In this TP Talks episode, transfer pricing professionals discuss the latest progress related to transfer pricing in China to help manage risk and enhance tax certainty, including the issuance of a Q&A on the administration of forex cash in-flows and out-flows of transfer pricing adjustments, China State Taxation Administration’s issuance of a Consultation Draft on the simplified procedure for unilateral Advance Pricing Arrangements and the potential benefits, as well as other observations. For more information, see our Tax Insights: China issues Q&A regarding the administration on forex cash in-flows and out-flows of TP adjustments and China STA issues consultation draft on simplified procedure for unilateral APAs.

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This podcast features a discussion of the UK’s proposed changes to its transfer pricing documentation rules, including novel features for taxpayers to consider.

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In this Special Edition Financial Transactions Transfer Pricing podcast, David Ledure (Transfer Pricing Partner, PwC Belgium), Tanja Keser (Transfer Pricing Partner, PwC Germany), Erin Venter (Transfer Pricing Partner, PwC New Zealand), and Agustin Aila (Transfer Pricing Senior Manager, PwC Argentina) discuss new developments, including pending legislation in Germany related to new requirements for interest deductions; New Zealand’s recently enacted Restricted Transfer Pricing rule for inbound related party debt; and new rules in Argentina impacting intercompany financing.  The group also discusses debt capacity and controversy generally.

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In this episode, our Transfer Pricing professionals discuss their recent experience with APAs in Japan and the US generally, as well as touch on bilateral APAs between the US and Japan.  The panelists focus on lessons from prior economic downturns and how an APA can be a tool to manage uncertainty. The panelists also discuss maximizing the utility of an APA for triangle transactions, US APMA’s outlook on APAs, and takeaways. 

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This episode features a discussion of how companies can utilize automation for both large and small scale transfer pricing transactions, including automation of transfer pricing adjustments, profit monitoring and allocation, and specific processes and transfer pricing calculations.

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This TP Talks Special Edition quarterly podcast features a regional update on Chapter X of the OECD Guidelines, regulatory changes, market conditions and the pandemic, as well as an update on LIBOR.

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This episode features a discussion of how companies may address the impact of the pandemic on their business for transfer pricing purposes. The panelists address how companies can use publicly available information on third-party behavior to support their business decisions stemming from economic disruptions, focusing on actions to take in the immediate, near term, and a long term.

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This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.

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TP readiness amid economic uncertainty —Tax controversy: Is transfer pricing low hanging fruit for tax authorities? 

This TP Talks Special Edition podcast focuses on transfer pricing controversy, specifically as it relates to government subsidies in response to the current economic crisis and the resulting transfer pricing challenges multinationals may face when governments look to recover subsidies. The panelists provide insights on what steps companies can take today to prepare for potential transfer pricing audits.

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In this TP Talks Special Edition podcast, Kartikeya Singh (Transfer Pricing Partner, PwC US), Marta Milewska (Transfer Pricing Partner, PwC Mexico), and Paul Tang (Transfer Pricing Partner, PwC China) discuss transfer pricing benchmarking and data limitations impacting comparability, delineating atypical conditions, and adjustments or refinements that may be considered to improve comparability in light of the current economic climate.

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