TP Talks - PwC's Global Transfer Pricing podcast

PwC

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.

  • 34 minutes 58 seconds
    Episode 110: Transfer Pricing in the Middle East: Opportunities abound

    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.

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    10 December 2024, 2:00 pm
  • 17 minutes 16 seconds
    Episode 109: Brazil’s big shift: The new transfer pricing reality

    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.

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    20 November 2024, 7:00 pm
  • 44 minutes 28 seconds
    Episode 108: Special Edition – Financial Transactions Transfer Pricing

    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 of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.

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    7 November 2024, 4:00 pm
  • 32 minutes 24 seconds
    Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves

    This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1

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    9 October 2024, 5:00 pm
  • 35 minutes 29 seconds
    Episode 106: CbCR: The evolving landscape

    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.

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    14 August 2024, 1:00 pm
  • 40 minutes 59 seconds
    Episode 105: Special Edition – Financial Transactions Transfer Pricing

    This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada.

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    19 June 2024, 5:00 pm
  • 29 minutes 24 seconds
    Episode 104: Who bears the risk? Navigating HMRC’s guidance

    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.

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    16 May 2024, 12:00 pm
  • 30 minutes 3 seconds
    Episode 103: Pricing intercompany loans: why implicit support matters

    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.

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    4 April 2024, 3:00 pm
  • 24 minutes 44 seconds
    Episode 102: Stock-based compensation: One size does not fit all

    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 perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways.

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    5 February 2024, 11:00 pm
  • 13 minutes 58 seconds
    Episode 101: The time is now: year-end TP adjustments in China

    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 address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry.

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    12 December 2023, 10:00 am
  • 23 minutes 46 seconds
    Episode 100: Perspectives on China and India

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

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    22 November 2023, 8:00 pm
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