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 char...
Feb 14, 2025•20 min•Season 1Ep. 112
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
Jan 03, 2025•23 min•Season 1Ep. 111
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
Dec 10, 2024•35 min•Season 1Ep. 110
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
Nov 20, 2024•17 min•Season 1Ep. 109
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 under...
Nov 07, 2024•44 min•Season 1Ep. 108
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
Oct 09, 2024•32 min•Season 1Ep. 107
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
Aug 14, 2024•35 min•Season 1Ep. 106
This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada. Support the show
Jun 19, 2024•41 min•Season 1Ep. 105
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
May 16, 2024•29 min•Season 1Ep. 104
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
Apr 04, 2024•30 min•Season 1Ep. 103
In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide ...
Feb 05, 2024•25 min
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 presen...
Dec 12, 2023•14 min•Season 1Ep. 101
This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show
Nov 22, 2023•24 min•Season 1Ep. 100
In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more. Support the...
Oct 16, 2023•41 min•Season 1Ep. 99
In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation. Timestamps: 1:17 - What is Pillar 1 and what is Amount B under Pillar 1? 3:30 - Can you bring our listeners up to spee...
Aug 29, 2023•41 min•Season 1Ep. 98
In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice) and Greg Ossi (former Principal in PwC’s US National Tax Practice) discuss some of the historical transformative milestones that have reshaped transfer pricing. They also examine the current transfer pricing landscape and take a look forward, exploring some of the possibilities and challenges that lie ahead for transfer pricing practitioners and taxpayers. Support the show...
Jul 19, 2023•15 min•Season 1Ep. 97
In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Andrew Hwang (Americas Operational Transfer Pricing Leader, PwC US), and Antonino De Benedictis (EMEA Operational Transfer Pricing Leader, PwC UK) discuss why Operational Transfer Pricing (OTP) is increasingly becoming a priority for in-house tax and finance professionals, the value and benefits OTP offers the broader finance function and C-Suite, scalability of OTP to accommodate small to large scale transformation...
Jun 29, 2023•18 min•Season 1Ep. 96
FTTP Q2 2023: Debt capacity and transfer pricing In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Martin Cazaux (Transfer Pricing Principal, PwC US), and Tony Koivula (Transfer Pricing Manager, PwC Finland) discuss debt capacity and transfer pricing, focusing on the US’s and EU’s history of looking at debt capacity, the varying approaches to analyzing debt capacity, Australia’s draft legislation on proposed new interest limitation rules, debt servic...
Jun 19, 2023•22 min•Season 1Ep. 95
In this TP Talks episode, Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Michela Chin (Transfer Pricing leader for PwC Brazil), and Matias Pedevilla (Transfer Pricing Principal with PwC US and global leader of PwC's Global Coordinated Documentation service) discuss the overhaul of Brazil’s transfer pricing system, focusing on the main changes that have been introduced, the implications of the pending rules for multinationals, and what companies should be doing now. Support the show...
May 17, 2023•17 min•Season 1Ep. 94
This TP Talks episode is part 3 of a three-part series on Pillar Two, where Ugo Cannavale (Transfer Pricing Leader for PwC Italy), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the latest Pillar Two developments, country level developments, and what companies need to prioritize from a transfer pricing perspective. See also: The opening – Transfer pricing is a critical pie...
Apr 17, 2023•36 min•Season 1Ep. 93
FTTP Q1 2023: A looking ahead (and back) on financial markets and what to expect from tax authorities In this TP Talks Special Edition podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Dan Pybus (PwC’s EMEA Financial Transactions TP Leader), Bob Ritter (PwC’s US Financial Transactions TP Leader), and Hiral Mistry (Transfer Pricing Partner, PwC Australia) discuss changing financial market conditions, tax policy changes, what to expect from tax authorities in 2023, as well as a look b...
Mar 20, 2023•22 min•Season 1Ep. 92
In this TP Talks episode, new podcast host Ugo Cannavale (Transfer Pricing Leader, PwC Italy) is joined by Monica Cohen-Dumani (International Tax Services Partner, PwC Switzerland), and Brad Slattery (Global VCT Transfer Pricing Leader, PwC US) to discuss the role ESG and transparency play in driving value in operating model transformation and how transfer pricing plays a key part. The speakers focus on the EU Corporate Sustainability Directive and how tax and transfer pricing is tied into the D...
Feb 17, 2023•23 min•Season 1Ep. 91
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Osman Mollagee and Michael Butler (PwC Transfer Pricing Partners based in South Africa) to discuss the business environment in regions across Africa, the tax and transfer pricing landscape, general audit processes and avenues available with respect to dispute resolution, and what developing countries are looking for from Pillars One and Two of the OECD’s global tax reform p...
Dec 15, 2022•32 min•Season 1Ep. 90
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more. Support the show...
Nov 01, 2022•39 min•Season 1Ep. 89
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Kristina Novak and Andrew Kim (Transfer Pricing Principals in PwC’s US National Tax Services practice) to discuss recent trends and outlook with respect to US transfer pricing controversy, and steps taxpayers should consider to avoid potential risks. Support the show
Sep 20, 2022•27 min•Season 1Ep. 88
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Niek van der Put (Transfer Pricing Director, PwC Netherlands), Neil Schaatsbergen (Transfer Pricing Director, PwC Netherlands), and Aleks Davydov (Transfer Pricing Senior Manager, PwC Netherlands). They discuss two decrees recently published by the Dutch tax authorities related to transfer pricing and the attribution of profits to permanent establishments, exploring what’s ...
Aug 10, 2022•18 min•Season 1Ep. 87
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the Pillar Two discussion, focusing on the commentary published in March and how it has slightly reinterpreted the role of transfer pricing in Pillar Two; developments in Europe, including the UK stakeholder consult...
Jul 21, 2022•37 min•Season 1Ep. 86
In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing ch...
Jun 14, 2022•21 min•Season 1Ep. 85
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 provisio...
May 13, 2022•26 min•Season 84Ep. 1
In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiati...
Apr 05, 2022•28 min•Season 1Ep. 83
