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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

TP Talks - PwC's Global Transfer Pricing podcast

Episode 76: The new world tax system – what it means for your company

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 (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 75: Pillar One update: details of the OECD/G20 Inclusive Framework Statement

This TP Talks episode features a discussion of the latest developments for transfer pricing in Germany.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 74: A dialog on German transfer pricing developments

This Financial Transactions Transfer Pricing quarterly podcast features a discussion of the end of LIBOR, focusing on why and when the majority of LIBOR term rates will expire and the replacement rates; certain exceptions with regard to US dollar LIBOR tenors; the general tax and transfer pricing considerations; potential challenges converting from the old overnight LIBOR to the new overnight reference rates, and available options for reference rates with a longer maturity; developments across Asia-Pac region; and key takeaways.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 73: Financial Transactions Transfer Pricing – June 2021

In this TP Talks podcast, Drew Kim (Partner, PwC’s State and Local Tax practice), Jana Lessne (Transfer Pricing Managing Director, PwC’s Washington National Tax Services), and Matthew Lindeman (Director, PwC’s State and Local Tax practice) discuss the current landscape related to domestic US transfer pricing, including how state tax authorities are looking to raise revenue and increasingly scrutinizing domestic intercompany transactions. They also highlight considerations for companies related to developing effective state audit defense strategies and provide key takeaways. Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 72: Domestic US Transfer Pricing - what state taxing authorities have on their agenda

In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. For more information, see our Tax Insights: China issues Q&A regarding the administration on forex cash in-flows and out-flows of TP adjustments and China STA issues consultation draft on simplified procedure for unilateral APAs.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 71: China transfer pricing updates – a focus on clarity and simplification

This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 70: Keeping pace with changes to UK transfer pricing documentation rules

In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing.  The group also discusses debt capacity and controversy generally.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 69: Financial Transactions Transfer Pricing – March 2021

In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan.  The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways. Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 68: Advance Pricing Arrangements – a reliable tool for managing TP risk on the path forward

This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 67: TP Automation – efficiencies for projects of any size

This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 66: Financial Transactions Transfer Pricing – December 2020

This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 65: TP Readiness amid economic uncertainty – Using third-party behavior to support business decisions

This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint

TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities? This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential transfer pricing audits.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 63: TP readiness amid economic uncertainty — Tax controversy: Is transfer pricing low hanging fruit for tax authorities?

In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 62: TP readiness amid economic uncertainty: Comparability considerations and challenges

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.