Exploring Transfer Pricing

Transfer pricing may be routed in rules and regulations, but the people who shape the field bring their own stories, perspectives, and motivations. In this special 'Get to Know' episode, host Brittany Hardin Tanguay sits down with three recent arrivals to KPMG who bring decades of experience from the IRS and Office of Chief Counsel. They discuss how they discovered tax and transfer pricing, what drew them into public service, and how their government experience now informs their work with multinational businesses. Join our host Brittany Hardin Tanguay as she welcomes Jayme Reynolds (Managing Director, Tax Controversy and Dispute Resolution (TCDR) and former IRS APMA official),Kathleen Agbayani (Managing Director, TCDR and former IRS Office of Chief Counsel attorney), and Doug O'Donnell (Senior Managing Director, TCDR and former Acting Commissioner and Deputy Commissioner of the IRS). Together, they discuss pivotal career moments, their first real exposure to transfer pricing, and the lessons they carry forward as they now advise multinational groups form the private-sector side of the table.

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In Part 2 of this two-part series, host Brittany Hardin Tanguay and Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) practice, continue their conversation fielding questions from transfer pricing professionals at the TP Minds West Coast event in Palo Alto. This episode digs into the practical realities of GenAI's impact on transfer pricing, covering three key areas: - The evolving value of data (and why a single data point is nearly worthless until it's aggregated, cleansed, and put to work) - How GenAI adoption is - and isn't - reshaping comparability analysis and benchmarking under TNMM and CPM, and - Where tax authorities are most likely to challenge intercompany arrangements tied to AI-driven value creation.

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, Brittany Hardin Tanguay, comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto. We explore the implications of GenAI on transfer pricing: - Does GenAI-generated content constitute new intellectual property? - How does automation shift the allocation of intercompany costs? - What steps can companies take to stay proactive amid the rapid adoption of this technology? From understanding the evolving role of data to tackling comparability challenges, this discussion explores the dynamic intersection of GenAI and transfer pricing in Part 1 of this two-part episode.

ICAP - the OECD's International Compliance Assurance Program - offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way? This episode presents a unique opportunity to hear directly from both perspectives: Doug O'Donnell, former IRS Acting Commissioner and Deputy Commissioner, who was instrumental in shaping ICAP for tax administrations, and Erik Skarstad, who has navigated the program during his time as a Transfer Pricing leader for Fortune 100 companies. Their firsthand experiences reveal the practical realities, challenges and benefits of participating in ICAP. Join our host Brittany Hardin Tanguay as she speaks with Doug O'Donnell (Senior Managing Director, Washington National Tax, Tax Controversy and Dispute Resolution) and Erik Skarstad (Managing Director, Tax, Transfer Pricing) to unpack ICAP's origins, objectives, and real-world impact. Together, they share insights from both sides of the table, government and taxpayer, on building trust, navigating challenges, and finding value in multinational cooperation.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.

On this episode of Exploring Transfer Pricing, we discuss utilizing process improvement tools to pinpoint where GenAI can truly shine in transfer pricing. With generative artificial intelligence (GenAI) taking the spotlight in innovation, organizations are asking: Where do we start? In this episode of Exploring Transfer Pricing, we discuss how process improvement methodologies can help businesses identify the best opportunities to integrate GenAI into transfer pricing processes. From reducing mundane manual tasks to scaling solutions globally, we explore how defining, discovering, and solving through structured frameworks can demystify GenAI's role in transforming your transfer pricing processes. Join our guest host Seth Salenger (Manager, Tax, Transfer Pricing), for a conversation with Amanda Carey (Managing Director, Tax, WNT - Transfer Pricing) and Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing). Together, they break down actionable steps for organizations to embrace GenAI as a tool for efficiency and innovation - while balancing quality and accuracy in a rapidly transforming tax landscape.

