The Fiona Show: Transfer Pricing: Recent Episodes
CrossBorder Solutions
On the Fiona Show, we discuss current issues in the transfer pricing world. Whether you’re new to transfer pricing, or you’ve been around the international tax block, learn about the latest trends in the global regulatory environment and technology in one weekly podcast.
Here, a few best practices for 2022 that every transfer pricing professional should embrace.
Since the introduction of BEPS, "tax transparency" has become a buzz phrase around the globe. What does transparency look like in the U.S.? And how is the IRS beefing up efforts to promote it here at home? In this episode of The Fiona Show, transfer pricing expert and former IRS competent authority analyst, Barbara Mantegani makes it all clear.
With the introduction of faceless audits in India last year, a new era in tax transparency appears to have dawned – and just in time to compensate for a global lockdown. Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law, joins today's Fiona Show podcast to discuss what the practice could mean for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination.
Stock based compensation is a way of paying company members with equity in the business, which is great for companies and employees. From a transfer pricing perspective, however, it can cause problems. Here, David Chamberlain of California Polytechnic State University-San Luis Obispo explains some of the issues that can arise and what multinational companies can do about them.
Global tax reform is underway, creating a new framework that comes with constant contradictions. On today's episode, Dr. Lorraine Eden returns to discuss her takeaways from proposals to tax only the 'top 100' companies in Pillar One negotiations.
Germany's recent compliance initiatives are picking up more speed than the Autobahn. On today's episode, CrossBorder Solutions Tax Director Hasker Hoogenberg and independent German-based transfer pricing specialist Oliver Treidler examine the transforming audit environment in Germany, and how MNEs can insulate themselves from further examination.
CrossBorder Chief Economist Mimi Song and transfer pricing expert Johann Muller take a closer look at the impacts of COVID-19 for low-risk distributors. Should these entities be able to absorb losses? Listen here to find out.
We know you love our expert coverage of the transfer pricing landscape, but did you know we bring that same level of informative analysis to the world of research and development tax incentives? On The Fiona Show: R&D Tax Credit, we—along with leading tax experts—explore how these incentives reward companies for innovation, fuel economic growth, and lead to paradigm-shifting discoveries across industries. If you don’t know R&D tax incentives, you may be part of the tragic majority leaving money on the table. Explore the back catalog of The Fiona Show: R&D Tax Credit to level up your tax knowledge, and subscribe to stay ahead on the latest in global innovation and the tax incentives that very likely come with it.
Getting the world to agree on a global tax plan is no easy job. This podcast discussion reveals what’s triggering global tax debates, and how MNEs can avoid getting caught in the middle.
Public country-by-country reporting is very close to becoming a reality in the European Union. How would this transparency initiative impact multinationals and the global tax community? CrossBorder Solutions’ Transfer Pricing Director Pamesh Sharma and Queen Mary University of London Tax Law Professor Christiana HJI Panayi explore the implications.
This episode explores the landmark Glencore versus the Australian Taxation Office case, and what it means for the future of compliance. Former ATO member Geoff Morris and CrossBorder Solutions’ Director Solutions Engineer Doug Darling discuss
Chief Economist Mimi Song joins University of Connecticut Professor of Law Richard Pomp to examine Amazon’s latest win against the European Commission and the key transfer pricing takeaways for multinationals.
Chief Economist Mimi Song defines key tax terms, from tax scrutiny to “the race to the bottom,” and explains how they translate in the global tax conversation.
Why did the Italian Supreme Court administer two different rulings on inter-company transactions? What can taxpayers learn from it? Chief Economist Mimi Song and University of Ferrara Professor of Law Marco Greggi discuss.
The Danish Tax Authority’s recent win against Tetra Pak Processing Systems can only mean one thing: increased scrutiny for taxpayers. Chief Economist Mimi Song and international corporate income tax expert Johann Muller analyze how the Tetra Pak win could bolster the tax authority’s confidence, leading to a likely increase in audits.
What's the relationship between tech and tax? How will the Biden administration’s latest tax proposals impact U.S. tech giants? Chief Economist Mimi Song and Vice President of Global Projects at the Tax Foundation Daniel Bunn unpack these questions and more.
