ITR Voices

Former Internal Revenue Service commissioner Danny Werfel joins ITR editor Tom Baker for a wide-ranging episode of Taxing Times covering his tenure at the helm of the US tax authority and some of the biggest questions facing tax administrations today.

Werfel led the IRS twice, including serving as its 50th commissioner from 2023 to 2025. It makes Werfel one of the most high-profile guests to appear on Taxing Times, and the conversation contains plenty of must-listen moments.

As well as reflecting candidly on his experience running the IRS and the challenges of leading a major tax authority, Werfel offers his take on the state of the agency today, following drastic workforce reductions. 

The discussion then turns to the rapid development of AI and the risks it could create for tax systems.

Among the scenarios explored is a future in which AI agents are deployed on both sides of a tax audit, raising questions about independence, controls and how tax authorities and businesses should manage increasingly autonomous technology.

The discussion also ranges across tax administration, public-sector leadership and international cooperation, including the circumstances that might create new opportunities for consensus at the OECD.

We hope you enjoy listening.

Tax insurance is expanding beyond its traditional M&A roots as businesses, investors and advisers look for new ways to manage technical uncertainty, according to Rian Bahia, associate director in Howden’s tax and contingent risk team. 

Speaking to ITR Senior Reporter Sam Sholli on the latest episode of Taxing Times with ITR, Bahia explained how policies can cover known tax risks where a defensible position exists but the potential exposure is disproportionately large.

Bahia also outlined how the product developed alongside warranty and indemnity insurance, which generally covers unknown risks arising from transactions. Potential users now extend beyond private equity and real estate funds to corporates, lenders, insolvency practitioners, hedge funds and pension funds. 

The discussion also explored the wide range of issues that may be considered for cover, including corporate tax, VAT, employment taxes, withholding tax, permanent establishments and tax residence. 

We hope you enjoy listening.

Tax authorities are becoming more sophisticated, more data-driven and increasingly willing to scrutinise the reality behind multinational operating models, according to Ariane Calloud, a partner in Baker McKenzie's Paris tax dispute resolution practice. 

Speaking on the latest episode of Taxing Times with ITR, Calloud discussed how growing volumes of data, international information sharing and advances in AI are transforming tax audits and controversy work. 

In France, she said, transfer pricing (TP) remains a key focus, with authorities increasingly examining whether business operations, decision-making and value creation activities align with groups' transfer pricing policies. 

The conversation also explored how multinationals can reduce controversy risk before disputes arise. Calloud stressed the importance of understanding how local operations function in practice, regularly reviewing TP arrangements and ensuring consistency between tax positions and public-facing information.  

Looking ahead, Calloud predicted that tax authorities will continue to coordinate more closely across borders through simultaneous and joint audits. She also identified pillar two as a likely future source of controversy as administrations gain experience with the rules.

We hope you enjoy listening.

Amid a flurry of tax technology M&A this summer, Indian advisory firm Nexdigm struck a strategic alliance with Singaporean AI-enabled transfer pricing platform infer360. 

In this episode of Taxing Times with ITR, Editor Tom Baker sat down with Nexdigm's Maulik Doshi and infer360 co-founder Sunil Agarwal to dig deeper into the partnership and explore what the combined offering can deliver for clients across India, the UAE and beyond. 

Our guests also drew on their practical experience to share clients' top TP headaches, and discussed why the tax technology industry is consolidating and how India's professional services market is developing. 

We hope you enjoy listening. 

Earlier this year, Australian firm KordaMentha launched a dedicated tax disputes practice, recruiting Andrew Howell from PwC to help lead its push into a market that is becoming increasingly complex for multinational taxpayers. But what drew Howell to the firm, and where does KordaMentha see itself in Australia's evolving tax controversy landscape? 

In this episode of Taxing Times with ITR, ITR Editor Tom Baker speaks with Howell about KordaMentha's ambitions in the market and the opportunities created by a growing client shift from the big four.

The pair also discuss the Australian Taxation Office's current enforcement priorities, the transfer pricing (TP) and disputes issues causing the biggest headaches for taxpayers, and how Australia's approach compares with those of other leading jurisdictions.

