As cross-border activity becomes increasingly common for middle-market companies, international tax considerations are no longer limited to large multinationals. From transfer pricing and tariffs to global tax compliance and planning, businesses expanding overseas face greater complexity and heightened scrutiny from tax authorities worldwide. Understanding where value is created, how intercompany transactions should be priced, and how global tax rules interact is critical for managing risk and supporting sustainable international growth.

In this episode, Brooks Nelson, Tax Partner, and Sarah McGregor, Tax Director, are joined by Nelson Yates, Partner and International Tax Leader, to discuss key cross-border tax issues middle-market CFOs and business leaders should have on their radar. They break down transfer pricing fundamentals, explore how tariffs intersect with intercompany pricing, and share practical considerations for companies entering or expanding in foreign markets.

Listen to learn more about:

• 02:30 – Transfer pricing basics and why it matters
• 04:10 – How governments view cross-border profit allocation
• 06:27 – Intercompany services, IP, and value drivers
• 10:38 – Marketing intangibles and local market investment
• 11:55 – Practical steps CFOs can take today
• 14:45 – Transfer pricing documentation and penalty protection
• 16:35 – Tariffs and their interaction with transfer pricing
• 20:20 – Global tax planning and compliance implications
• 22:42 – International expansion costs and best practices

Related Guidance 

• Article: Navigating the International Tax Landscape After 2025 Tax Reform