In this episode of Exploring Transfer Pricing, we discuss utilizing operational transfer pricing to move from a manual mess to an automated success. As global regulations intensify and the demand for accuracy grows, having a robust operational transfer pricing (OTP) strategy is no longer a luxury - it is a necessity. Many believe that implementing an OTP solution requires a large front investment, but a solution may not be out of reach. Our host Brittany Hardin Tanguay is joined by Raj Bodapati (Principal, Tax - National Leader, Operational Transfer Pricing) and Magdalena Bonna (Partner, Global Transfer Pricing Services - KPMG Germany), and together they examine how to turn your operational transfer pricing challenges into a competitive advantage.

What does the G7 agreement mean for Pillar Two in the US? How do changes to Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) influence transfer pricing strategies? Why is modeling more crucial than ever? This episode tackles these questions and more, offering insights into IP planning, cost sharing agreements, and the services cost method. Whether you're curious about the nuances of the G7 agreement or the implications of updates to the Base Erosion and Anti-Abuse Tax (BEAT), this episode provides insights and practical guidance to help taxpayers navigate the evolving transfer pricing landscape under OB3. Our host Brittany Hardin Tanguay is joined by Marissa Rensen (Managing Director, Washington National Tax - International Tax) and Thomas Bettge (Senior Manager, Washington National Tax - Transfer Pricing), and together they examine the legislative changes introduced by the One Big, Beautiful Bill (OB3) and its implications for transfer pricing.

Companies are rethinking tax strategies with an eye on transparency and responsibility in today's evolving landscape. On this episode of Exploring Transfer Pricing, we'll highlight the important role played by tax planning to support business growth objectives, and the important role of comprehensive transfer pricing documentation to mitigate audit risks. Join our host Brittany Hardin Tanguay as she, along with her guests Kristin Essary (Principal and National Transfer Pricing Advisory Leader), and Marissa Rensen (Managing Director, WNT - International Tax), explore how companies can leverage their intellectual property, navigate the intricacies of foreign tax credits, and manage the Base Erosion and Anti-Abuse Tax (BEAT). Discover how strategic collaboration and detailed modeling can unlock tax savings opportunities to ensure your business remains buoyant amidst today's turbulent tax tides.

Strap in for the rollercoaster of tariffs - How transfer pricing can help smooth out the ride. Join us for this episode as we attempt to unravel the complexities of tariffs and transfer pricing, and discuss what taxpayers need to be aware of to stay ahead of the rapidly changing tariff landscape. Join our host Brittany Hardin Tanguay as she, along with her guests Nicole Porpiglia (Managing Director, Tax, Trade and Customs) and Adam Kelfer (Managing Director, Tax, Transfer Pricing), share their experiences and reveal how strategic collaboration between transfer pricing and trade and customs teams can unlock significant value for businesses.

Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readiness. Join our host Brittany Hardin Tanguay as she, along with her guest Mark Horowitz (Principal, Tax - KPMG US), react to the thoughts of other transfer pricing practitioners on the nuances of intercompany agreements. Brittany and Mark discuss the evolution of intercompany agreements, the importance of clear risk allocation, and the necessity of maintaining flexibility to adapt to unforeseen circumstances. Discover how businesses can effectively manage their intercompany agreements to align with tax authority expectations and safeguard against potential disputes, all while fostering a robust framework for global operations.

Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readiness. Join our host Brittany Hardin Tanguay as she, along with her guest Mark Horowitz (Principal, Tax - KPMG US), react to the thoughts of other transfer pricing practitioners on the nuances of intercompany agreements. Brittany and Mark discuss the evolution of intercompany agreements, the importance of clear risk allocation, and the necessity of maintaining flexibility to adapt to unforeseen circumstances. Discover how businesses can effectively manage their intercompany agreements to align with tax authority expectations and safeguard against potential disputes, all while fostering a robust framework for global operations.

