like 9/11 and the pandemic shape our perceptions of work. The balance between job, career, and calling, and their impact on our lives. The concept of "transfer pricing" in personal and professional life. Strategies for finding balance and fulfillment in your work. Show Notes: 00:00:00 - Introduction, Melina introduces Christopher Wong Michelson, co-author of Is Your Work Worth It? and sets the stage for a discussion on the philosophical aspects of work. 00:02:30 - Christopher's Background and Journey Christopher shares his journey from academia to management consulting and his experiences at PwC and various academic institutions. 00:10:45 - The Impact of 9/11 and the Pandemic Discussion on how significant events like 9/11 and the pandemic have prompted people to reassess their work and life priorities. 00:18:32 - The Question of Work's Worth Christopher delves into the central question of the book, Is Your Work Worth It? and the importance of finding meaning in work. 00:25:54 - Job, Career, and Calling Exploration of the different orientations towards work and the trade-offs involved in pursuing a calling. 00:34:06 - Transfer Pricing in Personal and Professional Life Christopher explains the concept of transfer pricing and how it can be applied to balance personal and professional investments. 00:40:22 - Finding Balance and Fulfillment Strategies for incorporating meaningful activities into your work and life to achieve balance and fulfillment. 00:46:15 - Advice for Organizational Leaders Tips for leaders on how to create meaningful work environments that encourage employees to find value and purpose in their roles. 00:50:30 - Conclusion What stuck with you while listening to the episode? What are you going to try? Come share it with Melina on social media -- you'll find her as @thebrainybiz everywhere and as Melina Palmer on LinkedIn. Thanks for listening. Don't forget to subscribe on Apple Podcasts or Android. If you like what you heard, please leave a review on iTunes and share what you liked about the show.  I hope you love everything recommended via The Brainy Business! Everything was independently reviewed and selected by me, Melina Palmer. So you know, as an Amazon Associate I earn from qualifying purchases. That means if you decide to shop from the links on this page (via Amazon or others), The Brainy Business may collect a share of sales or other compensation. Let's connect: Melina@TheBrainyBusiness.com The Brainy Business® on Facebook The Brainy Business on Twitter The Brainy Business on Instagram The Brainy Business on LinkedIn Melina on LinkedIn The Brainy Business on Youtube Connect with Christopher: LinkedIn Christopher's Website Learn and Support The Brainy Business: Check out and get your copies of Melina's Books.  Get the Books Mentioned on (or related to) this Episode: Good Habits, Bad Habits, by Wendy Wood Indistractable, by Nir Eyal How to Change, by Katy Milkman Happier Hour, by Cassie Holmes Is Your Work Worth It?, by Christopher Wong Michaelson and Jennifer Tosti-Kharas Top Recommended Next Episode: Nick Hobson Interview (ep 382) Already Heard That One? Try These:  Habits (ep 256) Status Quo Bias (ep 376) Tapping into the Power of Habit (ep 368) Wendy Wood Interview (ep 428) Sludge (ep 384) Other Important Links:  Brainy Bites - Melina's LinkedIn Newsletter

TP Talks - PwC's Global Transfer Pricing podcast
Episode 106: CbCR: The evolving landscape

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Aug 14, 2024 35:29


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.

TP Talks - PwC's Global Transfer Pricing podcast
Episode 105: Special Edition – Financial Transactions Transfer Pricing

TP Talks - PwC's Global Transfer Pricing podcast

Play Episode Listen Later Jun 19, 2024 40:59


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

GILTI Conscience
Dissecting Cross-Border Transfer Pricing Resolutions with Clark Armitage

GILTI Conscience

Play Episode Listen Later May 7, 2024 36:36 Transcription Available


The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing disputes. Associates Eman Cuyler and Stefane Victor joined the discussion as well.

Exploring Transfer Pricing
How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?

Exploring Transfer Pricing

Play Episode Listen Later Mar 20, 2024 14:23


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).