PODCAST · business
Uncontrolled Opinions
by Silvana and Mikhail
All things transfer pricing. Uncontrolled Opinions is an open-ended exploration of all things transfer pricing. Silvana and Mikhail, share their views and insights from a practical transfer pricing economists lens.
Episodes
-
Interco Financing and Swaps
In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing. Part 1 — Intercompany Financing: Foundations, Challenges & Evolving Practice In Part 1, Mikhail and Silvana sit down with Adriaan to explore how...
-
Highlights from NABE 2025 TP Symposium
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2025 Transfer Pricing Conference. Mikhail and Silvana explore several of the most interesting panels, including: · Go Big or Go Home: Periodic Adjustments After the 2025 GLAM and…
more -
Why We Do This
For episode 13, we're getting personal! We're digging into why we started this podcast and the unplanned beginnings of our careers in transfer pricing. Get our "uncontrolled opinion" on why the TP world needs more open dialogue and less secrecy. It's time to pull back the curtain!
-
Economic Substance and TP
In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economic substance in the context of transfer pricing. We dive into the economic substance doctrine —its origins, why it was codified in Section 7701(o)…
more -
Amount B / SSA Refresher
In this episode, we refresh on Amount B / Simplified and Streamline Approach (SSA). We cover what has happened since February 2024. For a deeper dive, explore the resources below, including guidance, fact sheets, tools, and the full OECD report on Amount B: OECD Pillar One – Amount B OECD...
-
Transfer Pricing for Intragroup Loans
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing practitioner with deep expertise in intercompany (IC) financial transactions. Together, they dive into the foundational elements of transfer pricing...
-
Apple ECJ State Aid Case TP implications
In this episode, Mikhail and Silvana dive into the 2024 European Court of Justice (ECJ) decision on Apple’s contested tax arrangements in Ireland. While the heart of the matter centers on “illegal state aid,” the conversation highlights key transfer pricing concepts such as the arm’s length...
-
Country Risk Premium Adjustment in TNMM
In this episode of Uncontrolled Opinions, Mikhail and Silvana discuss the country risk premium adjustment when applying a Transactional Net Margin Method (TNMM). This discussion is particularly timely, given the recent emphasis on this adjustment in the OECD's Amount B guidance and its mandatory...
-
Public vs Private Companies in CPM/TNMM Analyses
In this episode of Uncontrolled Opinions, we explore the pros and cons of using public and private company data in the context of a TNMM or CPM analysis in transfer pricing. We discuss practical aspects such as data availability, quality, reliability, the impact of size and operating leverage…
more -
TNMM & Local Country Rules
In this episode, Silvana and Mikhail explore how local country-specific rules impact the use of the Transactional Net Margin Method (TNMM) in transfer pricing. They discuss how different regulations affect the selection of comparables and the calculation of the arm’s length range, using examples...
-
AI in Transfer Pricing
Is there a role for AI in transfer pricing? We believe the simple answer to this question is – yes – but with a few qualifiers. In this conversation, we dive into what is AI, Generative AI and how next-word prediction can and may be used in a transfer pricing context. While we are generally...
-
Highlights from the NABE TP Symposium 2024
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2024 Transfer Pricing Conference. Mikhail and Silvana explore several of the most interesting panels, including: · Geographic Market Adjustments in CPMs/TNMMs: Amount B and Beyond · AI...
-
What is Control?
What is “Control”? Nope we are not talking about Janet Jackson’s song. The raison d’etre in TP is pricing of “Controlled Transactions”. So, what is control? In this episode of Uncontrolled Opinions, hosts Silvana and Mikhail dive into the definition of “control” in the context of transfer…
more -
Arms' Length Range
Arm's Length Range: In this episode, Mikhail and Silvana dive into the intricacies of the arm's length range, the interquartile range, and various statistical methods used in transfer pricing. They discuss the importance of these concepts in their day-to-day practice and how the arm’s length…
more -
The Evolution and Impact of Amount B
In this Podcast, Silvana and Mikhail discuss the developments surrounding OECD Amount B guidance as it stands in March 2024. We explore the scope and criteria of Amount B, emphasizing its focus on tangible goods and excluding digital goods and services. We review the three-step pricing matrix and...
We're indexing this podcast's transcripts for the first time — this can take a minute or two. We'll show results as soon as they're ready.
No matches for "" in this podcast's transcripts.
No topics indexed yet for this podcast.
Loading reviews...
ABOUT THIS SHOW
All things transfer pricing. Uncontrolled Opinions is an open-ended exploration of all things transfer pricing. Silvana and Mikhail, share their views and insights from a practical transfer pricing economists lens.
HOSTED BY
Silvana and Mikhail
CATEGORIES
Loading similar podcasts...
Frequently Asked Questions
How many episodes does Uncontrolled Opinions have?
Uncontrolled Opinions currently has 15 episodes available on PodParley. New episodes are automatically indexed when they're published to the podcast feed.
What is Uncontrolled Opinions about?
All things transfer pricing. Uncontrolled Opinions is an open-ended exploration of all things transfer pricing. Silvana and Mikhail, share their views and insights from a practical transfer pricing economists lens.
How often does Uncontrolled Opinions release new episodes?
Uncontrolled Opinions has 15 episodes. Check the episode list to see recent publication dates and frequency.
Where can I listen to Uncontrolled Opinions?
You can listen to Uncontrolled Opinions on PodParley by clicking any episode. We provide an embedded audio player for direct listening, and you can also subscribe via your preferred podcast app using the RSS feed.
Who hosts Uncontrolled Opinions?
Uncontrolled Opinions is created and hosted by Silvana and Mikhail.
URL copied to clipboard!