Understanding the critical link between Pillar 2 and transfer pricing. Delve into the intricate relationship between Pillar Two and transfer pricing in this episode of the KPMG Exploring Transfer Pricing podcast. As the OECD's Inclusive Framework introduces Pillar Two to ensure a minimum level of taxation for multinational groups, understanding its implications on transfer pricing has become paramount. How does Pillar Two affect the preparation and use of Country-by-Country reports? What are the critical components of the transitional Safe Harbor test under Pillar Two? And what role does operational transfer pricing play in managing Pillar Two compliance? Join our host, Brittany Hardin Tanguay, as she explores these pivotal questions with Lucia Barone, a tax partner with KPMG Italy, and Kathy Lim, a tax partner based in Belgium. Together, they provide valuable insights and practical advice to help multinational groups navigate the complexities of Pillar Two.

Reflecting on the international and transfer pricing landscape of 2024, and anticipating what's on the horizon for 2025. As the curtain falls on 2024, we take a retrospective journey back through the key tax initiatives that have carved the contours of the transfer pricing arena this year. This episode casts its navigational net wide, exploring topics from foreign derived intangible income (FDII) and base erosion and anti-abuse tax (BEAT) Planning, to generative artificial intelligence (GenAI), and on-going controversies and compliance changes in transfer pricing. Join our guest host Seth Salenger, along with guests from the KPMG U.S. Washington National Tax Practice Jessie Coleman and Brittany Hardin Tanguay, as they come together to discuss the highlights and developments of the year gone by, and consider the challenges and opportunities set to shape the year ahead.

From development to exploitation, refining our understanding of DEMPE in transfer pricing. Dive into the ever-changing world of DEMPE (Development, Enhancement, Maintenance, Protection and Exploitation) in this episode of the KPMG TaxRadio podcast Exploring Transfer Pricing, where we reflect on insights from the DEMPE session during the KPMG 2024 U.S. Cross-Border Tax Conference. Building on the results of our live survey with a diverse group of tax professionals representing multinational enterprises, we explore their perspectives and potential trends, offering a comprehensive and insightful view of the current and future state of transfer pricing. What are the key challenges companies face when integrating new acquisitions or managing dispersed senior management? How do different tax authorities mold DEMPE with their unique interpretations? And what strategies can businesses employ to mitigate risks and prepare for potential audits? Join our host, Brittany Hardin Tanguay, alongside Jack O'Meara and Prita Subramanian, both Principals in the KPMG U.S. Washington National Tax Practice, as they answer these questions and unpack the results of a recent survey conducted at the KPMG 2024 U.S. Cross-Border Tax Conference.

From the Samba to Merengue, exploring the tax dance in the Latin American region. Rhumba-ing into the complicated dance of transfer pricing controversy, this episode discusses the tax controversy trends seen in the region of Latin America, or LATAM. What avenues are there for companies to address tax certainty and controversy in LATAM? Which transactions draw the most scrutiny for the LATAM tax authorities? And how can companies look to mitigate some of the risks of operating in the LATAM region? Join our host, Brittany Hardin Tanguay, as she explores the secret spices of LATAM tax issues with Alejandro Barran, Partner, Tax - Transfer Pricing, KPMG Mexico, former head of the Competent Authority office in Mexico in charge of the Advance Pricing Agreements and Mutual Agreements Procedures, and Juan Carlos Vidal, Partner, Tax - KPMG Peru. Together, they explore the transfer pricing issues and difficulties operating within the LATAM region.

From cliffs to castles, exploring the tax terrain of Ireland and the UK. Diving into the stormy seas of transfer pricing disputes, this episode unveils the escalating challenges and evolving trends in the United Kingdom and Ireland. How has Brexit reshaped the transfer pricing relationship between the competent authorities in Ireland and the UK? What impact has the OECD and G20's Base Erosion and Profit Shifting, or BEPS, initiative had on transfer pricing disputes in these regions? And how effective are tools like Advance Pricing Agreements, or APAs, and Mutual Agreement Procedures, or MAPs, in mitigating these disputes? Join our host Brittany Hardin Tanguay as she and her guests Neil Casey, Partner, Transfer Pricing, KPMG Ireland and Nick Stevart, Director, Global Transfer Pricing Controversy Management, KPMG UK explore the latest trends, notable cases, and the evolving landscape of transfer pricing in these two jurisdictions.

