TP Talks - PwC's Global Transfer Pricing podcast

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Curated Questions: Conversations Celebrating the Power of Questions!

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A Fork, A Precipice, A Decision 24:42

10 dni temu24:42

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24:42

Episode Notes [01:14] Unexpected Email from Employer [05:49] The Deferred Resignation Program [06:34] Initial Reactions and Concerns [08:01] Evaluating the Offer [08:21] Enhanced Standards of Conduct [08:55] Personal Reflections and Concerns [12:21] Seeking Advice and Making a Decision [13:01] Option One: Do Not Resign [14:56] Option Two: Resign [16:44] Insights from Conversations [21:30] Making The Decision [23:51] Final Thoughts and Gratitude Resources Mentioned Sebastian Junger The Soul of Shame by Curt Thompson Donald Trump Elon Musk Steve Bannon Russell Vought Derek Sivers Sumner Crenshaw Brian Fretwell at Finding Good Chad Littlefield The Thought Leaders Practice by Matt Church Simon Cowell Beauty Pill Producer Ben Ford Questions Asked Is it legitimate, and can it be trusted? How are you feeling? What questions come to your mind? Where does your mind go? Are you seeking safety? Would this have been an adrenaline rush as you raced to send the resignation response? What an "enhanced standard" regarding loyalty and trustworthiness was? What are these new "enhanced standards?" Are they beyond what my Constitutional oath requires? If I don't resign, how bright will the target on my back glow? My leadership has supported all my work, but would termination direction come from higher up the chain of command? What would you recommend if we talked over coffee? What questions would you ask? How would you use listening? How would you use silence? How is this scenario playing out in your mind and body? What is coming to the surface for you? How might that influence what you are about to say to me? What are the chances of my name popping on a list and getting fired? How about the chances of being part of an official Reduction in Force and early retirement? Would the administration make a better offer? What do I know about the pending job market? What did I expect the workplace to be like and did I want to be there as the contractions took place? Will the administration pay me through the end of September or will they renege? Can I sufficiently build the Curated Questions business to transition by 1 October? - Do I have the faith or confidence to step into this future as a sole practitioner and grow Curated Questions into all I envisioned? Was this purpose calling? What would I expect the job market to look like at the end of summer if I hadn't developed the income streams to maintain our lifestyle? What is your recommendation? Did it change from your initial recommendation? Where in your body are you feeling the uncertainty? Are you processing this scenario in parallel with your decision as if you had received the email? What additional questions should I have considered? Who else should I have consulted with? How would you have changed my risk rating? What is the correct length of the pregnant pause before making an important announcement? What processes would you use in my circumstance, and what would be different? What questions are at the top of your list to get to a decision? Who would be the members of your pantheon you would counsel with to gain clarity? Apart from the heady analysis, what other key practices would you include in your journey through a similar situation?…

TP Talks - PwC's Global Transfer Pricing podcast

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PwC partners and thought leaders discuss and provide valuable insights on transfer pricing developments around the world. Our podcasts not only provide you the latest regulatory changes and developments, but also inform you how they can impact your business.

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#PwC #Taxation #Business #Business News #Transfer #Price #Tax #Consulting

TP Talks - PwC's Global Transfer Pricing podcast

51 subscribers

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115 odcinków

#PwC #Taxation #Business #Business News #Transfer #Price #Tax #Consulting

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TP Talks - PwC's Global Transfer Pricing podcast

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Episode 112: Special Edition – Financial Transactions Transfer Pricing 20:01

5 weeks temu20:01

20:01

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 characteristics, including examples of financing that meet the criteria. Finally, they discuss the similarities and differences in returns between Islamic and conventional financing, the benchmarking of Islamic financial transactions for transfer pricing purposes, and the broader societal contributions of Islamic finance through Zakat, a wealth-based charitable contribution, and its implications for transfer pricing. Support the show…

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 111: Navigating transfer pricing, trade and tariffs in a protectionist world 23:10

11 weeks temu23:10

23:10

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

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 110: Transfer Pricing in the Middle East: Opportunities abound 34:58

15 weeks temu34:58

34:58

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

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 109: Brazil’s big shift: The new transfer pricing reality 17:16

18 weeks temu17:16

17:16

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

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 108: Special Edition – Financial Transactions Transfer Pricing 44:28

20 weeks temu44:28

44:28

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 discussion underscores the nuanced and fact-specific nature of debt capacity analysis across different jurisdictions, with varying implications for taxpayers. Support the show…

TP Talks - PwC's Global Transfer Pricing podcast

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Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves 32:24

24 weeks temu32:24

32:24

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

TP Talks - PwC's Global Transfer Pricing podcast

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Episode 106: CbCR: The evolving landscape 35:29

32 weeks temu35:29

35:29

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

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 105: Special Edition – Financial Transactions Transfer Pricing 40:59

40 weeks temu40:59

40:59

This TP Talks Special Edition podcast focuses on recent legislative developments and audit trends in Germany, Australia, and Canada. Support the show

TP Talks - PwC's Global Transfer Pricing podcast

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Episode 104: Who bears the risk? Navigating HMRC’s guidance 29:24

45 weeks temu29:24

29:24

In this episode of TP Talks, Kristina Novak sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC on identifying and pricing contributions to risk control by decision-makers. Support the show

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 103: Pricing intercompany loans: why implicit support matters 30:03

51 weeks temu30:03

30:03

This TP Talks episode features a discussion of the recent IRS administrative guidance regarding implicit support and its impact on the pricing of intercompany loan transactions, both from a US and global perspective. Support the show

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 102: Stock-based compensation: One size does not fit all 24:44

1 year temu24:44

24:44

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations when analyzing whether to put a recharge agreement in place. They finish with a discussion of the interplay between recharge agreements and Pillar Two and final takeaways. Support the show…

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 101: The time is now: year-end TP adjustments in China 13:58

1 year temu13:58

13:58

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Jessica Yin (Transfer Pricing Partner, PwC Shanghai), Rong Zhen (Corporate Tax and Forex Partner, PwC Shanghai), and Nancy Chen (Transfer Pricing Senior Manager, PwC Shanghai) discuss why many MNCs operating in China have been more attentive to year-end transfer pricing adjustments (TPAs), what TPAs Chinese subsidiaries might need to undertake, the challenges cross-border TPAs present in China, and options available for MNCs to implement year-end adjustments. The speakers also address indirect tax implications for upward TPAs, and how taxpayers can respond to a potential inquiry. Support the show…

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 100: Perspectives on China and India 23:46

1 year temu23:46

23:46

This TP Talks episode features a discussion of the transfer pricing developments in India and China. Support the show

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 99: More pain? A review of the transfer pricing controversy environment 40:34

1 year temu40:34

40:34

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), David Swenson (Consultant in PwC’s US National Tax Services Transfer Pricing Practice), and Mark Thomas (Principal in PwC’s US National Tax Services Transfer Pricing Practice) discuss the current tax and transfer pricing controversy landscape, including the current audit environment, the impact of global tax reform, the IRS’s recently announced audit initiative, and more. Support the show…

TP Talks - PwC's Global Transfer Pricing podcast

1
Episode 98: Pillar One Amount B: Reading the tea leaves 40:37

2 years temu40:37

40:37

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation. Timestamps: 1:17 - What is Pillar 1 and what is Amount B under Pillar 1? 3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B? 5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document? 12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives? 18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that? 20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works? 31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most? 35:30 - What are some takeaways that you can offer our listeners? Support the show…

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