It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best prepare.
Over the last two years, few jurisdictions have heightened their transfer pricing scrutiny with the enthusiasm of Vietnam. CrossBorder Solutions Chief Economist Mimi Song and Duke University professor Eddy Malesky discuss how MNEs can brace themselves for impact.
How much do we love transfer pricing? Every single of the 100 episodes that make up 'The Fiona Show: Transfer Pricing' podcast lets us count the ways, but to celebrate our centennial episode, we boiled down 10 essential lessons our guests have taught us about how transfer pricing is an art -- not a science.
The value chain analysis is essential for planning and defending a multinational's transfer pricing. International corporate income tax expert Johann Muller joins CrossBorder Solutions Chief Economist Mimi Song on today's episode to answer every question on value chains and transfer pricing you're too afraid to ask.
With new initiatives by the HMRC to claim the £34 billion that it says MNEs owe the UK in unpaid taxes, the message to taxpayers is painstakingly clear: transfer pricing compliance in the UK is an order, not a request. CrossBorder Chief Economist Mimi Song and UK-based transfer pricing expert Pamesh Sharma talk about how MNEs can best prepare for more scrutiny.
CrossBorder Solutions Director of International Tax Michael Desimone joins Chief Economist Mimi Song to discuss what the Biden administration's 'Made in America' tax plan has in store for MNEs, especially those with operations in low-tax jurisdictions.
CrossBorder Solutions Chief Economist Mimi Song and Dr. Diana Criclivaia discuss everything you need to know about joint audits, and why they're rising in prevalence.
While the EU Commission cannot determine tax rates for individual jurisdictions, they do have other weapons in their arsenal to fight BEPS. David Chamberlain, assistant professor of Accounting and Tax at California Polytechnic State University, joins CrossBorder Solutions Chief Economist Mimi Song to discuss the commission's deluge of state aid cases against the biggest household names among MNEs.
Anticipating the tax scrutiny for FY 2020, CrossBorder Solutions Chief Economist Mimi Song offers her expert strategies for helping MNEs stay compliant in her latest article in Treasury and Risk.
As the last few years have shown, tariffs can have a big impact on a multinational's transfer pricing. CrossBorder Solutions Chief Economist Mimi Song and transfer pricing expert Hasker Hoogenberg discuss recent trends and the ways Customs enforcement agencies look at their jobs differently than international tax authorities.
How effective are country-by-country reports in mitigating base erosion and profit shifting? And would making CbCRs public actually end up hurting analysis? Charles University’s Dr. Petr Jansky joins CrossBorder Solutions Chief Economist Mimi Song to discuss.
Chief Economist Mimi Song discusses her whitepaper, The Future of Benchmarking, and how technology changes the game for transfer pricing compliance.
Transfer pricing service transactions are one of the most highly scrutinized by tax authorities. Here, find out why and learn the steps you can take to minimize your risk.
CrossBorder Solutions transfer pricing expert, Doug Darling, explains the OECD's Guidance on Financial Transactions and offers strategies that promise to keep you in compliance in every jurisdiction.
China was the first country struck by the pandemic, but it was also the first economy to recover. CrossBorder Chief Economist Mimi Song joins the podcast to discuss lessons the world can learn from its quick revival, and address specific concerns of MNEs with Chinese operations.
Law360 reporter Alex Parker returns to the Fiona Show to discuss the likely impact that President Biden's plans to reform GILTI will have on the OECD's digital service tax proposals.
CrossBorder Solutions’ Chief Economist Mimi Song and Director Solutions Engineer Doug Darling discuss how tax jurisdictions are cracking down on profit shifting through transfer pricing, and ways MNEs can avoid extra examination.
Chief Economist Mimi Song discusses taxation of the digital economy, and the implications for MNEs.
CEO of Royalty Stat Dr. Ednaldo Silva discusses what new OECD guidance for transfer pricing regimes in developing countries means for MNEs.
On this episode of 'The Fiona Show' find out which 5 jurisdictions are on our "must-watch" list for increased transfer scrutiny in 2021.
