This TP Talks podcast features discussion of the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation. Support the show
In this Financial Transactions Transfer Pricing quarterly podcast, Bob Ritter (PwC’s US Financial Transactions Transfer Pricing leader) is joined by Laura Valestin (Partner in PwC’s National Tax practice in Washington DC, specializing in financial products), and Chad Clark (Director in PwC’s Financial Markets and Real Estate practice, based in Austin, TX) to discuss LIBOR and the final regulations released by the IRS and US Treasury that provide tax guidance with respect to alterations to debt i...
In this episode, we feature an excerpt from PwC’s Global Transfer Pricing Conference, focusing on ESG factors as drivers of value creation and levers to manage risks, concentrating on supply chain/value chain analysis, tax transparency, intercompany financial transactions, and deals. The panelists included Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), Jayde Thompson (Transfer Pricing partner – PwC Australia), Noor Sanders (Transfer Pricing partner – PwC Netherlands), and...
In this TP Talks episode, Lauren Dangelmayr (Principal, Transfer Pricing - PwC US), Hamish McElwee (Partner, Transfer Pricing - PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), Ivan Williams (Partner, Transfer Pricing - PwC Canada), and Thushara Corea (Director,Transfer Pricing - PwC Canada) discuss the oilfield services industry, focusing on planning related to leasing and IP, ESG, as well as pragmatic approaches to transfer pricing documen...
In this TP Talks episode, Lauren Dangelmayr (Transfer Pricing Principal, PwC US), Hamish McElwee (Transfer Pricing Partner, PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), and Ivan Williams (Transfer Pricing Partner, PwC Canada) discuss the changing regulatory environment around the world and the impact on the oilfield services industry. The speakers also discuss the controversy environment and how companies in the industry are managing ris...
This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico. Support the show
This episode features an excerpt from our recent Global Transfer Pricing Conference, discussing the OECD global tax agreement, where we are now and where things are heading. Support the show
This TP Talks episode features a discussion of Pillar One transfer pricing issues related to the July 1 Statement by the OECD/G20 Inclusive Framework on BEPS on a two-pillar solution to address the taxation of the digitalization of the economy. Support the show
This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany. Support the show
This Financial Transactions Transfer Pricing quarterly podcast features a discussion of the end of LIBOR, focusing on why and when the majority of LIBOR term rates will expire and the replacement rates; certain exceptions with regard to US dollar LIBOR tenors; the general tax and transfer pricing considerations; potential challenges converting from the old overnight LIBOR to the new overnight reference rates, and available options for reference rates with a longer maturity; developments across A...
In this TP Talks podcast, Drew Kim (Partner, PwC’s State and Local Tax practice), Jana Lessne (Transfer Pricing Managing Director, PwC’s Washington National Tax Services), and Matthew Lindeman (Director, PwC’s State and Local Tax practice) discuss the current landscape related to domestic US transfer pricing, including how state tax authorities are looking to raise revenue and increasingly scrutinizing domestic intercompany transactions. They also highlight considerations for companies related t...
In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. F...
This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider. Support the show
In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound r...
In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan. The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways. Support the show...
This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations. Support the show
This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR. Support the show
This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term. Support the show...
This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options. Support the show...
TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities? This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential tr...
In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate. Support the show...
In this TP Talks Special Edition podcast, Bob Ritter (PwC US Financial Transactions Transfer Pricing Leader), Edwin Baghdasarayan (PwC Australia Transfer Pricing Partner), and Jessica Yin (PwC China Transfer Pricing Partner) discuss issues and solutions related to existing intercompany financing arrangements arising as a result of the pandemic, considerations for new intercompany financing arrangements, and some key main focus areas. Support the show...
This TP Talks Special Edition podcast features a discussion of immediate, short, and long-term transfer pricing planning and controversy considerations in light of today’s business disruptions. Support the show
In this podcast, Chris Desmond (PwC US Transfer Pricing Partner), Lionel Van Reet (PwC Belgium Customs and International Trade Partner), and Maytee Pereira (PwC US Customs and International Trade Managing Director) discuss transfer pricing and the interrelationship with customs and trade, focusing on the impact on consumer markets - markdown vs drawback optimization, managed margin and trade impact considerations, as well as key takeaways. Support the show...
In this podcast, Andrew Fairfoull (Transfer Pricing Partner, PwC Singapore), Stehan Rasch, (Transfer Pricing Partner, PwC Germany), Jie Hong Liao (Transfer Pricing Partner, PwC Singapore), and Marc Philipp, (Management Consulting Partner, PwC South East Asia Consulting) discuss how multinational corporations are responding to the business disruption from an operations and supply chain management perspective, as well as the transfer pricing aspects of operations and supply chain from a short and ...
In this podcast, PwC professionals discuss important transfer pricing considerations related to the General Anti-avoidance rule (GAAR), permanent establishment, new limitations on payments to “preferred regimes,” and reportable transactions. Support the show
In this podcast, PwC professionals discuss liquidity from a macroeconomic point of view, addresses current intercompany liquidity considerations, and consider the impact of the current economic environment on debt valuation and pricing. Support the show
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