The LCN Legal Podcast

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The LCN Legal Podcast brings you expert views and analysis of the legal aspects of transfer pricing compliance. Our focus is always on real-world, practical insights that you can apply in your everyday work. We often feature interviews with experts within and around the international transfer pricing community. Hosted on Acast. See acast.com/privacy for more information.

08/29/2024

Episode 19: Practical challenges when implementing Amount B, with Robin Hart

Paul Sutton talks to Robin Hart – a Principal in Charles River Associates’ Transfer Pricing Practice, based in the San Francisco Bay Area – about the current status of Amount B. With an expected start date of 1 January 2025, and many important factors still unclear, it is a very significant challenge for many multinationals. Paul and Robin’s discussion covers: A recap of what Amount B is intended to achieve, and progress so farA summary of the current situationWhat we know at this time, and some very significant questions that are still unansweredThe incentives for some countries not to adopt Amount B, and some of the practical consequences that might resultHow multinationals should already be preparingSome of the challenges for multinationals in implementing Amount BPossible longer-term developments, including the Amount B approach being extended to other transaction typesKey takeaways for MNEs who are affected by these issues. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

33 min
08/02/2024

Episode 18: Effective project management, with Mick Edmondson

Paul Sutton talks to Mick Edmondson, who specialises in the project management of complex cross-border restructurings, including legal entity reduction / corporate rationalisation and digital transformation programs. They look at how to manage large-scale projects so that they deliver the intended results, the different methodologies that are appropriate in different situations, and some of the technology and tools that are available. Paul and Mick’s discussion covers: The definition of a project, and what distinguishes this from ‘business as usual’The cost / benefit analysis of devoting time and resource to project management, as opposed to ‘just getting on with it’The crucial importance of bringing together all the key stakeholders at the start, and getting top-level buy-inA basic framework process that helps to avoid common pitfallsSome potential consequences of not completing each stage before moving on to the nextThe main project management methodologies, and when each is appropriateThe key questions that a Head of Tax should address when considering starting a significant projectSome of the technology tools that are available, and how to use them most effectivelyKey takeaways for people who are contemplating a large or complex project. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

40 min
05/30/2024

Episode 17: Operating model effectiveness, with Sam Barrett, Ernst & Young LLP

Paul Sutton talks to Sam Barrett – Managing Director, Americas Operating Model Effectiveness, which is part of the International Tax practice at Ernst & Young LLP – about operating model effectiveness and global value chain projects. What are they, what do they try to achieve, and how can they be implemented successfully? Paul and Sam’s discussion covers: What operating model effectiveness aims to achieve, and howThe typical drivers behind operating model effectiveness and global value chain projectsHow the tax and transfer pricing teams should be involvedThe role of non-tax functions such as IT, HR and LegalGeneral principles and methodologies that can be appliedHow to make sure that, after implementation, projects have actually achieved the intended resultsThe main challenges for multinational groups’ tax functions over the next yearKey takeaways for heads of tax and their advisers. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

27 min
05/02/2024

Episode 16: Pareto optimality and its practical application in TP, with Philippe Penelle

Paul Sutton discusses the concept of Pareto optimality and its practical application in transfer pricing with Philippe Penelle, a Ph.D. economist with 25 years of TP experience. Philippe specialises in the valuation of intellectual property and the pricing of contractual contingent and derivative provisions. He is a former leader of the Washington National Tax Transfer Pricing Office of a Big Four Accounting Firm, and a member of the board of the National Association for Business Economics Transfer Pricing Symposium held annually in Washington, DC. Paul and Philippe discuss: What ‘Pareto optimal’ means in the context of controlled transactionsThe related concept of ‘moral hazard’, and how it featured in early OECD discussions regarding the BEPS projectThe implications for the four steps required when applying the arm’s length principle, including the role of agreements in substantiating Pareto optimalityExamples of transaction types for which the concept of Pareto optimality can create great clarityExamples of how Philippe has used this concept to achieve better outcomes for his clients in transfer pricing challengesKey takeaways for heads of tax and transfer pricing practitioners when designing transfer pricing policies. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

