How Transfer Pricing Rules Shape Corporate Tax Bills

This episode unpacks the complex world of transfer pricing — the rules that determine how multinational corporations allocate income across borders. Lucas explains how companies like Apple and Starbucks have used transfer pricing to shift profits to low-tax jurisdictions, and how the OECD's BEPS framework is tightening those rules. Luna challenges whether the new regulations actually reduce tax avoidance or just create more compliance paperwork. We look at specific cases: the Starbucks Netherlands case, the IRS's ongoing dispute with Microsoft over $39 billion in profit allocation, and what the new 2026 transfer pricing documentation requirements mean for multinationals. The hosts also touch on the role of intangible assets — patents and trademarks — as the primary vehicle for profit shifting, and why arm's-length pricing is so hard to enforce when there's no comparable market transaction. A practical, concrete look at one of tax policy's most arcane but consequential areas. #TransferPricing #CorporateTax #TaxAvoidance #BEPS #OECD #ProfitShifting #IntangibleAssets #ArmLengthPrinciple #Starbucks #Apple #Microsoft #IRS #TaxPolicy #Economics #MultinationalCorporations #TaxCompliance #FexingoBusiness #BusinessPodcast Keep every episode free: buymeacoffee.com/fexingo