Finally, they take a deep dive into the landmark PepsiCo dispute, which Howell led. They explore the key lessons for multinationals, the wider implications for TP practitioners, and what Howell hopes delegates will take away from his upcoming discussion on the case at ITR's Transfer Pricing Forum Europe.

We hope you enjoy listening.

Ryan has made major moves to expand its international footprint in recent years, including the acquisitions of Svalner Atlas and Dhruva Advisors. But what is driving the firm’s growth strategy, and where does it see itself in an increasingly crowded tax advisory market?

In this episode of Taxing Times with ITR, ITR Editor Tom Baker speaks with Tom Shave, president of Ryan’s Europe and Asia Pacific operations, about the rationale behind the firm’s recent dealmaking and the firm's lofty global ambitions.

The pair also discuss the intensifying battle for market share among tax-focused firms, including the rise of competitors such as Alvarez & Marsal Tax and WTS.

Finally, they consider how private equity investment is reshaping the profession. Is PE providing the capital and ambition needed to build global challengers, or does it risk changing the nature of tax advisory firms for the worse?

We hope you enjoy listening.

This month's Taxing Times with ITR delves into the rapidly unfolding KPMG Australia scandal and considers whether the big four firms have overarching cultural and governance issues that explain such persistent controversy. 

ITR Editor Tom Baker and Senior Reporter Sam Sholli also assess the market impact that the continued negative press around the big four could have on these firms.

Finally, Tom and Sam give a behind-the-scenes look into ITR's new weekly news analysis format: Beyond the Headlines. In the discussion, Tom analyses whether technology-backed transfer pricing consultancies could pose a threat to traditional advisory firms, while Sam explores how and why tax is rising up the law firm merger agenda. 

We hope you enjoy listening. 

In the latest episode of Taxing Times with ITR, Editor Tom Baker and Senior Reporter Sam Sholli delve into Ryan's headline acquisition of European tax firm Svalner Atlas, and consider how transformational the buyout could be in Ryan's quest for global advisory reach.

Tom and Sam also explore a surge in private client tax advisory work and what is driving demand across the market. The discussion considers how firms are responding to increasingly complex cross-border needs, and how those unequipped to capitalise on the demand risk leaving money on the table. 

Finally, the episode examines the recent "common understanding" that allows jurisdictions to waive penalties for late pillar two filings due to a lack of available portals. 

We hope you enjoy listening. 

ITR’s latest podcast features an in-depth conversation between ITR Editor Tom Baker and Jeff Soar, CEO of the newly launched WTS UK, offering listeners an early look at the firm’s strategy and ambitions in the UK market.

In the episode, Soar opens up about WTS UK’s positioning – including how the firm intends to differentiate itself from the big four and compete for high-end advisory work. 

The podcast also explores Soar’s personal decision to join WTS UK and his perspective on the evolving tax partner recruitment market, with candid reflections on what is driving movement at the senior level.

Finally, Baker and Soar reflect on April's ITR AI in Tax Forum, sharing their highlights from a timely and action-packed agenda.

We hope you enjoy listening. 

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead.

While tax is commonly regarded as one of two certainties in life, many questions remain concerning pillar two. Are there downsides to the side-by-side package announced in January 2026? Is the new simplified effective tax rate safe harbour truly simpler in practice? Are further OECD measures on the horizon?

An ITR podcast recorded in partnership with Deloitte provides an inside track on the key pillar two issues as the following speakers explore the perspectives of clients, governments, and the OECD:

• Chad Hungerford, a partner in Deloitte Tax LLP’s international tax practice and Deloitte’s global pillar two leader; and
• Alison Lobb, a partner at Deloitte UK who specialises in international tax and policy.

From a US standpoint, Hungerford explains that the side-by-side agreement has helped ease political uncertainty and reduced the likelihood of top‑up tax for many, but also introduces a new layer of operational complexity. Lobb, meanwhile, believes that the measures represent just the “start of the simplification journey” and cites the OECD’s Amsterdam Dialogue in discussing the possibility of further reforms.

The conversation also examines the relationship between the new simplified effective tax rate and the transitional country-by-country reporting safe harbour, and the data and systems challenges confronting taxpayers and governments. For tax practitioners facing evolving compliance requirements, Hungerford says, “there’s a lot of work headed their way”. That much, at least, seems certain.