The Fiona Show: Transfer Pricing

CrossBorder Solutions•www.crossborder.ai

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

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Episodes

Episode 117: Transfer Pricing New Year's Resolutions

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

Jan 12, 2022•50 min0

Episode 116: Tax Transparency in the U.S.

Since the introduction of BEPS, "tax transparency" has become a buzz phrase around the globe. What does transparency look like in the U.S.? And how is the IRS beefing up efforts to promote it here at home? In this episode of The Fiona Show, transfer pricing expert and former IRS competent authority analyst, Barbara Mantegani makes it all clear. CrossBorder Solutions

Dec 08, 2021•32 min0

Episode 115: India's Faceless Audits

With the introduction of faceless audits in India last year, a new era in tax transparency appears to have dawned – and just in time to compensate for a global lockdown. Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law, joins today's Fiona Show podcast to discuss what the practice could mean for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination. CrossBorder Solutions...

Nov 19, 2021•43 min0

Episode 114: Taking Stock of Stock Based Compensation

Stock based compensation is a way of paying company members with equity in the business, which is great for companies and employees. From a transfer pricing perspective, however, it can cause problems. Here, David Chamberlain of California Polytechnic State University-San Luis Obispo explains some of the issues that can arise and what multinational companies can do about them. CrossBorder Solutions

Oct 06, 2021•56 min0

Episode 113: Taxing the Top 100

Global tax reform is underway, creating a new framework that comes with constant contradictions. On today's episode, Dr. Lorraine Eden returns to discuss her takeaways from proposals to tax only the 'top 100' companies in Pillar One negotiations. CrossBorder Solutions

Sep 14, 2021•1 hr 8 min0

Episode 112: Germany's Increased Scrutiny

Germany's recent compliance initiatives are picking up more speed than the Autobahn. On today's episode, CrossBorder Solutions Tax Director Hasker Hoogenberg and independent German-based transfer pricing specialist Oliver Treidler examine the transforming audit environment in Germany, and how MNEs can insulate themselves from further examination. CrossBorder Solutions

Aug 24, 2021•1 hr 5 min0

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

CrossBorder Chief Economist Mimi Song and transfer pricing expert Johann Muller take a closer look at the impacts of COVID-19 for low-risk distributors. Should these entities be able to absorb losses? Listen here to find out. CrossBorder Solutions

Aug 17, 2021•51 min0

Introducing The Fiona Show: R&D Tax Credit

We know you love our expert coverage of the transfer pricing landscape, but did you know we bring that same level of informative analysis to the world of research and development tax incentives? On The Fiona Show: R&D Tax Credit, we—along with leading tax experts—explore how these incentives reward companies for innovation, fuel economic growth, and lead to paradigm-shifting discoveries across industries. If you don’t know R&D tax incentives, you may be part of the tragic majority leaving money ...

Aug 12, 2021•2 min0

Episode 110: The Impending Global Tax Reform

Getting the world to agree on a global tax plan is no easy job. This podcast discussion reveals what’s triggering global tax debates, and how MNEs can avoid getting caught in the middle. CrossBorder Solutions

Aug 10, 2021•53 min0

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

Public country-by-country reporting is very close to becoming a reality in the European Union. How would this transparency initiative impact multinationals and the global tax community? CrossBorder Solutions’ Transfer Pricing Director Pamesh Sharma and Queen Mary University of London Tax Law Professor Christiana HJI Panayi explore the implications. CrossBorder Solutions

Aug 03, 2021•51 min0

Episode 108: What Multinationals Need to Know About the ATO

This episode explores the landmark Glencore versus the Australian Taxation Office case, and what it means for the future of compliance. Former ATO member Geoff Morris and CrossBorder Solutions’ Director Solutions Engineer Doug Darling discuss CrossBorder Solutions

Jul 27, 2021•1 hr 6 min0

Episode 107: A Transfer Pricing Legal Case in its Prime

Chief Economist Mimi Song joins University of Connecticut Professor of Law Richard Pomp to examine Amazon’s latest win against the European Commission and the key transfer pricing takeaways for multinationals. CrossBorder Solutions

Jul 20, 2021•56 min0

Episode 106: Enriching Your Tax Vocabulary

Chief Economist Mimi Song defines key tax terms, from tax scrutiny to “the race to the bottom,” and explains how they translate in the global tax conversation. CrossBorder Solutions

Jul 13, 2021•1 hr 3 min0

Episode 105: Italy's Mixed Messages

Why did the Italian Supreme Court administer two different rulings on inter-company transactions? What can taxpayers learn from it? Chief Economist Mimi Song and University of Ferrara Professor of Law Marco Greggi discuss. CrossBorder Solutions

Jul 06, 2021•58 min0

Episode 104: Denmark's Increased Scrutiny

The Danish Tax Authority’s recent win against Tetra Pak Processing Systems can only mean one thing: increased scrutiny for taxpayers. Chief Economist Mimi Song and international corporate income tax expert Johann Muller analyze how the Tetra Pak win could bolster the tax authority’s confidence, leading to a likely increase in audits. CrossBorder Solutions

Jun 29, 2021•50 min0

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

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

Jun 22, 2021•43 min0

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

It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best prepare. CrossBorder Solutions

Jun 15, 2021•58 min0

Episode 101: Audits on the Rise in Vietnam

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

Jun 08, 2021•48 min0

Episode 100: Our 100th Episode!

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

Jun 01, 2021•53 min0

Episode 99: The Value of the Value Chain Analysis

The value chain analysis is essential for planning and defending a multinational's transfer pricing. International corporate income tax expert Johann Muller joins CrossBorder Solutions Chief Economist Mimi Song on today's episode to answer every question on value chains and transfer pricing you're too afraid to ask. CrossBorder Solutions

May 25, 2021•1 hr 1 min0

Episode 98: HMRC Crackdown

With new initiatives by the HMRC to claim the £34 billion that it says MNEs owe the UK in unpaid taxes, the message to taxpayers is painstakingly clear: transfer pricing compliance in the UK is an order, not a request. CrossBorder Chief Economist Mimi Song and UK-based transfer pricing expert Pamesh Sharma talk about how MNEs can best prepare for more scrutiny. CrossBorder Solutions

May 18, 2021•50 min0

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

CrossBorder Solutions Director of International Tax Michael Desimone joins Chief Economist Mimi Song to discuss what the Biden administration's 'Made in America' tax plan has in store for MNEs, especially those with operations in low-tax jurisdictions. CrossBorder Solutions

May 11, 2021•58 min0

Episode 96: Joint Audits and Transfer Pricing

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

May 04, 2021•58 min0

Episode 95: The EU Commission and State Aid Cases

While the EU Commission cannot determine tax rates for individual jurisdictions, they do have other weapons in their arsenal to fight BEPS. David Chamberlain, assistant professor of Accounting and Tax at California Polytechnic State University, joins CrossBorder Solutions Chief Economist Mimi Song to discuss the commission's deluge of state aid cases against the biggest household names among MNEs. CrossBorder Solutions

Apr 27, 2021•55 min0

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

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

Apr 20, 2021•59 min0

Episode 93: Transfer Pricing & Tariffs

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

Apr 13, 2021•58 min0

Episode 92: Rethinking Country-by-Country Reporting

How effective are country-by-country reports in mitigating base erosion and profit shifting? And would making CbCRs public actually end up hurting analysis? Charles University’s Dr. Petr Jansky joins CrossBorder Solutions Chief Economist Mimi Song to discuss. CrossBorder Solutions

Apr 06, 2021•58 min0