The Fiona Show: Transfer Pricing - podcast cover

The Fiona Show: Transfer Pricing

CrossBorder Solutionswww.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.

Episodes

Episode 57: Transfer Pricing in Denmark

Denmark has been dubbed one of the happiest places on earth, so why aren’t transfer pricing executives thrilled? CrossBorder Solutions

Jul 29, 202044 min0

Episode 52: Transfer Pricing in Germany

Sure, the country is a member of the OECD, and generally speaking, it follows the organization’s transfer pricing guidelines, but even a straight-shooting country like Germany has transfer pricing nuances. CrossBorder Solutions

Jun 19, 20201 hr 5 min0

Episode 46: Transfer Pricing in Poland

Newish regulations, heightened compliance, DAC6. How is this EU country cracking down on transfer pricing? Straight from Poland, CrossBorder Solutions’ transfer pricing expert Milena Kaniewska tells all. CrossBorder Solutions

Apr 29, 202054 min0

Episode 42: Are You Transfer Pricing Audit-Ready?

We thought so. Well, there’s no time like the present to get started. Tax Attorney and Transfer Pricing Advisor Barbara Mantegani is here to offer strategies on how to ace an audit. Think of it as Audit Prep 101. CrossBorder Solutions

Apr 01, 20201 hr0

Episode 41: Cost-Sharing Post TCJA

Cost-sharing arrangements are subjective at best—even by transfer pricing standards. Over the years, major tech-companies like Xilinx, Amazon, Altera, and now Facebook, have all been victims of their own interpretations of cost-sharing regulations that have been written, re-written, modified, and in some cases, grandfathered to previous or even temporary versions. And that's all not to even mention the Tax Cuts and Jobs Act. So, does the world have a right to be a little perplexed? We’d say so. ...

Mar 25, 20201 hr 13 min0

Episode 40: India

India marches to the beat of its own tabla. From its friends-with-benefits relationship with the OECD to its sophisticated unilateral moves: few countries are as bold and forward-thinking, especially when it comes to transfer pricing. CrossBorder Solutions

Mar 18, 202056 min0

Episode 37: Transfer Pricing in the UK

Sure, country pubs and warm beer have their charm. But if you ask us, the real appeal of the United Kingdom comes from its straightforward approach to corporate taxation. I mean, there are no mixed messages. A punitive diverted profits tax says, “We want our tax dollars.” A profit diversion compliance facility says, “How can we help you give us our tax dollars?” A pending digital services tax says, “We need even more tax dollars.” A growing number of transfer pricing specialists at the HMRC says...

Feb 26, 202058 min0

Episode 33: Pillar One is Not BEPS 2

You may have heard Dr. Lorraine Eden on The Fiona Show—Episode 29, “Is the Arm’s Length Standard Really the Problem?”—when she gave us a very impassioned defense of the principle that’s become the backbone of transfer pricing. Well, today she’s back, this time leading the charge about the sorry attempt at BEPS Action One—the taxation of the digital economy—known to you, as Pillar One. CrossBorder Solutions

Jan 29, 20201 hr 23 min0

Episode 32: So, You Want to Be In More Than Pictures?

When a company evolves from the photographic industry into skincare, pharmaceuticals, medical equipment, network systems, printers, and more, the transfer pricing director had better keep up. Here, FujiFilm’s Director of Taxes, Peter De Nicola, reveals how through years of reinventions at Fuji, he focused on the big picture. CrossBorder Solutions

Jan 22, 202034 min0

Episode 31: You Say You Want a Resolution...

What happens when you take your transfer pricing dispute to the competent authority? Tax attorney—and former competent authority analyst—Barbara Mantegani tells all. CrossBorder Solutions

Jan 15, 20201 hr 2 min0

Episode 30: Transfer Pricing New Year's Resolutions

If you learned lessons the hard way in 2019, vow to make 2020 different. Here, 'Fiona Show' experts reveal how to kick off the transfer pricing new year on the right foot. Best of all, unlike your other resolutions, you don't have to join a gym to succeed. CrossBorder Solutions

Jan 08, 202054 min0