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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June 4, 2026Episode 12421 min
Episode 124: Lessons from global transfer pricing negotiations
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
April 28, 2026Episode 12335 min
Episode 123: Data-driven decisions: AI elevates transfer pricing strategy
This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement.Support the show
April 9, 2026Episode 12226 min
Episode 122: The great services debate: Pricing, people, and profit allocation
This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments.Support the show
February 19, 2026Episode 12127 min
Episode 121: Transfer pricing controversy: Planning for the long term
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
December 2, 2025Episode 11923 min
Episode 119: When tariffs wag the transfer pricing dog
Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing.Support the show
November 7, 2025Episode 11829 min
Episode 118: Special Edition – Financial Transactions Transfer Pricing
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
September 29, 2025Episode 11742 min
Episode 117: Services or something more? Navigating blurred lines in transfer pricing
Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions.Support the show
September 8, 2025Episode 11628 min
Episode 116: Special Edition – Financial Transactions Transfer Pricing
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
July 31, 2025Episode 11533 min
Episode 115: Ready or Not? Navigating the UK’s next TP chapter
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
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