TP Talks - PwC's Global Transfer Pricing podcast

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  Episode 125: India's evolving transfer pricing landscape 16.07.2026 32min

  Kristina and John are joined by Eric Mehta to discuss the significant transfer pricing reforms announced as part of India's Union Budget 2026. Support the show
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  Episode 124: Lessons from global transfer pricing negotiations 04.06.2026 21min

  Kristina Novak and John Cianfrone sit down with Mona Cairncross for an inside look at global transfer pricing negotiations and lessons from her time as Assistant Director of the IRS APMA Program. Support the show
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  Episode 123: Data-driven decisions: AI elevates transfer pricing strategy 28.04.2026 35min

  This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement. Support the show
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  Episode 122: The great services debate: Pricing, people, and profit allocation 09.04.2026 26min

  This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments. Support the show
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  Episode 121: Transfer pricing controversy: Planning for the long term 19.02.2026 27min

  This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks. Support the show
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  Episode 120: Increased scrutiny, higher stakes: Inside Australia’s TP enforcement shift 18.12.2025 27min

  Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape. Support the show
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  Episode 119: When tariffs wag the transfer pricing dog 02.12.2025 23min

  Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing. Support the show
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  Episode 118: Special Edition – Financial Transactions Transfer Pricing 07.11.2025 29min

  David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues. Support the show
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  Episode 117: Services or something more? Navigating blurred lines in transfer pricing 29.09.2025 42min

  Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions. Support the show
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  Episode 116: Special Edition – Financial Transactions Transfer Pricing 08.09.2025 28min

  In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact. Support the show
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  Episode 115: Ready or Not? Navigating the UK’s next TP chapter 31.07.2025 33min

  Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader). Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the n...
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  Special Edition – Financial Transactions Transfer Pricing 03.06.2025 29min

  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 ra...
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  Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025 03.04.2025 39min

  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 wha...
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  Episode 112: Special Edition – Financial Transactions Transfer Pricing 14.02.2025 20min

  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 c...
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  Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world 03.01.2025 23min

  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 10.12.2024 34min

  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
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  Episode 109: Brazil’s big shift: The new transfer pricing reality 20.11.2024 17min

  In this TP Talks episode, Kristina Novak sits down with Marcelo Vieira to discuss the progress of Brazil’s overhaul of its transfer pricing regime. Support the show
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  Episode 108: Special Edition – Financial Transactions Transfer Pricing 07.11.2024 44min

  Debt capacity In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium), Stan Goldenberg (M&A Transfer Pricing Director, PwC US), Andrew Cotterill (Transfer Pricing Senior Manager, PwC UK), and Ben Pietersen (Eurasian Transfer Pricing Director, PwC Georgia) discuss debt capacity from a transfer pricing perspective, exploring the principles and practices of the US, UK, Georgia, and other Eurasian countries. The discus...
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  Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves 09.10.2024 32min

  This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD’s February 2024 final report and subsequent June guidance.1 Support the show
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  Episode 106: CbCR: The evolving landscape 14.08.2024 35min

  This TP Talks episode addresses the evolution of country-by-country reporting (CbCR) as it relates to the OECD’s Pillar Two Transitional CbCR Safe Harbor and Public CbCR. Support the show