Exploring Transfer Pricing

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist , Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, , comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto. We explore the implications of GenAI on tra...

ICAP - the OECD's International Compliance Assurance Program - offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way? This episode presents a unique opportunity to hear directly from both perspectives: Doug O'Don...

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compl...

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compl...

On this episode of Exploring Transfer Pricing, we discuss utilizing process improvement tools to pinpoint where GenAI can truly shine in transfer pricing. With generative artificial intelligence (GenAI) taking the spotlight in innovation, organizations are asking: Where do we start? In this episode of Exploring Transfer Pricing, we discuss how process improvement methodologies can help businesses...

In this episode of Exploring Transfer Pricing, we discuss utilizing operational transfer pricing to move from a manual mess to an automated success. As global regulations intensify and the demand for accuracy grows, having a robust operational transfer pricing (OTP) strategy is no longer a luxury - it is a necessity. Many believe that implementing an OTP solution requires a large front investment,...

What does the G7 agreement mean for Pillar Two in the US? How do changes to Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) influence transfer pricing strategies? Why is modeling more crucial than ever? This episode tackles these questions and more, offering insights into IP planning, cost sharing agreements, and the services cost method. Whether you're curi...

Companies are rethinking tax strategies with an eye on transparency and responsibility in today's evolving landscape. On this episode of Exploring Transfer Pricing, we'll highlight the important role played by tax planning to support business growth objectives, and the important role of comprehensive transfer pricing documentation to mitigate audit risks. Join our host as she, along with her guest...

Strap in for the rollercoaster of tariffs - How transfer pricing can help smooth out the ride. Join us for this episode as we attempt to unravel the complexities of tariffs and transfer pricing, and discuss what taxpayers need to be aware of to stay ahead of the rapidly changing tariff landscape. Join our host as she, along with her guests (Managing Director, Tax, ) and (Managing Director, Tax, ),...

Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readine...

Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readine...

Understanding the critical link between Pillar 2 and transfer pricing. Delve into the intricate relationship between Pillar Two and transfer pricing in this episode of the KPMG Exploring Transfer Pricing podcast. As the OECD's Inclusive Framework introduces Pillar Two to ensure a minimum level of taxation for multinational groups, understanding its implications on transfer pricing has become param...

Reflecting on the international and transfer pricing landscape of 2024, and anticipating what's on the horizon for 2025. As the curtain falls on 2024, we take a retrospective journey back through the key tax initiatives that have carved the contours of the transfer pricing arena this year. This episode casts its navigational net wide, exploring topics from foreign derived intangible income (FDII)...

From development to exploitation, refining our understanding of DEMPE in transfer pricing. Dive into the ever-changing world of DEMPE (Development, Enhancement, Maintenance, Protection and Exploitation) in this episode of the KPMG TaxRadio podcast Exploring Transfer Pricing, where we reflect on insights from the DEMPE session during the KPMG 2024 U.S. Cross-Border Tax Conference. Building on the r...

From the Samba to Merengue, exploring the tax dance in the Latin American region. Rhumba-ing into the complicated dance of transfer pricing controversy, this episode discusses the tax controversy trends seen in the region of Latin America, or LATAM. What avenues are there for companies to address tax certainty and controversy in LATAM? Which transactions draw the most scrutiny for the LATAM tax au...

From cliffs to castles, exploring the tax terrain of Ireland and the UK. Diving into the stormy seas of transfer pricing disputes, this episode unveils the escalating challenges and evolving trends in the United Kingdom and Ireland. How has Brexit reshaped the transfer pricing relationship between the competent authorities in Ireland and the UK? What impact has the OECD and G20's Base Erosion and...

Trim down with legal entity rationalization and streamline your transfer pricing. Legal entity rationalization, a strategic method of streamlining corporate structures, plays a pivotal role in enhancing business efficiency and cost-effectiveness. But how does this process help businesses meet their objectives? And what is its significance in the face of ever-changing tax landscapes and regulatory...

Unlocking the potential of GenAI throughout the Transfer Pricing lifecycle. Within the complex landscape of transfer pricing, the introduction of generative artificial intelligence (GenAI) is stirring up a new era of possibilities. But how is GenAI influencing this multifaceted field? What novel trends are emerging, propelled by GenAI advancements? And how should we incorporate this cutting-edge t...

From canals to autobahns, traversing the European tax controversy landscape. In the intricate realm of transfer pricing, tax controversies and disputes present a unique set of challenges. But how are these challenges being addressed in Europe, particularly in Germany and the Netherlands? What trends are emerging in these jurisdictions? And how is the concept of joint audits being leveraged as a po...

Beyond Controversy: The collaborative landscape of transfer pricing disputes. In the complex world of transfer pricing, setting the right price for intercompany transactions is both a science and a subjective process. But how does this play out in the face of international disputes? Where do treaty-based resolutions like the Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA)...

Cupid's arrow has struck the heart of many curious people, leading them to transfer pricing. Prepare to be smitten as we delve into the hearts of multiple transfer pricing professionals, the matchmakers of the corporate world, who work to harmonize the rhythm of regulatory compliance with the melody of business objectives in a symphony of economic strategy. Whether it was love at first sight or a...

Charting out the OECD's 2022 Mutual Agreement Procedure (MAP) Statistics to appreciate how effective MAP is in resolving transfer pricing disputes. The OECD released the 2022 Mutual Agreement Procedure (MAP) Statistics and announced its much heralded MAP Awards, the Transfer Pricing equivalent of the Oscars. When a multinational is subject to a transfer pricing adjustment, MAP is a process the tax...

Our host Brittany Hardin Tanguay is joined by Maggie Fritz, a Tax Principal and the global banking leader for transfer pricing, and Brie Siciliano, a Managing Director for Tax specializing in financial services. Together, they'll unravel the complexities that the banking industry encounters when enacting transfer pricing.

2023 has been a rollercoaster in the world of international tax and transfer pricing - and 2024 looks to be more of the same. As 2023 draws to a close, we delve into the key tax initiatives that have shaped the transfer pricing landscape over the past year. This episode navigates through topics ranging from the OECD's Pillar One and Pillar Two, to the adoption of the OECD Guidelines by Brazil and...

Hammering out transfer pricing challenges in the building, construction, and real estate industry. Building on our Transfer Pricing Industries Series, we have constructed an episode on the specialized transfer pricing issues faced by the building, construction, and real estate, BCRE, industry. The uniqueness of the underlying assets influence how transactions are valued, and how to price the assoc...