Kristina Novak and John Cianfrone sit down with Mona Cairncross for an inside look at global transfer pricing negotiations and lessons from her time as Assistant Director of the IRS APMA Program.

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This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement.

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This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments.

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This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks.

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Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape.

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Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing.

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David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues.

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Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.

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In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.

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Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today.

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