Exploring Transfer Pricing
In the Exploring Transfer Pricing podcast series, a KPMG manager interviews senior transfer pricing professionals to answer her questions. The discussions aim to provide a clearer understanding of the transfer pricing landscape for listeners. It's designed for seasoned international tax professionals, inquisitive economists, and curious explorers alike. The podcast is brought to you by KPMG TaxRadio.
Episodes
Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2)
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 practica
Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 1)
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 tr
What is the International Compliance Assurance Program (ICAP)? - Audio Only
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'Do
Taxing Times - 2025 Transfer Pricing Recap and Beyond - Video
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 compl
Taxing Times - 2025 Transfer Pricing Recap and Beyond - Audio Only
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 compl
How Can GenAI Improve Transfer Pricing Processes? - Audio Only
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
Are There Myths About Operational Transfer Pricing?
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
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 cur
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 as she, along with her gu
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 as she, along with her guests (Managing Director, Tax, ) and (Managing Director, Ta
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 readin
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 readin
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 para
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)
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
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 a
What's Shaping Tax Controversy in Ireland and the UK?
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
Unraveling the Intricacies of Legal Entity Rationalization and Transfer Pricing
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
Will GenAI Revolutionize Transfer Pricing?
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
What's shaping Tax Controversy in Germany and the Netherlands?
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
How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?
Beyond Controversy: The collaborative landscape of transfer pricing disputes.
In the complex world of transfer pricing, setting the right price for intercompany transactions is both a science and a subjective process. But how does this play out in the face of international disputes? Where do treaty-based resolutions like the Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA)
Love Letter to Transfer Pricing
Cupid's arrow has struck the heart of many curious people, leading them to transfer pricing.
Prepare to be smitten as we delve into the hearts of multiple transfer pricing professionals, the matchmakers of the corporate world, who work to harmonize the rhythm of regulatory compliance with the melody of business objectives in a symphony of economic strategy. Whether it was love at first sight or a
Special Update: OECD's 2022 Mutual Agreement Procedure (MAP) Statistics
Charting out the OECD's 2022 Mutual Agreement Procedure (MAP) Statistics to appreciate how effective MAP is in resolving transfer pricing disputes.
The OECD released the 2022 Mutual Agreement Procedure (MAP) Statistics and announced its much heralded MAP Awards, the Transfer Pricing equivalent of the Oscars. When a multinational is subject to a transfer pricing adjustment, MAP is a process the ta
Industry Series: Transfer Pricing for Banking
Our host Brittany Hardin Tanguay is joined by Maggie Fritz, a Tax Principal and the global banking leader for transfer pricing, and Brie Siciliano, a Managing Director for Tax specializing in financial services. Together, they'll unravel the complexities that the banking industry encounters when enacting transfer pricing.
Taxing Times: 2023 Transfer Pricing Recap and Beyond
2023 has been a rollercoaster in the world of international tax and transfer pricing - and 2024 looks to be more of the same.
As 2023 draws to a close, we delve into the key tax initiatives that have shaped the transfer pricing landscape over the past year. This episode navigates through topics ranging from the OECD's Pillar One and Pillar Two, to the adoption of the OECD Guidelines by Brazil and
Industry Series: Transfer Pricing for Building, Construction, and Real Estate
Hammering out transfer pricing challenges in the building, construction, and real estate industry.
Building on our Transfer Pricing Industries Series, we have constructed an episode on the specialized transfer pricing issues faced by the building, construction, and real estate, BCRE, industry. The uniqueness of the underlying assets influence how transactions are valued, and how to price the asso
REITs: In Real Estate Investment We Trust
Our host Brittany Hardin Tanguay is joined by Stephen Giordano, KPMG Partner, Washington National Tax, focused on Business Tax Services - Passthroughs, and Sharon Liu, KPMG Principal, Tax - Transfer Pricing, to discuss some of the key issues of transfer pricing within the REITs realm.
Industry Series: Transfer Pricing for Retail
Our host Brittany Hardin Tanguay is joined by Diane Shkodina, Managing Director, Tax - Transfer Pricing, and Nick Stavrakis, Managing Director, Tax - Transfer Pricing to discuss the challenges transfer pricing practitioners are facing with developing an arm's-length transfer pricing range for North American retail distribution companies and beyond
Financial Transactions from the Dutch Perspective
Going Dutch on testing financial transactions!
In this episode we explore the Chapter 10 OECD Guidelines involving financial transactions with our KPMG Netherlands colleagues. The Netherlands has long been known as a financial services transaction hub and integral for multinational enterprises' treasury functions - why has this historically been the case? What are some of the major transfer prici
Special Update: Amount B Under Pillar One
If Amount B is supposed to simplify transfer pricing, why does it seem so complicated? Listen as we break it down.