Trim down with legal entity rationalization and streamline your transfer pricing. Legal entity rationalization, a strategic method of streamlining corporate structures, plays a pivotal role in enhancing business efficiency and cost-effectiveness. But how does this process help businesses meet their objectives? And what is its significance in the face of ever-changing tax landscapes and regulatory requirements? In this episode, we discuss how businesses are assessing their current legal entity structure, as well as how and why they pinpoint opportunities for rationalization, all while considering transfer pricing. Join our host, Brittany Hardin Tanguay, as she delves into this captivating discussion with Ashley Marx, Managing Director, Tax - Mergers and Acquisitions (KPMG US), and Adam Kelfer, Managing Director, Tax - Transfer Pricing (KPMG US).

Unlocking the potential of GenAI throughout the Transfer Pricing lifecycle. Within the complex landscape of transfer pricing, the introduction of generative artificial intelligence (GenAI) is stirring up a new era of possibilities. But how is GenAI influencing this multifaceted field? What novel trends are emerging, propelled by GenAI advancements? And how should we incorporate this cutting-edge technology into the traditional transfer pricing approach? Delve into the discussion as we navigate the exciting intersection of GenAI and transfer pricing. Join our host Brittany Hardin Tanguay as she poses the questions you asked at TP Minds held in San Francisco last December, to Thomas Herr, KPMG US National Leader in Transfer Pricing and Innovation. Listen as Thomas reflects on how AI will automate and transform transfer pricing in the future.

From canals to autobahns, traversing the European tax controversy landscape. In the intricate realm of transfer pricing, tax controversies and disputes present a unique set of challenges. But how are these challenges being addressed in Europe, particularly in Germany and the Netherlands? What trends are emerging in these jurisdictions? And how is the concept of joint audits being leveraged as a potential solution? Join our host Brittany Hardin Tanguay as she explores these questions with Jens Lamberg Karremen (Partner, KPMG Netherlands) and Holger Peters (Partner, Head of Global Transfer Pricing Dispute Resolution Services in KPMG Germany). They share their experiences and insights on the current landscape, discuss the increasing scrutiny of transfer pricing arrangements, and introduce to us KPMG's initiative to coordinate tax and transfer pricing dispute resolution work globally.

Beyond Controversy: The collaborative landscape of transfer pricing disputes. In the complex world of transfer pricing, setting the right price for intercompany transactions is both a science and a subjective process. But how does this play out in the face of international disputes? Where do treaty-based resolutions like the Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) fit into this puzzle? And just how pivotal are these tools in providing certainty and preventing double taxation? Join our host, Brittany Hardin Tanguay, as she navigates this fascinating discussion with Lillie Sullivan (Senior Manager, KPMG US: Washington National Tax - Controversy and Dispute Resolution), and Joshua McConkey (Managing Director, KPMG US: Washington National Tax Controversy and Dispute Resolution).

Cupid's arrow has struck the heart of many curious people, leading them to transfer pricing. Prepare to be smitten as we delve into the hearts of multiple transfer pricing professionals, the matchmakers of the corporate world, who work to harmonize the rhythm of regulatory compliance with the melody of business objectives in a symphony of economic strategy. Whether it was love at first sight or a slow-burning passion, their stories are a testament to the dynamic, challenging, and rewarding nature of a career in transfer pricing. So, grab a box of chocolates and join us as we pen a love letter to transfer pricing, and perhaps inspire the next generation of romantics in this crucial and captivating sector of the global economy. In this very special episode of Exploring Transfer Pricing, our host Brittany Hardin Tanguay revisits some of her heartfelt conversations with previous guests of the program, including Robin Archer, Director, KPMG UK, Enrique Martin, Principal, KPMG US, Sayantani Ghose, Principal, KPMG US, Diana Shkodina, Principal, KPMG US, Nick Stavrakis, Managing Director, KPMG US, Brad Parker, Principal, KPMG US, and David Unger, Managing Director, KPMG US.

