TP Talks - PwC's Global Transfer Pricing podcast

In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Kristina Novak and Andrew Kim (Transfer Pricing Principals in PwC’s US National Tax Services practice) to discuss recent trends and outlook with respect to US transfer pricing controversy, and steps taxpayers should consider to avoid potential risks.  

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In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Niek van der Put (Transfer Pricing Director, PwC Netherlands), Neil Schaatsbergen (Transfer Pricing Director, PwC Netherlands), and Aleks Davydov (Transfer Pricing Senior Manager, PwC Netherlands). They discuss two decrees recently published by the Dutch tax authorities related to transfer pricing and the attribution of profits to permanent establishments, exploring what’s in the decrees, the potential impact for companies, and what actions taxpayers should take.  

See also: Dutch Ministry of Finance publishes new transfer pricing decree

Contacts: David Ernick, Niek van der Put, Neil Schaatsbergen, Aleks Davydov

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In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax Services practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the Pillar Two discussion, focusing on the  commentary published in March and how it has slightly reinterpreted the role of transfer pricing in Pillar Two; developments in Europe, including the UK stakeholder consultation and the ECOFIN progress regarding implementation of Pillar Two within the European Union; US developments; and the transfer pricing implications in instances of double taxation in the Pillar Two system.

Stay tuned for future TP Talks podcasts covering Pillar Two developments. 

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In this TP Talks podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Michel van der Breggen (Transfer Pricing Partner, PwC Netherlands), Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), and Rui Yuan (Transfer Pricing Manager, PwC Netherlands) talk about sustainable financing and what it means for transfer pricing. They first share some observations on the sustainable wave in the capital markets. The panelists then discuss some of the potential transfer pricing challenges that are expected to emerge with the current rapid developments in sustainable financing. 

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In this TP Talks episode, Erin March (Transfer Pricing Principal, PwC US), Dennis Tingey (Tax Services Partner, PwC US), and Marco Fiaccadori (Transfer Pricing Principal, PwC US National Tax Services) discuss the R&D capitalization requirements under the new US § 174 regulations, focusing on transfer pricing-related questions and issues, including the definition of amortization under Section 174, primary issues taxpayers are dealing with post-Q1, impact on key U.S. international tax provisions, contract R&D/R&E arrangements, and the interplay of Section 174 capitalization and the cost sharing rules under Section 1.482-7.

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In this podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Ed Baghdasarayan (Transfer Pricing Partner, PwC Australia), Dan Pybus (Transfer Pricing/EMEA Financial Transactions TP Leader, PwC UK), and Bob Ritter (US Financial Transactions Transfer Pricing Leader) discuss the 2022 outlook for financial markets and policy environment, focusing on trends with regard to interest rates and debt leverage; ESG and sustainable financing; transfer pricing court cases; other general tax initiatives impacting financing; key takeaways from the US final regulations on the LIBOR transition; emerging practices in the market regarding intercompany finance policies; and cryptocurrency.

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This TP Talks podcast features discussion of the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation.

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In this Financial Transactions Transfer Pricing quarterly podcast, Bob Ritter (PwC’s US Financial Transactions Transfer Pricing leader) is joined by Laura Valestin (Partner in PwC’s National Tax practice in Washington DC, specializing in financial products), and Chad Clark (Director in PwC’s Financial Markets and Real Estate practice, based in Austin, TX) to discuss LIBOR and the final regulations released by the IRS and US Treasury that provide tax guidance with respect to alterations to debt instruments, derivative contracts, and other contracts that replace interbank offered rates with qualified replacement rates, or fallback replacement rate provisions. They also highlight changes from the proposed regulations and provide key considerations for companies. 

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In this episode, we feature an excerpt from PwC’s Global Transfer Pricing Conference, focusing on ESG factors as drivers of value creation and levers to manage risks, concentrating on supply chain/value chain analysis, tax transparency, intercompany financial transactions, and deals. The panelists included Ronan Finn (Ireland TP country leader and PwC’s global TP ESG leader), Jayde Thompson (Transfer Pricing partner – PwC Australia), Noor Sanders (Transfer Pricing partner – PwC Netherlands), and Shane McEvoy (Transfer Pricing partner – PwC US). 

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In this TP Talks episode, Lauren Dangelmayr (Principal, Transfer Pricing - PwC US), Hamish McElwee (Partner, Transfer Pricing - PwC Australia), Szymon Wlazlowski (Transfer Pricing - Energy, Utilities and Resources Leader for EMEA), Ivan Williams (Partner, Transfer Pricing -  PwC Canada), and Thushara Corea (Director,Transfer Pricing - PwC Canada) discuss the oilfield services industry, focusing on planning related to leasing and IP, ESG, as well as pragmatic approaches to transfer pricing documentation.

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