Special Edition – Financial Transactions Transfer Pricing
In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief.Support the show
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Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025
In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership changes, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing—particularly under a second Trump administration.Support the show
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Episode 112: Special Edition – Financial Transactions Transfer Pricing
In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) is joined by Shereen Osman (Financial Services Assurance Director and PwC’s Global Islamic Finance practice co-leader, PwC UAE) and Zachary Noteman (PwC’s Middle East Financial Transactions TP Leader). They discuss aspects of Islamic financing and its intersection with transfer pricing. They then explore what Islamic (or Sharia) financing entails and its distinguishing characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial transactions for transfer pricing purposes, and the broader societal contributions of Islamic finance through Zakat, a wealth-based charitable contribution, and its implications for transfer pricing.Support the show
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Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world
In this TP Talks episode, Kristina Novak is joined by Kristin Bohl to discuss the transfer pricing aspects of the current customs and trade environment.Support the show
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Episode 110: Transfer Pricing in the Middle East: Opportunities abound
In this TP Talks episode, Kristina Novak sits down with Steven Cawdron and Zachary Noteman to discuss the evolving transfer pricing environment in the Middle East.Support the show
Om TP Talks - PwC's Global Transfer Pricing podcast
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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