Charting out the OECD's 2022 Mutual Agreement Procedure (MAP) Statistics to appreciate how effective MAP is in resolving transfer pricing disputes. The OECD released the 2022 Mutual Agreement Procedure (MAP) Statistics and announced its much heralded MAP Awards, the Transfer Pricing equivalent of the Oscars. When a multinational is subject to a transfer pricing adjustment, MAP is a process the taxpayer can invoke to avoid double taxation. The MAP statistics provide multinationals with important insights into how well MAP relationships are working. Our host Brittany Hardin Tanguay is joined by Phil Roper, a Partner from KPMG UK, and Thomas Bettge, a Senior Manager in Washington National Tax, to discuss their impressions from the latest release of MAP Statistics.

Our host Brittany Hardin Tanguay is joined by Maggie Fritz, a Tax Principal and the global banking leader for transfer pricing, and Brie Siciliano, a Managing Director for Tax specializing in financial services. Together, they'll unravel the complexities that the banking industry encounters when enacting transfer pricing.

2023 has been a rollercoaster in the world of international tax and transfer pricing - and 2024 looks to be more of the same. As 2023 draws to a close, we delve into the key tax initiatives that have shaped the transfer pricing landscape over the past year. This episode navigates through topics ranging from the OECD's Pillar One and Pillar Two, to the adoption of the OECD Guidelines by Brazil and the impact of economic uncertainty and evolving business models on transfer pricing. Our host Brittany Hardin Tanguay is joined by Jessie Coleman, a Principal in Washington National Tax, to discuss highlights from the previous year, as well as the challenges and opportunities that lie ahead in the realm of transfer pricing.

Hammering out transfer pricing challenges in the building, construction, and real estate industry. Building on our Transfer Pricing Industries Series, we have constructed an episode on the specialized transfer pricing issues faced by the building, construction, and real estate, BCRE, industry. The uniqueness of the underlying assets influence how transactions are valued, and how to price the associated transactions around it. With a large diversity in the types of transactions and assets, transfer pricing practitioners must rely more heavily on sound economic principles. Our host Brittany Hardin Tanguay is joined by Weston Krider, a KPMG Transfer Pricing Managing Director based in Los Angeles and rejoined by Sharon Liu, a KPMG Transfer Pricing Principal in Economic and Valuation Services to discuss some of the key issues of transfer pricing within the building and construction industry.

Our host Brittany Hardin Tanguay is joined by Stephen Giordano, KPMG Partner, Washington National Tax, focused on Business Tax Services - Passthroughs, and Sharon Liu, KPMG Principal, Tax - Transfer Pricing, to discuss some of the key issues of transfer pricing within the REITs realm.

Our host Brittany Hardin Tanguay is joined by Diane Shkodina, Managing Director, Tax - Transfer Pricing, and Nick Stavrakis, Managing Director, Tax - Transfer Pricing to discuss the challenges transfer pricing practitioners are facing with developing an arm's-length transfer pricing range for North American retail distribution companies and beyond

Going Dutch on testing financial transactions! In this episode we explore the Chapter 10 OECD Guidelines involving financial transactions with our KPMG Netherlands colleagues. The Netherlands has long been known as a financial services transaction hub and integral for multinational enterprises' treasury functions - why has this historically been the case? What are some of the major transfer pricing issues involving these Dutch financial entities? How does the Dutch Tax Authority reconcile the OECD Guidelines vs. Dutch Tax Laws? What role does risk play in determining the type of financial entity? If you are interested in financial services hubs, OECD Guidelines, and beautiful fields of never-ending tulips, strap on your clogs!