Transfer pricing expert—and arm's-length standard crusader—Dr. Lorraine Eden returns to The Fiona Show to talk about what Pillar One means for the global tax landscape.
We recap the year in transfer pricing litigation across the world with 25 year-plus industry veteran and former IRS competent authority analyst, Barbara Mantegani.
As the latest member of the OECD, Colombia is making a name for itself as a no-nonsense jurisdiction from clamping down on commodities to DIAN's unique tax value units system.
We recap our year of advice on transfer pricing amid a pandemic from experts on the 'Fiona Show' podcast with CrossBorder Solutions Chief Economist Mimi Song.
Mimi Song is not only CrossBorder Solutions’ Chief Economist but also an economy news pundit rock star all in her own right. We talk to her in-depth about about her new article in Bloomberg, “Tax Scrutiny and What You Can Expect in 2021” and what new OECD guidelines mean for the post-COVID transfer pricing landscape.
Looking to avoid a tax audit in the former Soviet Union? On this episode, learn more about Russia’s transfer pricing rules and regulations, and how technology can help.
Big news: Italy is changing its transfer pricing regulations. This episode uncovers everything you need to know about the updated requirements and the implications for taxpayers.
An OECD enhanced participation status; an assigned transfer pricing account representative; 4 days to produce documentation when under audit. Transfer pricing in Indonesia proves to be a windy road. In this episode, learn how to navigate this unique jurisdiction’s rules and regulations.
What does it take to stay in compliance with the Turkish Ministry of Finance? It’s more complicated than you think.
Don’t be fooled by Vietnam’s low thresholds. It ranks high on the audit scale. Find out the tax compliance boxes you need to check in this developing country.
What does it take to stay on the Israeli Tax Authority's good side? Here's everything you need to know.
Lax on the outside with its own set of preferences on the inside. Transfer pricing in Thailand just isn't what it seems.
Strictly loose or loosely strict? Learn more about New Zealand’s intricate transfer pricing rules and regulations.
What do the regulations in this dimensional jurisdiction reveal about the country itself? Find out in Part Two of a two-part discussion with South Africa transfer pricing expert Dr. Keith Engel.
What do the regulations in this dimensional jurisdiction reveal about the country itself? Find out in Part One of a two-part discussion with South Africa transfer pricing expert Dr. Keith Engel.
Transfer pricing in Sweden is juicier than its meatballs. Find out how this straight-shooting OECD member is enforcing its regulations.
In Belgium, there are the official transfer pricing rules… and then there’s the litany of documentation disclosures that are not actually part of the tax code.
At the heart of understanding South Korean transfer pricing is understanding what makes South Korea South Korea.
Few industries have been as hard-hit by the pandemic as live entertainment. VP of tax planning and compliance at Feld Entertainment shares her experience and how she's looking at the company's transfer pricing documentation through the end of the year.
Ah those Scandinavian winds, always so mysterious and it’s particularly difficult to tell which way they’re blowing in Norway when it comes to transfer pricing.
How will the country's new tax reform affect your transfer pricing? There's one way to find out!
Official regulations. More scrutiny. New compliance burdens. Think the luck of the Irish is still on your side?
Denmark has been dubbed one of the happiest places on earth, so why aren’t transfer pricing executives thrilled?
Could a new digital services tax be the least of your worries in France? Oui, oui, Monsieur.
If there's one thing that this country agrees on, it's that transfer pricing means big revenue bucks.
Sure, the country is a member of the OECD, and generally speaking, it follows the organization’s transfer pricing guidelines, but even a straight-shooting country like Germany has transfer pricing nuances.
When it comes to transfer pricing, IP is always under the microscope. Here’s how one tax exec handles it.
The Italian way of life is pretty easy-going, but the Italian tax authorities? Not so much.
Transfer pricing compliance in 2020 promises to be tricky. CrossBorder Solutions' experts reveal what to keep an eye on now.
Tax scrutiny, compliance, the effects of Covid-19—it’s all in a day’s work for this transfer pricing exec.
Newish regulations, heightened compliance, DAC6. How is this EU country cracking down on transfer pricing? Straight from Poland, CrossBorder Solutions’ transfer pricing expert Milena Kaniewska tells all.
