DiscoverTP Talks - PwC's Global Transfer Pricing podcast
TP Talks - PwC's Global Transfer Pricing podcast
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TP Talks - PwC's Global Transfer Pricing podcast

Author: PwC

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PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.

119 Episodes
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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 provi...
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
Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions. Support the show
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
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 n...
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 ra...
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 wha...
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 c...
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 discus...
This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1 Support 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), 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 pre...
This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show
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