TP Talks - PwC's Global Transfer Pricing podcast

Special Edition – Financial Transactions Transfer Pricing


Listen Later

In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief.

Support the show

...more
View all episodesView all episodes
Download on the App Store

TP Talks - PwC's Global Transfer Pricing podcastBy PwC

  • 4.8
  • 4.8
  • 4.8
  • 4.8
  • 4.8

4.8

17 ratings


More shows like TP Talks - PwC's Global Transfer Pricing podcast

View all
Motley Fool Money by The Motley Fool

Motley Fool Money

3,178 Listeners

EY Cross-Border Taxation Alerts by Ernst & Young

EY Cross-Border Taxation Alerts

12 Listeners

PwC's accounting podcast by PwC

PwC's accounting podcast

177 Listeners

Odd Lots by Bloomberg

Odd Lots

1,775 Listeners

The Daily by The New York Times

The Daily

111,562 Listeners

Talking Tax by Bloomberg Tax

Talking Tax

110 Listeners

Tax Notes Talk by Tax Notes

Tax Notes Talk

91 Listeners

Cross-border Tax Talks by PwC

Cross-border Tax Talks

111 Listeners

The Journal. by The Wall Street Journal & Gimlet

The Journal.

5,923 Listeners

Hard Fork by The New York Times

Hard Fork

5,438 Listeners

Inside International Tax by KPMG LLP (U.S.)

Inside International Tax

39 Listeners

EY Transfer Pricing Roundup by EY - International Tax and Transaction Services

EY Transfer Pricing Roundup

9 Listeners

The Economics Show by Financial Times

The Economics Show

115 Listeners