We spoke with three tax executives to see how they’re adjusting to the impact of COVID-19.
Will public reporting make tax transparency even more revealing? All signs point to, yes.
We thought so. Well, there’s no time like the present to get started. Tax Attorney and Transfer Pricing Advisor Barbara Mantegani is here to offer strategies on how to ace an audit. Think of it as Audit Prep 101.
Cost-sharing arrangements are subjective at best—even by transfer pricing standards. Over the years, major tech-companies like Xilinx, Amazon, Altera, and now Facebook, have all been victims of their own interpretations of cost-sharing regulations that have been written, re-written, modified, and in some cases, grandfathered to previous or even temporary versions. And that's all not to even mention the Tax Cuts and Jobs Act. So, does the world have a right to be a little perplexed? We’d say so.
India marches to the beat of its own tabla. From its friends-with-benefits relationship with the OECD to its sophisticated unilateral moves: few countries are as bold and forward-thinking, especially when it comes to transfer pricing.
This transfer pricing exec says audits aren’t a question of “if,” they’re a question of “when.” Here, he explains why.
Sure, country pubs and warm beer have their charm. But if you ask us, the real appeal of the United Kingdom comes from its straightforward approach to corporate taxation. I mean, there are no mixed messages. A punitive diverted profits tax says, “We want our tax dollars.” A profit diversion compliance facility says, “How can we help you give us our tax dollars?” A pending digital services tax says, “We need even more tax dollars.” A growing number of transfer pricing specialists at the HMRC says, well, you probably get the picture.
Given the brave new digital economy, the definition of permanent establishment is anything, but well, permanent.
It's certainly not out of the question. Here, Dr. Lorraine Eden, a transfer pricing expert, professor, author -- and lately, podcast rockstar -- explains why.
You may have heard Dr. Lorraine Eden on The Fiona Show—Episode 29, “Is the Arm’s Length Standard Really the Problem?”—when she gave us a very impassioned defense of the principle that’s become the backbone of transfer pricing. Well, today she’s back, this time leading the charge about the sorry attempt at BEPS Action One—the taxation of the digital economy—known to you, as Pillar One.
When a company evolves from the photographic industry into skincare, pharmaceuticals, medical equipment, network systems, printers, and more, the transfer pricing director had better keep up. Here, FujiFilm’s Director of Taxes, Peter De Nicola, reveals how through years of reinventions at Fuji, he focused on the big picture.
What happens when you take your transfer pricing dispute to the competent authority? Tax attorney—and former competent authority analyst—Barbara Mantegani tells all.
If you learned lessons the hard way in 2019, vow to make 2020 different. Here, 'Fiona Show' experts reveal how to kick off the transfer pricing new year on the right foot. Best of all, unlike your other resolutions, you don't have to join a gym to succeed.
Not according to transfer pricing expert Dr. Lorraine Eden. In this podcast, she explains why.
When it comes to transfer pricing, intangible transactions present their own unique challenges. Here, some tips to help conquer them.
With a little planning—and a little help from CrossBorder Solutions’ amazing new software--you can maximize your transfer pricing and minimize your tax bill. Here’s everything you need to know to get started.
Once you get a handle on functions, assets, and risks, the rest of your transfer pricing report falls into place.
What should MNEs consider during a merger or acquisition? Expert Clay Ayers reveals—from firsthand experience--how two companies can get their transfer pricing on the same page.
Scrutiny, customs-specific audits, dawn raids, and now a trade war. What makes transfer pricing in China so complicated? Well, how much time do you have?
How do you find a profit-level indicator you can trust? Founder & Director of RoyaltyStat, Dr. Ednaldo Silva has a few theories.
When it comes to transfer pricing, there are no guarantees that your taxable income is really your taxable income. But the OECD’s International Compliance Assurance Program can certainly help improve the odds. In this frank discussion, the OECD’s Dr. Achim Pross and Mark Johnson tell you all about it.
Transfer pricing may be tricky on a good day, but comparisons and analysis get even more complicated during a time of losses. In this eye-opening discussion, tax attorney Barbara Mantegani strategizes about transfer pricing in tough times.
