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

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

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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.

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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 provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document?  
12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives?
18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that?
20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 
25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works?
31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most?
35:30 - What are some takeaways that you can offer our listeners?

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