Episodes

  • What's shaping Tax Controversy in Germany and the Netherlands?

    What's shaping Tax Controversy in Germany and the Netherlands?
    Apr 29 2024
    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 Pricing Dispute Resolution Services in KPMG Germany). They share their experiences and insights on the current landscape, discuss the increasing scrutiny of transfer pricing arrangements, and introduce to us KPMG's initiative to coordinate tax and transfer pricing dispute resolution work globally.
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    17 mins
  • How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?

    How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?
    Mar 20 2024
    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 with Lillie Sullivan (Senior Manager, KPMG US: Washington National Tax - Controversy and Dispute Resolution), and Joshua McConkey (Managing Director, KPMG US: Washington National Tax Controversy and Dispute Resolution).
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    14 mins
  • Love Letter to Transfer Pricing

    Love Letter to Transfer Pricing
    Feb 14 2024
    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 to transfer pricing, and perhaps inspire the next generation of romantics in this crucial and captivating sector of the global economy. In this very special episode of Exploring Transfer Pricing, our host Brittany Hardin Tanguay revisits some of her heartfelt conversations with previous guests of the program, including Robin Archer (Director, KPMG UK), Enrique Martin (Principal, KPMG US), Sayantani Ghose (Principal, KPMG US), Diana Shkodina (Principal, KPMG US), Nick Stavrakis (Managing Director, KPMG US), Brad Parker (Principal, KPMG US), and David Unger (Managing Director, KPMG US).
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    16 mins
  • Special Update: OECD's 2022 Mutual Agreement Procedure (MAP) Statistics

    Special Update: OECD's 2022 Mutual Agreement Procedure (MAP) Statistics
    Jan 26 2024
    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 Phil Roper, a Partner from KPMG UK, and Thomas Bettge, a Senior Manager in Washington National Tax, to discuss their impressions from the latest release of MAP Statistics.
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    15 mins
  • Industry Series: Transfer Pricing for Banking

    Industry Series: Transfer Pricing for Banking
    Dec 21 2023
    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.
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    15 mins
  • Taxing Times: 2023 Transfer Pricing Recap and Beyond

    Taxing Times: 2023 Transfer Pricing Recap and Beyond
    Nov 20 2023
    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 highlights from the previous year, as well as the challenges and opportunities that lie ahead in the realm of transfer pricing.
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    16 mins
  • Industry Series: Transfer Pricing for Building, Construction, and Real Estate

    Industry Series: Transfer Pricing for Building, Construction, and Real Estate
    Oct 20 2023
    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 associated transactions around it. With a large diversity in the types of transactions and assets, transfer pricing practitioners must rely more heavily on sound economic principles. Our host Brittany Hardin Tanguay is joined by Weston Krider, a KPMG Transfer Pricing Managing Director based in Los Angeles and rejoined by Sharon Liu, a KPMG Transfer Pricing Principal in Economic and Valuation Services to discuss some of the key issues of transfer pricing within the building and construction industry.
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    16 mins
  • REITs: In Real Estate Investment We Trust

    REITs: In Real Estate Investment We Trust
    Sep 26 2023
    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.
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    16 mins