Start / TP Talks – PwC’s Global Transfer Pricing podcast / Episode 88 us tp controversy trends and outlook

TP Talks – PwC’s Global Transfer Pricing podcast

Episode 88: US TP controversy trends and outlook

27 min • 20 september 2022

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.

Episode 88: US TP controversy trends and outlook

Senaste avsnitt

Special Edition – Financial Transactions Transfer Pricing

Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025

Episode 112: Special Edition – Financial Transactions Transfer Pricing

Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world

Episode 110: Transfer Pricing in the Middle East: Opportunities abound

Episode 109: Brazil’s big shift: The new transfer pricing reality

Episode 108: Special Edition – Financial Transactions Transfer Pricing

Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves

Episode 106: CbCR: The evolving landscape

Episode 105: Special Edition – Financial Transactions Transfer Pricing

Episode 104: Who bears the risk? Navigating HMRC’s guidance

Episode 103: Pricing intercompany loans: why implicit support matters

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

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

Episode 100: Perspectives on China and India

Episode 99: More pain? A review of the transfer pricing controversy environment

Episode 98: Pillar One Amount B: Reading the tea leaves

Episode 97: Transfer Pricing: Exploring the past, present, and future

Episode 96: Operational Transfer Pricing: A catalyst to unlock potential in tax and beyond

Episode 95: Special Edition – Financial Transactions Transfer Pricing (June 2023)

Episode 94: Brazil’s transfer pricing rules: A shift to international standards

Episode 93: The endgame begins – Navigating TP implications in the Pillar Two world

Episode 92: Special Edition – Financial Transactions Transfer Pricing (March 2023)

Episode 91. Business transformation – when ESG, value chain, and transparency converge

Episode 90: Transfer pricing in Africa from a bird’s-eye view

Episode 89: EU and UK TP controversy trends and outlook

Episode 88: US TP controversy trends and outlook

Episode 87: Winds of change: New Dutch transfer pricing and PE rules that can impact your business

Episode 86: The middlegame – Pillar Two strategy for transfer pricing evolves

Episode 85: Special Edition – Financial Transactions Transfer Pricing (June 2022)

Episode 84: US § 174 – getting your arms around the new R&D capitalization rules

Episode 83: Special Edition – Financial Transactions Transfer Pricing (March 2022)

Episode 82: The opening – Transfer pricing is a critical piece of the Pillar Two chessboard

Episode 81: Special Edition – Financial Transactions Transfer Pricing

Episode 80: Putting the TP into ESG

Episode 79: Special Edition – TP in the oilfield services industry (Part 2)

Episode 78: Special Edition – TP in the oilfield services industry (Part 1)

Episode 77: Special Edition – Financial Transactions Transfer Pricing (September 2021)

Episode 76: The new world tax system – what it means for your company

Episode 75: Pillar One update: details of the OECD/G20 Inclusive Framework Statement

Episode 74: A dialog on German transfer pricing developments

Episode 73: Financial Transactions Transfer Pricing – June 2021

Episode 72: Domestic US Transfer Pricing - what state taxing authorities have on their agenda

Episode 71: China transfer pricing updates – a focus on clarity and simplification

Episode 70: Keeping pace with changes to UK transfer pricing documentation rules

Episode 69: Financial Transactions Transfer Pricing – March 2021

Episode 68: Advance Pricing Arrangements – a reliable tool for managing TP risk on the path forward

Episode 67: TP Automation – efficiencies for projects of any size

Episode 66: Financial Transactions Transfer Pricing – December 2020

Episode 65: TP Readiness amid economic uncertainty – Using third-party behavior to support business decisions

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

Episode 63: TP readiness amid economic uncertainty — Tax controversy: Is transfer pricing low hanging fruit for tax authorities?

Episode 62: TP readiness amid economic uncertainty: Comparability considerations and challenges

Episode 61: TP readiness amid economic uncertainty: Financial Transactions

Episode 60: TP readiness amid economic uncertainty: Transfer pricing and policies

Episode 59: TP readiness amid economic uncertainty: Customs and trade

Episode 58: TP readiness amid economic uncertainty: Operations and supply chain

Episode 57: Mexican tax reform from a transfer pricing perspective

Episode 56: TP readiness amid economic uncertainty - Liquidity and cash management

Episode 55: Special Edition - Impact of OECD final FT paper - Americas region

Episode 54: Special Edition - Impact of OECD final FT paper - Asia Pacific region

Episode 53: Special Edition - Impact of OECD final FT paper - EMEA region

Episode 52: TP implications of the Final and Proposed BEAT regulations

Episode 51: OECD proposal for profit allocation under Pillar One

Episode 50: India transfer - what does the future hold?

Episode 49: Latest developments in the Middle East transfer pricing landscape

Episode 48: Key changes in Hong Kong transfer pricing

Episode 47: US transfer pricing - a review of top developments in 2019

Episode 46: Impact of today's issues on your transfer pricing

Episode 45: ATO PCG on inbound distribution arrangements - what it means for multinationals operating in Australia

Episode 44: Swiss tax reform - key transfer pricing considerations

Episode 43: Intra-group services in the post-BEPS era: A look at Japan and Vietnam

Episode 42: BREXIT from a transfer pricing lens

Episode 41: Taxing Digitalisation

Episode 40: Special Edition - Digital solutions and transfer pricing - developments going on in the ERP landscape

Episode 39: Special Edition - Transfer pricing compliance - A look at TP documentation and CbC reporting

Episode 38: Draft TP By-Laws published in Saudi Arabia - a landmark moment

Episode 37: Transfer Pricing - catalyst or speedbump on the global trade highway?