Exploring Transfer Pricing

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 is joined by (Managing Director, Washington National Tax - International Tax) and (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 as she, along with her guests (Principal and National Transfer Pricing Advisory Leader), and (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 as she, along with her guests (Managing Director, Tax, ) and (Managing Director, Tax, ), 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.