56 min
03/28/2024

Episode 15: The role of AI in transfer pricing and benchmarking, with Borys Ulanenko

Paul Sutton and Borys Ulanenko discuss the role of AI in benchmarking for transfer pricing, including the practical problems that AI can address, how AI can help TP professionals to demonstrate that their benchmark analyses are robust, and some common misconceptions around the use of AI. Borys is the founder of ArmsLength.AI. This platform introduces AI solutions to complex tax challenges, streamlining data analysis and enhancing decision-making accuracy. Before ArmsLength.AI, he worked at Aibidia, focusing on digital solutions in the same field. Paul and Borys discuss: The problems inherent in the benchmarking processThe challenges that TP professionals face when creating benchmarking analysesThe role of AI in addressing these issuesReal-world examples of how AI can make benchmarking analyses that are more robust, and demonstrably soExamples of what ArmsLength.AI does for its clients, and its pricing modelsCommon misconceptions around the use of AI, and what people should consider when assessing any AI tool on the market. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

41 min
02/28/2024

Episode 14: ESG and how it relates to tax, with Sue Bonney

Paul Sutton talks to Sue Bonney, an independent ESG adviser who works with senior people in some of the UK’s largest and most important organisations. In that role she helps business leaders to shape strategic responses to the responsible business agenda and ESG. Paul and Sue discuss: Four ‘lenses’ through which to view ESG issuesThe right way to approach ESG in order to see tangible and useful resultsHer view on ESG scores, and in what respects they can be meaningfulThe relationship between ESG and the standards of tax governance which tax administrations such as the ATO require from corporatesA specific example of a tax strategy statement published by a large corporate which Sue regards as well thought-outKey areas for action that Heads of Tax should considerWhat a ‘targeted intervention’ to help large corporates with their ESG might look like. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

29 min
02/02/2024

The new version of LCN’s book on intercompany agreements for transfer pricing compliance

The book, ‘Intercompany agreements for transfer pricing compliance: a practical guide’ was first published in March 2019. A revised edition will be published in September this year. Paul Sutton talks about the reasons for writing the original version, the cases and developments since then which have prompted the update, and how the new version will be different. Paul explains: Who the book is forWhat it is trying to achieveHow the transfer pricing world (and the role of intercompany agreements) has changed since 2019The cases and other developments which the new version will coverOther differences between the updated and original versions of the book. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

15 min
12/06/2023

Transfer pricing aspects of intangibles, with Filippo Miotto

Paul Sutton talks to Filippo Miotto, Transfer Pricing Director at BDO Australia, about the transfer pricing aspects of intangibles, particularly in the light of the ATO’s recently updated draft Practical Compliance Guidelines. Paul and Filippo discuss a range of issues around the draft Practical Compliance Guidelines (PCG) issued by the Australian Taxation Office, including: Why intangibles tend to attract attention from tax authoritiesThe context for the new PCG, and the ATO’s approachThe structure, content and aims of the PCGThe self-assessment reporting process, and the situations in which this is mandatoryExamples of the types of arrangements that are likely to attract more scrutinyWhat sorts of evidence taxpayers may need in order to support their TP arrangementsHow other tax authorities’ requirements may develop in the near futureAustralia’s new Multinational Tax Integrity regimeKey takeaways for groups and their advisers. Want more insights on transfer pricing, legal risk, and cross-border structuring? Join the LCN newsletterRegister for Upcoming webinarsLearn more about Intercompany Agreements

33 min

The LCN Legal Podcast brings you expert views and analysis of the legal aspects of transfer pricing compliance. Our focus is always on real-world, practical insights that you can apply in your everyday work. We often feature interviews with experts within and around the international transfer pricing community. Hosted on Acast. See acast.com/privacy for more information.

Creator

LCN Legal
Years Active

2023 - 2024
Episodes

19
Rating

Clean
Copyright

© 2026 LCN Legal
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The LCN Legal Podcast