Exploring Transfer Pricing

Episódios

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  Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2) 14.07.2026 17min

  The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In Part 2 of this two-part series, host and , Senior Managing Director at KPMG LLP Washington National Tax (WNT) practice, continue their conversation fielding questions from transfer pricing professionals at the TP Minds West Coast event in Palo Alto. This episode digs into the practical realities of GenAI's impact on transfer pricing, covering three key areas: We explore the implications of GenAI on transfer pricing: - The evolving value of data (and why a single data point is nearly worthless until it's aggregated, cleansed, and put to work) - How GenAI adoption is - and isn't - reshaping comparability analysis and benchmarking under TNMM and CPM; and - Where tax authorities are most likely to challenge intercompany arrangements tied to AI-driven value creation.
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  Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 1) 01.06.2026 13min

  The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist , Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, , comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto. We explore the implications of GenAI on transfer pricing: - Does GenAI-generated content constitute new intellectual property? - How does automation shift the allocation of intercompany costs? - What steps can companies take to stay proactive amid the rapid adoption of this technology? From understanding the evolving role of data to tackling comparability challenges, this discussion explores the dynamic intersection of GenAI and transfer pricing in Part 1 of this two-part episode.
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  What is the International Compliance Assurance Program (ICAP)? - Audio Only 27.02.2026 21min

  ICAP - the OECD's International Compliance Assurance Program - offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way? This episode presents a unique opportunity to hear directly from both perspectives: Doug O'Donnell, former IRS Acting Commissioner and Deputy Commissioner, who was instrumental in shaping ICAP for tax administrations, and Erik Skarstad, who has navigated the program during his time as a Transfer Pricing leader for Fortune 100 companies. Their firsthand experiences reveal the practical realities, challenges and benefits of participating in ICAP. Join our host as she speaks with Doug O'Donnell (Senior Managing Director, Washington National Tax, Tax Controversy and Dispute Resolution) and (Managing Director, Tax, Transfer Pricing) to unpack ICAP's origins, objectives, and real-world impact. Together, they share insights from both sides of the table - government and taxpayer - on building trust, navigating challenges, and finding value in multinational cooperation.
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  Taxing Times - 2025 Transfer Pricing Recap and Beyond - Video 19.12.2025 14min

  As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host (Senior Manager, Tax, WNT - Transfer Pricing), is joined by (Principal - Washington National Tax, Transfer Pricing) and (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.
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  Taxing Times - 2025 Transfer Pricing Recap and Beyond - Audio Only 19.12.2025 14min

  As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host (Senior Manager, Tax, WNT - Transfer Pricing), is joined by (Principal - Washington National Tax, Transfer Pricing) and (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.
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  How Can GenAI Improve Transfer Pricing Processes? - Audio Only 13.11.2025 26min

  On this episode of Exploring Transfer Pricing, we discuss utilizing process improvement tools to pinpoint where GenAI can truly shine in transfer pricing. With generative artificial intelligence (GenAI) taking the spotlight in innovation, organizations are asking: Where do we start? In this episode of Exploring Transfer Pricing, we discuss how process improvement methodologies can help businesses identify the best opportunities to integrate GenAI into transfer pricing processes. From reducing mundane manual tasks to scaling solutions globally, we explore how defining, discovering, and solving through structured frameworks can demystify GenAI's role in transforming your transfer pricing processes. Join our guest host (Manager, Tax, Transfer Pricing), for a conversation with (Managing Director, Tax, WNT - Transfer Pricing) and (Senior Manager, Tax, WNT - Transfer Pricing). Together, they break down actionable steps for organizations to embrace GenAI as a tool for efficiency and innovation - while balancing quality and accuracy in a rapidly transforming tax landscape.
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  Are There Myths About Operational Transfer Pricing? 30.10.2025 18min

  In this episode of Exploring Transfer Pricing, we discuss utilizing operational transfer pricing to move from a manual mess to an automated success. As global regulations intensify and the demand for accuracy grows, having a robust operational transfer pricing (OTP) strategy is no longer a luxury - it is a necessity. Many believe that implementing an OTP solution requires a large front investment, but a solution may not be out of reach. Our host is joined by (Principal, Tax - National Leader, Operational Transfer Pricing) and (Partner, Global Transfer Pricing Services - KPMG Germany), and together they examine how to turn your operational transfer pricing challenges into a competitive advantage.
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  Special Update: OB3's Impact on Transfer Pricing 12.08.2025 17min

  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 is joined by (Managing Director, Washington National Tax - International Tax) and (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.
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  How Can Companies Plan to Enhance Transfer Pricing in the Current Tax Environment? 13.06.2025 19min

