TP Talks - PwC's Global Transfer Pricing podcast

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

This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement. Support the show

This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments. Support the show

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

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

Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing. Support the show

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

Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions. Support the show

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

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 new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today. Support the show

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 rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief. Support the show

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 what the future may hold for transfer pricing—particularly under a second Trump administration. Support the show

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

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

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

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

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

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

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.

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