How Transfer Pricing Moves Profits Across Borders

Episode 79 of The Tax Policy Podcast dives into transfer pricing — the rules that determine how multinational corporations allocate income between subsidiaries in different countries. Lucas and Luna explain why a one-page intercompany agreement for a patent can shift millions in taxable profit to a low-tax jurisdiction. They walk through the arm's-length standard, the OECD's BEPS framework, and a concrete example involving a fictional U.S. tech company licensing software to its Irish subsidiary. They also discuss the 2026 landscape: increased IRS scrutiny, country-by-country reporting thresholds, and how the OECD's Pillar One and Pillar Two are reshaping the game. By the end, listeners will understand why transfer pricing is the single most important corporate tax issue for global companies — and why tax authorities are fighting harder than ever to police it. #TransferPricing #CorporateTax #BEPS #OECD #ArmLengthStandard #PillarOne #PillarTwo #GlobalTax #IPMigration #CountryByCountryReporting #IRS #MultinationalCorporations #TaxPlanning #IntercompanyAgreements #Economics #TaxPolicy #FexingoBusiness #BusinessPodcast Keep every episode free: buymeacoffee.com/fexingo