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. Support the show

Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint

PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.

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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. Support the show

Episode 103: Pricing intercompany loans: why implicit support matters

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. Support the show

Episode 102: Stock-based compensation: One size does not fit all

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Jessica Yin (Transfer Pricing Partner, PwC Shanghai), Rong Zhen (Corporate Tax and Forex Partner, PwC Shanghai), and Nancy Chen (Transfer Pricing Senior Manager, PwC Shanghai) discuss why many MNCs operating in China have been more attentive to year-end transfer pricing adjustments (TPAs), what TPAs Chinese subsidiaries might need to undertake, the challenges cross-border TPAs present in China, and options available for MNCs to implement year-end adjustments. The speakers also address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry. Support the show

Episode 101: The time is now: year-end TP adjustments in China

This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show

Episode 100: Perspectives on China and India

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more. Support the show

Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint

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