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)

TP Talks - PwC's Global Transfer Pricing podcast

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

In this TP Talks Special Edition podcast, Bob Ritter (PwC US Financial Transactions Transfer Pricing Leader), Edwin Baghdasarayan (PwC Australia Transfer Pricing Partner), and Jessica Yin (PwC China Transfer Pricing Partner) discuss issues and solutions related to existing intercompany financing arrangements arising as a result of the pandemic, considerations for new intercompany financing arrangements, and some key main focus areas.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 61: TP readiness amid economic uncertainty: Financial Transactions

This TP Talks Special Edition podcast features a discussion of immediate, short, and long-term transfer pricing planning and controversy considerations in light of today’s business disruptions.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 60: TP readiness amid economic uncertainty: Transfer pricing and policies

In this podcast, Chris Desmond (PwC US Transfer Pricing Partner), Lionel Van Reet (PwC Belgium Customs and International Trade Partner), and Maytee Pereira (PwC US Customs and International Trade Managing Director) discuss transfer pricing and the interrelationship with customs and trade, focusing on the impact on consumer markets - markdown vs drawback optimization, managed margin and trade impact considerations, as well as key takeaways.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 59: TP readiness amid economic uncertainty: Customs and trade

In this podcast, Andrew Fairfoull (Transfer Pricing Partner, PwC Singapore), Stehan Rasch, (Transfer Pricing Partner, PwC Germany), Jie Hong Liao (Transfer Pricing Partner, PwC Singapore), and Marc Philipp, (Management Consulting Partner, PwC South East Asia Consulting) discuss how multinational corporations are responding to the business disruption from an operations and supply chain management perspective, as well as the transfer pricing aspects of operations and supply chain from a short and medium-term perspective.Support the show (https://www.pwc.com/gx/en/services/tax/transfer-pricing.html)

Episode 58: TP readiness amid economic uncertainty: Operations and supply chain

In this podcast, PwC professionals discuss important transfer pricing considerations related to the General Anti-avoidance rule (GAAR), permanent establishment, new limitations on payments to “preferred regimes,” and reportable transactions.

Episode 57: Mexican tax reform from a transfer pricing perspective

In this podcast, PwC professionals discuss liquidity from a macroeconomic point of view, addresses current intercompany liquidity considerations, and consider the impact of the current economic environment on debt valuation and pricing.

Episode 56: TP readiness amid economic uncertainty - Liquidity and cash management

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.