  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 as she, along with her guests (Principal and National Transfer Pricing Advisory Leader), and (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.
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  How Do Tariffs and Transfer Pricing Interact? 23.04.2025 20min

  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 as she, along with her guests (Managing Director, Tax, ) and (Managing Director, Tax, ), share their experiences and reveal how strategic collaboration between transfer pricing and trade and customs teams can unlock significant value for businesses.
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  Why Are Intercompany Agreements Important? 11.02.2025 20min

  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.
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  Why Are Intercompany Agreements Important? 14.01.2025 20min

  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.
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  What is the interaction between Pillar 2 and Transfer Pricing? 25.11.2024 16min

  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.
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  Taxing Times: 2024 Transfer Pricing Recap and Beyond 17.10.2024 14min

  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.
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  DEMPE Demystified: Navigating Intangible Assets in Transfer Pricing 26.09.2024 16min

  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.
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  What's Shaping Tax Controversy in Latin America? 04.09.2024 17min

  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.
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  What's Shaping Tax Controversy in Ireland and the UK? 06.08.2024 16min

  From cliffs to castles, exploring the tax terrain of Ireland and the UK. Diving into the stormy seas of transfer pricing disputes, this episode unveils the escalating challenges and evolving trends in the United Kingdom and Ireland. How has Brexit reshaped the transfer pricing relationship between the competent authorities in Ireland and the UK? What impact has the OECD and G20's Base Erosion and Profit Shifting, or BEPS, initiative had on transfer pricing disputes in these regions? And how effective are tools like Advance Pricing Agreements, or APAs, and Mutual Agreement Procedures, or MAPs, in mitigating these disputes? Join our host Brittany Hardin Tanguay as she and her guests Neil Casey, Partner, Transfer Pricing, KPMG Ireland and Nick Stevart, Director, Global Transfer Pricing Controversy Management, KPMG UK explore the latest trends, notable cases, and the evolving landscape of transfer pricing in these two jurisdictions.
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  Unraveling the Intricacies of Legal Entity Rationalization and Transfer Pricing 28.06.2024 15min

  Trim down with legal entity rationalization and streamline your transfer pricing. Legal entity rationalization, a strategic method of streamlining corporate structures, plays a pivotal role in enhancing business efficiency and cost-effectiveness. But how does this process help businesses meet their objectives? And what is its significance in the face of ever-changing tax landscapes and regulatory requirements? In this episode, we discuss how businesses are assessing their current legal entity structure, as well as how and why they pinpoint opportunities for rationalization, all while considering transfer pricing. Join our host, Brittany Hardin Tanguay, as she delves into this captivating discussion with Ashley Marx, Managing Director, Tax - Mergers and Acquisitions (KPMG US), and Adam Kelfer, Managing Director, Tax - Transfer Pricing (KPMG US).
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  Will GenAI Revolutionize Transfer Pricing? 06.06.2024 17min

  Unlocking the potential of GenAI throughout the Transfer Pricing lifecycle. Within the complex landscape of transfer pricing, the introduction of generative artificial intelligence (GenAI) is stirring up a new era of possibilities. But how is GenAI influencing this multifaceted field? What novel trends are emerging, propelled by GenAI advancements? And how should we incorporate this cutting-edge technology into the traditional transfer pricing approach? Delve into the discussion as we navigate the exciting intersection of GenAI and transfer pricing. Join our host Brittany Hardin Tanguay as she poses the questions you asked at TP Minds held in San Francisco last December, to Thomas Herr, KPMG US National Leader in Transfer Pricing and Innovation. Listen as Thomas reflects on how AI will automate and transform transfer pricing in the future.
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  What's shaping Tax Controversy in Germany and the Netherlands? 29.04.2024 16min

  From canals to autobahns, traversing the European tax controversy landscape. In the intricate realm of transfer pricing, tax controversies and disputes present a unique set of challenges. But how are these challenges being addressed in Europe, particularly in Germany and the Netherlands? What trends are emerging in these jurisdictions? And how is the concept of joint audits being leveraged as a potential solution? Join our host Brittany Hardin Tanguay as she explores these questions with Jens Lamberg Karremen (Partner, KPMG Netherlands) and Holger Peters (Partner, Head of Global Transfer Pricing Dispute Resolution Services in KPMG Germany). They share their experiences and insights on the current landscape, discuss the increasing scrutiny of transfer pricing arrangements, and introduce to us KPMG's initiative to coordinate tax and transfer pricing dispute resolution work globally.