PwC
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 provide you not only the latest regulatory changes developments, but also inform you how they can impact your business.
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Episodes
Episode 99: More pain? A review of the transfer pricing controversy environment 16.10.2023 40:34
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, t...
Episode 98: Pillar One Amount B: Reading the tea leaves 29.08.2023 40:37
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 -...
Episode 97: Transfer Pricing: Exploring the past, present, and future 19.07.2023 15:29
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...
Episode 96: Operational Transfer Pricing: A catalyst to unlock potential in tax and beyond 29.06.2023 18:16
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...
Episode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023) 19.06.2023 22:02
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 analyzin...
Episode 94: Brazil’s transfer pricing rules: A shift to international standards 17.05.2023 16:58
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 implication...
Episode 93: The endgame begins – Navigating TP implications in the Pillar Two world 17.04.2023 35:39
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 prior...
Episode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023) 20.03.2023 21:48
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 ma...
Episode 91. Business transformation – when ESG, value chain, and transparency converge 17.02.2023 23:03
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 fo...
Episode 90: Transfer pricing in Africa from a bird’s-eye view 15.12.2022 32:28
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...
Episode 89: EU and UK TP controversy trends and outlook 01.11.2022 38:37
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. Suppo...
Episode 88: US TP controversy trends and outlook 20.09.2022 26:30
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
Episode 87: Winds of change: New Dutch transfer pricing and PE rules that can impact your business 10.08.2022 17:48
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 relat...
Episode 86: The middlegame – Pillar Two strategy for transfer pricing evolves 21.07.2022 36:43
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...
Episode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022) 14.06.2022 21:26
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 sustainab...
Episode 84: US § 174 – getting your arms around the new R&D capitalization rules 13.05.2022 25:56
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 1...
Episode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022) 05.04.2022 28:22
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 de...
Episode 82: The opening – Transfer pricing is a critical piece of the Pillar Two chessboard 22.02.2022 22:49
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
Episode 81: Special Edition – Financial Transactions Transfer Pricing 17.02.2022 23:26
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...
Episode 80: Putting the TP into ESG 27.01.2022 26:03
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 (Trans...
Episode 79: Special Edition – TP in the oilfield services industry (Part 2) 22.12.2021 21:43
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...
Episode 78: Special Edition – TP in the oilfield services industry (Part 1) 16.12.2021 21:59
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...
Episode 77: Special Edition – Financial Transactions Transfer Pricing (September 2021) 03.11.2021 26:51
This TP Talks Special Edition quarterly podcast features a discussion of current trends for France, Singapore, and Mexico. Support the show
Episode 76: The new world tax system – what it means for your company 20.10.2021 16:23
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
Episode 75: Pillar One update: details of the OECD/G20 Inclusive Framework Statement 09.09.2021 37:58
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
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