In this TP Talks episode, Kristina Novak is joined by Kristin Bohl to discuss the transfer pricing aspects of the current customs and trade environment.

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In this TP Talks episode, Kristina Novak sits down with Steven Cawdron and Zachary Noteman to discuss the evolving transfer pricing environment in the Middle East.

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In this TP Talks episode, Kristina Novak sits down with Marcelo Vieira to discuss the progress of Brazil’s overhaul of its transfer pricing regime.

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Debt capacity 

In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers.

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This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1

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This TP Talks episode addresses the evolution of country-by-country reporting (CbCR) as it relates to the OECD’s Pillar Two Transitional CbCR Safe Harbor and Public CbCR.

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This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada.

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In this episode of TP Talks, Kristina Novak sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC on identifying and pricing contributions to risk control by decision-makers.

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This TP Talks episode features a discussion of the recent IRS administrative guidance  regarding implicit support and its impact on the pricing of intercompany loan transactions, both from a US and global perspective.

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In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways.

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