TP Talks - PwC's Global Transfer Pricing podcast
PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.
Episodes
Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.
In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.
Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader). Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits...
In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges pose...
In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership...
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 ...
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.
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.
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.
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...
This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1
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.
This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada.
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.
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.
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, financi...
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...
This TP Talks episode features a discussion of the transfer pricing developments in India and China.
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...
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 ...
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