If Amount B is supposed to simplify transfer pricing, why does it seem so complicated? Listen as we break it down. In this episode we explore the major announcement regarding Amount B released this week by the OECD with our KPMG knowledge leader from London. On Monday July 17, we got the latest update from the OECD on its efforts to simplify transfer pricing through Amount B, part of its BEPS 2.0 initiative to address the tax challenges of digitalization. What will this mean for multi-nationals cross-border transaction, transfer pricing policy, and future transfer pricing planning? Will Amount B actually apply to digital businesses? With all of the news regarding Amount B, we will break down the announcement and address some of the potential implications.

Your transfer pricing is in good hands, because we've seen a situation or two. The insurance industry and its representatives exist to make people's bad days less bad. Insurance provides protection for what matters most, but how do you transfer price for managing risk? If you're unsure how reinsurance works for cross-border intercompany transactions, we've got you covered! As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.

Why can't all my profit just go to an offshore haven? KPMG explains Asset Management transfer pricing in a post-BEPS world. Investment committees, sub-advisors and referral fees - Oh My! How should asset management tax practices battle the nuances of splitting highly lucrative asset management returns across their global footprints? In an industry which faces commercial pressure, non-tax regulators, and a minefield of BEPS exclusions, navigating the specific intercompany relationships within asset management may seem daunting. Tax authorities are taking very different approaches to the asset management industry, and conquering the compliance and planning opportunities has never been more timely. As part of our Industry Series, Exploring Transfer Pricing tours different industries with specialists to discuss some of what makes their industry of focus unique, and how that might impact the transfer pricing.

Perform a check-up on your company's financial health before stressing it with debt. We've established that everybody borrows, meaning that multinational enterprises in every industry are likely to engage in some level of intercompany financing. But how is it actually done? What parts of the business need to work together, and what considerations often get overlooked when setting interest rates on these loans between related parties? Join us to learn more, and to appreciate some of the nuances that must be reflected in each transfer pricing analysis.

Listen in to learn why some subsidiaries can be viewed as the black sheep of the family, while others as the next in line to run the business.

Open your eyes to the often complex and always fascinating world of transfer pricing in the life sciences industry.

The largest economy in South America has always been the exception when it comes to global transfer pricing, all of which appears likely to change

Have you ever thought transfer pricing could be simpler and more standardized? Are you tired of arguing about routine distribution returns? If you are, Amount B might be the solution for you.

There's a lot for transfer pricing to account for in the financial services industry. Because it can be a bit of a balancing act - listen to this episode to have it make cents!

Plug in, reboot, and join us for our latest version - er, episode - where we look at transfer pricing as it relates to the technology industry. It's a little more complicated than just clicking CTRL-ALT-DELETE.

What's it like to be in the driver's seat of practicing transfer pricing in the Industrial Manufacturing Automotive industry? Strap in to learn from industry veterans.

The space between two pillars. Pillars One and Two attempt to restabilize a system that is increasingly difficult for taxpayers to manage.

Discussing why OTP has become more important than ever.

Environmental effects on our planet. Social impacts in our communities. Governance results in reporting and structure. Where does transfer pricing fit into ESG?

Is it Local? When it comes to country-specific Transfer Pricing reports, acclimate yourself to the local terminology, and don't get tripped up by the different titles and requirements.

In this episode we discuss the mastery of the Master File, aka, the bass line in the symphony of global transfer pricing documentation.

With the onset of public country-by-country reporting - coordination, transparency, and analysis is key. Learn about some of the risks and mitigation tools and practices associated with interpreting data.

Step by step, country-by-country, tax authorities and taxpayers get closer and closer in sync.

Meet the global transfer pricing reporting trinity - Country by Country, Local File, and Master File. Learn how the Global Transfer Pricing Review makes it easier to manage.

How is it possible to simulate independence when your companies aren't? Find out more about why transfer pricing is so concerned with arm's length results.