In this episode we explore the major announcement regarding Amount B released this week by the OECD with our KPMG knowledge leader from London. On Monday July 17, we got the latest update from the OECD on its efforts to simplify transfer pricing through Amount B, part of its BEPS 2.0
Industry Series: Transfer Pricing for Insurance
Your transfer pricing is in good hands, because we've seen a situation or two.
The insurance industry and its representatives exist to make people's bad days less bad. Insurance provides protection for what matters most, but how do you transfer price for managing risk? If you're unsure how reinsurance works for cross-border intercompany transactions, we've got you covered!
As part of our Indust
Industry Series: Transfer Pricing for Asset Management
Why can't all my profit just go to an offshore haven? KPMG explains Asset Management transfer pricing in a post-BEPS world.
Investment committees, sub-advisors and referral fees - Oh My! How should asset management tax practices battle the nuances of splitting highly lucrative asset management returns across their global footprints? In an industry which faces commercial pressure, non-tax regulato
How Do You Analyze Financial Transactions?
Perform a check-up on your company's financial health before stressing it with debt. We've established that everybody borrows, meaning that multinational enterprises in every industry are likely to engage in some level of intercompany financing. But how is it actually done? What parts of the business need to work together, and what considerations often get overlooked when setting interest rates on
Are There Financial Transactions Outside of Financial Services?
Listen in to learn why some subsidiaries can be viewed as the black sheep of the family, while others as the next in line to run the business.
Industry Series: Transfer Pricing for Life Sciences
Open your eyes to the often complex and always fascinating world of transfer pricing in the life sciences industry.
Special Update: Brazilian Provisional Measure to Align with the OECD
The largest economy in South America has always been the exception when it comes to global transfer pricing, all of which appears likely to change
Amount B under Pillar One - Simplification for Baseline Marketing and Distribution Activities
Have you ever thought transfer pricing could be simpler and more standardized? Are you tired of arguing about routine distribution returns? If you are, Amount B might be the solution for you.
Industry Series: Transfer Pricing for Financial Services
There's a lot for transfer pricing to account for in the financial services industry. Because it can be a bit of a balancing act - listen to this episode to have it make cents!
Industry Series: Transfer Pricing for Technology
Plug in, reboot, and join us for our latest version - er, episode - where we look at transfer pricing as it relates to the technology industry. It's a little more complicated than just clicking CTRL-ALT-DELETE.
Industry Series: Transfer Pricing, Automotive
What's it like to be in the driver's seat of practicing transfer pricing in the Industrial Manufacturing Automotive industry? Strap in to learn from industry veterans.
Where Did Pillar One and Pillar Two Come From?
The space between two pillars. Pillars One and Two attempt to restabilize a system that is increasingly difficult for taxpayers to manage.
What is Operational Transfer Pricing?
Discussing why OTP has become more important than ever.
How Does ESG Impact Transfer Pricing?
Environmental effects on our planet. Social impacts in our communities. Governance results in reporting and structure. Where does transfer pricing fit into ESG?
What's the Deal with Local Files and Local Documentation?
Is it Local? When it comes to country-specific Transfer Pricing reports, acclimate yourself to the local terminology, and don't get tripped up by the different titles and requirements.
How Can You Master the Master File?
In this episode we discuss the mastery of the Master File, aka, the bass line in the symphony of global transfer pricing documentation.
What is Country-by-Country Reporting? (Part 2)
With the onset of public country-by-country reporting - coordination, transparency, and analysis is key. Learn about some of the risks and mitigation tools and practices associated with interpreting data.
What is Country-by-Country Reporting? (Part I)
Step by step, country-by-country, tax authorities and taxpayers get closer and closer in sync.
How Do You Document Transfer Pricing?
Meet the global transfer pricing reporting trinity - Country by Country, Local File, and Master File. Learn how the Global Transfer Pricing Review makes it easier to manage.
What is Arm's Length?
How is it possible to simulate independence when your companies aren't? Find out more about why transfer pricing is so concerned with arm's length results.
Why Is Value Chain Important to Transfer Pricing?
Listen as we link value creation to transfer pricing. The resulting chain of events will keep you hooked!
How Did We Get Here? A Brief History of Transfer Pricing
Throughout history, there have been only two certainties: death and taxes. Both have gotten more complicated over time, but fortunately we'll be focusing on the latter.
What is Transfer Pricing?
There's a place on the map where law, politics, finance, and economics all meet, and that intersection is transfer pricing. Join us to discover what transfer pricing is, and what it is not.
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