Exploring Transfer Pricing

KPMG LLP (U.S.)
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In the Exploring Transfer Pricing podcast series, brought to you by KPMG TaxRadio, a KPMG manager asks senior transfer pricing professionals the questions on her mind. After listening you'll have a clearer roadmap to traverse the transfer pricing landscape, whether you're a seasoned international tax professional, an inquisitive economist, or simply a curious explorer.

  1. AUG 12

    Special Update: OB3's Impact on Transfer Pricing

    What does the G7 agreement mean for Pillar Two in the US? How do changes to Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) influence transfer pricing strategies? Why is modeling more crucial than ever? This episode tackles these questions and more, offering insights into IP planning, cost sharing agreements, and the services cost method. Whether you're curious about the nuances of the G7 agreement or the implications of updates to the Base Erosion and Anti-Abuse Tax (BEAT), this episode provides insights and practical guidance to help taxpayers navigate the evolving transfer pricing landscape under OB3. Our host Brittany Hardin Tanguay is joined by Marissa Rensen (Managing Director, Washington National Tax - International Tax) and Thomas Bettge (Senior Manager, Washington National Tax - Transfer Pricing), and together they examine the legislative changes introduced by the One Big, Beautiful Bill (OB3) and its implications for transfer pricing.

    18 min

  2. JUN 13

    How Can Companies Plan to Enhance Transfer Pricing in the Current Tax Environment?

    Companies are rethinking tax strategies with an eye on transparency and responsibility in today's evolving landscape. On this episode of Exploring Transfer Pricing, we'll highlight the important role played by tax planning to support business growth objectives, and the important role of comprehensive transfer pricing documentation to mitigate audit risks. Join our host Brittany Hardin Tanguay as she, along with her guests Kristin Essary (Principal and National Transfer Pricing Advisory Leader), and Marissa Rensen (Managing Director, WNT - International Tax), explore how companies can leverage their intellectual property, navigate the intricacies of foreign tax credits, and manage the Base Erosion and Anti-Abuse Tax (BEAT). Discover how strategic collaboration and detailed modeling can unlock tax savings opportunities to ensure your business remains buoyant amidst today's turbulent tax tides.

    20 min

  3. APR 23

    How Do Tariffs and Transfer Pricing Interact?

    Strap in for the rollercoaster of tariffs - How transfer pricing can help smooth out the ride. Join us for this episode as we attempt to unravel the complexities of tariffs and transfer pricing, and discuss what taxpayers need to be aware of to stay ahead of the rapidly changing tariff landscape. Join our host Brittany Hardin Tanguay as she, along with her guests Nicole Porpiglia (Managing Director, Tax, Trade and Customs) and Adam Kelfer (Managing Director, Tax, Transfer Pricing), share their experiences and reveal how strategic collaboration between transfer pricing and trade and customs teams can unlock significant value for businesses.

    20 min

  4. FEB 11

    Why Are Intercompany Agreements Important?

    Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readiness. Join our host Brittany Hardin Tanguay as she, along with her guest Mark Horowitz (Principal, Tax - KPMG US), react to the thoughts of other transfer pricing practitioners on the nuances of intercompany agreements. Brittany and Mark discuss the evolution of intercompany agreements, the importance of clear risk allocation, and the necessity of maintaining flexibility to adapt to unforeseen circumstances. Discover how businesses can effectively manage their intercompany agreements to align with tax authority expectations and safeguard against potential disputes, all while fostering a robust framework for global operations.

    21 min

  5. 11/25/2024

    What is the interaction between Pillar 2 and Transfer Pricing?

    Understanding the critical link between Pillar 2 and transfer pricing. Delve into the intricate relationship between Pillar Two and transfer pricing in this episode of the KPMG Exploring Transfer Pricing podcast. As the OECD's Inclusive Framework introduces Pillar Two to ensure a minimum level of taxation for multinational groups, understanding its implications on transfer pricing has become paramount. How does Pillar Two affect the preparation and use of Country-by-Country reports? What are the critical components of the transitional Safe Harbor test under Pillar Two? And what role does operational transfer pricing play in managing Pillar Two compliance? Join our host, Brittany Hardin Tanguay, as she explores these pivotal questions with Lucia Barone, a tax partner with KPMG Italy, and Kathy Lim, a tax partner based in Belgium. Together, they provide valuable insights and practical advice to help multinational groups navigate the complexities of Pillar Two.

