Transfer pricing is one of the most important concepts in corporate finance, international tax, and multinational business strategy. 

In this episode of Corporate Finance Explained, we break down how multinational corporations allocate profits across countries, how profit shifting works, and why transfer pricing disputes involving Apple, Coca-Cola, Amazon, Microsoft, and Starbucks have reshaped global tax policy.

You’ll learn how transfer pricing works, how the arm’s length principle is applied, and why OECD BEPS rules, Country-by-Country Reporting, and Pillar Two are changing the future of international taxation and corporate finance.

This episode explores:
• What transfer pricing is and why multinational corporations use it
• The arm’s length principle explained
• OECD transfer pricing methods and profit allocation
• How Apple structured profits through Ireland
• Why Coca-Cola, Amazon, Microsoft, and Starbucks faced tax disputes
• OECD BEPS and Country-by-Country Reporting rules
• Pillar Two and the global minimum corporate tax
• Why economic substance now matters more than tax arbitrage
• How transfer pricing impacts valuation, treasury, FP&A, and corporate strategy

If you work in corporate finance, accounting, investment banking, FP&A, tax, treasury, consulting, or multinational operations, understanding transfer pricing is becoming increasingly important as global tax enforcement evolves.

Chapters:
00:00 Introduction
01:45 What transfer pricing actually is
04:20 The arm’s length principle explained
07:10 OECD transfer pricing methods
09:20 Apple’s €13B EU tax case
12:05 Amazon, Starbucks, Coca-Cola, and Microsoft disputes
16:00 OECD BEPS and Country-by-Country Reporting
19:30 Pillar Two and the global minimum tax
21:15 What finance professionals should do now

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