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 ..read more

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 examples of differences in treatment of SBC in different countries from both a tax and accounting pe ..read more

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 present in China, and options available for MNCs to implement year-end adjustments. The speakers also addr ..read more

This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show ..read more

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 show ..read more

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 speed on what has happened since the December 2022 consultation document on Amount B? 5:23 - Can you pro ..read more

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 ..read more

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 transformations, and practical considerations for implementing OTP. Support the show ..read more

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 serviceability, and reassessment of debt capacity and double taxation. Support the show ..read more

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 ..read more