Exploring Transfer Pricing

KPMG LLP (U.S.) · kpmg.com

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.

52 episodes

1mo ago latest

monthly cadence

English language

▶ Play latestRSS feed Website Business

https://kpmg.com/kpmg-us/content/dam/kpmg/feed/exploringtransferpricing.xml

Episodes 52

Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2)
1mo ago · 17:24
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, hostand, 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 wort
Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 1)
3mo ago · 13:23
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 t
What is the International Compliance Assurance Program (ICAP)? - Audio Only
6mo ago · 21:43
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 Transfe
Taxing Times - 2025 Transfer Pricing Recap and Beyond - Video
8mo ago · 14:09
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 an
Taxing Times - 2025 Transfer Pricing Recap and Beyond - Audio Only
8mo ago · 14:09
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 an
How Can GenAI Improve Transfer Pricing Processes? - Audio Only
9mo ago · 26:56
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 t
Are There Myths About Operational Transfer Pricing?
10mo ago · 18:02
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 hostis joined by(Principal, Tax - National Leader, Operational Transfer Pricing) and(Partner, Global Transfer Pricing Services - KPMG Germany), and together
Special Update: OB3's Impact on Transfer Pricing
1y ago · 17:49
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
How Can Companies Plan to Enhance Transfer Pricing in the Current Tax Environment?
1y ago · 19:33
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 hostas 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 fo
How Do Tariffs and Transfer Pricing Interact?
1y ago · 20:06
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 hostas 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.
Why Are Intercompany Agreements Important?
1y ago · 20:35
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 interco
Why Are Intercompany Agreements Important?
1y ago · 20:35
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 interco
What is the interaction between Pillar 2 and Transfer Pricing?
1y ago · 16:30
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 opera
Taxing Times: 2024 Transfer Pricing Recap and Beyond
1y ago · 14:32
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 Sale
DEMPE Demystified: Navigating Intangible Assets in Transfer Pricing
1y ago · 16:30
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
What's Shaping Tax Controversy in Latin America?
1y ago · 17:23
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
What's Shaping Tax Controversy in Ireland and the UK?
2y ago · 16:02
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,
Unraveling the Intricacies of Legal Entity Rationalization and Transfer Pricing
2y ago · 15:45
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 consideri
Will GenAI Revolutionize Transfer Pricing?
2y ago · 17:58
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
What's shaping Tax Controversy in Germany and the Netherlands?
2y ago · 16:56
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 Prici
How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?
2y ago · 14:23
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) fit into this puzzle? And just how pivotal are these tools in providing certainty and preventing double taxation? Join our host, Brittany Hardin Tanguay, as she navigates this fascinating discussion w
Love Letter to Transfer Pricing
2y ago · 15:52
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 slow-burning passion, their stories are a testament to the dynamic, challenging, and rewarding nature of a career in transfer pricing. So, grab a box of chocolates and join us as we pen a love letter
Special Update: OECD's 2022 Mutual Agreement Procedure (MAP) Statistics
2y ago · 15:09
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 taxpayer can invoke to avoid double taxation. The MAP statistics provide multinationals with important insights into how well MAP relationships are working. Our host Brittany Hardin Tanguay is joined by
Industry Series: Transfer Pricing for Banking
2y ago · 15:11
Explore how the banking industry walks the transfer pricing tightrope by balancing risks and regulations. 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
2y ago · 15:50
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 the impact of economic uncertainty and evolving business models on transfer pricing. Our host Brittany Hardin Tanguay is joined by Jessie Coleman, a Principal in Washington National Tax, to discuss hi