    17 min

  6. 10/17/2024

    Taxing Times: 2024 Transfer Pricing Recap and Beyond

    Reflecting on the international and transfer pricing landscape of 2024, and anticipating what's on the horizon for 2025. As the curtain falls on 2024, we take a retrospective journey back through the key tax initiatives that have carved the contours of the transfer pricing arena this year. This episode casts its navigational net wide, exploring topics from foreign derived intangible income (FDII) and base erosion and anti-abuse tax (BEAT) Planning, to generative artificial intelligence (GenAI), and on-going controversies and compliance changes in transfer pricing. Join our guest host Seth Salenger, along with guests from the KPMG U.S. Washington National Tax Practice Jessie Coleman and Brittany Hardin Tanguay, as they come together to discuss the highlights and developments of the year gone by, and consider the challenges and opportunities set to shape the year ahead.

    15 min

  7. 09/26/2024

    DEMPE Demystified: Navigating Intangible Assets in Transfer Pricing

    From development to exploitation, refining our understanding of DEMPE in transfer pricing. Dive into the ever-changing world of DEMPE (Development, Enhancement, Maintenance, Protection and Exploitation) in this episode of the KPMG TaxRadio podcast Exploring Transfer Pricing, where we reflect on insights from the DEMPE session during the KPMG 2024 U.S. Cross-Border Tax Conference. Building on the results of our live survey with a diverse group of tax professionals representing multinational enterprises, we explore their perspectives and potential trends, offering a comprehensive and insightful view of the current and future state of transfer pricing. What are the key challenges companies face when integrating new acquisitions or managing dispersed senior management? How do different tax authorities mold DEMPE with their unique interpretations? And what strategies can businesses employ to mitigate risks and prepare for potential audits? Join our host, Brittany Hardin Tanguay, alongside Jack O'Meara and Prita Subramanian, both Principals in the KPMG U.S. Washington National Tax Practice, as they answer these questions and unpack the results of a recent survey conducted at the KPMG 2024 U.S. Cross-Border Tax Conference.

    17 min

  8. 09/04/2024

    What's Shaping Tax Controversy in Latin America?

    From the Samba to Merengue, exploring the tax dance in the Latin American region. Rhumba-ing into the complicated dance of transfer pricing controversy, this episode discusses the tax controversy trends seen in the region of Latin America, or LATAM. What avenues are there for companies to address tax certainty and controversy in LATAM? Which transactions draw the most scrutiny for the LATAM tax authorities? And how can companies look to mitigate some of the risks of operating in the LATAM region? Join our host, Brittany Hardin Tanguay, as she explores the secret spices of LATAM tax issues with Alejandro Barran, Partner, Tax - Transfer Pricing, KPMG Mexico, former head of the Competent Authority office in Mexico in charge of the Advance Pricing Agreements and Mutual Agreements Procedures, and Juan Carlos Vidal, Partner, Tax - KPMG Peru. Together, they explore the transfer pricing issues and difficulties operating within the LATAM region.

    17 min
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About

In the Exploring Transfer Pricing podcast series, brought to you by KPMG TaxRadio, a KPMG manager asks senior transfer pricing professionals the questions on her mind. After listening you'll have a clearer roadmap to traverse the transfer pricing landscape, whether you're a seasoned international tax professional, an inquisitive economist, or simply a curious explorer.

Information

  • Creator
    KPMG LLP (U.S.)
  • Years Active
    2021 - 2025
  • Episodes
    43
  • Rating
    Clean
  • Copyright
    © Copyright 2025 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.
  • Show Website
    Exploring Transfer Pricing

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