When it comes to transfer pricing, Brazil is a real anomaly. But change may be on the horizon. In the OECD-Brazil Project, the OECD and Brazil are working together to see how the country can better align its transfer pricing regulations with OECD guidelines. In this fascinating discussion, Tom Balco, the head of the transfer pricing unit at the Center for Tax Policy at the OECD, reveals the Project’s takeaways and possible next-steps for Brazil.
Red Bubble, Google, Tradeshift, this XBS client has navigated all kinds of transfer pricing challenges. Here, she shares them all.
There are so many reasons to love the services cost method—it’s simple and straightforward, of course. And in some cases, it excuses you from paying the BEAT. CrossBorder Solutions experts Adam Sandford and Andrei Enoui discuss the details.
What methods are used to analyze intracompany outsourcing? XBS experts Adam Sanford and Andrei Enoiu talk about why service transactions are so important--and how to prove these complex arrangements are arm's length.
Intercompany agreements are a regular part of required local transfer pricing documentation, and that alone is a pretty compelling reason to prepare them. But don’t just take our word for it. Hear about these brilliant, lawful, and some might say, necessary agreements from Paul Sutton and Leiza Bladd-Symms of the U.K.-based LCN Legal, a company that specializes in intercompany transfer pricing agreements.
What’s it really like navigating transfer pricing 2019? In this revealing podcast, we hear from an in-house transfer pricing executive who has just about every iron in the international tax fire: digital tax implications, entities in super scrutinizing countries all over the world, transfer pricing from mergers and acquisitions, even past audits. If you’re in the transfer pricing weeds, this is one discussion you don’t want to miss.
Increased scrutiny. Stricter regulations. An eye on the digital economy. When it comes to transfer pricing, Argentina is stepping up its game. Here, CrossBorder Solutions’ South American specialist, Adam Sandford, discusses a few recent changes and what they mean for the future.
Josh White, a tax writer for International Tax Review and TP Week, has reported on the Altera case for TP Week and written about what it means from a transfer pricing perspective. Today, he talks to us about why the case is so important and why Altera isn’t the only company that stands to be affected by the verdict.
How do tax authorities pick their auditing targets? OECD tax advisor Manuel de los Santos joins CrossBorder Solutions from Paris to discuss the process for various member countries and other jurisdictions.
Sorry folks, but generic reports just aren’t cutting it anymore in the transfer pricing world. Here, a few of CrossBorder Solutions’ top execs explain why tax authorities reject them—and why big consultancies are still producing them. (Spoiler alert: it’s easier!)
Solid benchmarking begins with the right comparables, not necessarily the obvious ones. Here, CrossBorder Solutions’ Chief Economist Mimi Song and Senior Transfer Pricing Analyst Michael Quirk discuss the finer points of benchmark analyses. Learn how solid benchmarking studies can prove arm’s length transactions—and also, teach you a thing or two about your own business.
On today's episode, CrossBorder Solutions' VP of Economic Operations Andrei Enoiu and Chief Economist Mimi Song discuss how profit-based analysis can help determine if a transaction is arm’s length.
Those OECD-approved ways that prove you’re at arm’s length -- or at least let you cross your fingers and hope you’re at arm’s length.
CrossBorder Solutions' CEO Don Scherer stops by the Fiona Show to discuss why the changing global regulatory environment for transfer pricing necessitates the use of artificial intelligence to keep up, but unlike other industries impacted by technology, also accentuates the role that humans will always play in the process.
We're discussing all the hot debates at the crossroads of transfer pricing and the digital economy with Erin Perks, head of global transfer pricing at Marsh & McLennan live from CrossBorder Solutions' quarterly summit in beautiful Sarasota, Florida.
Dr. Ednaldo Silva of RoyaltyStat discusses hard to value intangibles at CrossBorder Solutions' quarterly summit in Sarasota, Florida.
Fiona and Matt walk through the challenges of global compliance with CrossBorder Solutions' chief economist Mimi Song, founding senior account executive Christy McDonald, and director of sales operations Michael Wallack. From the changing regulatory environment to how countries with developing markets are looking to transfer pricing to increase their tax revenue -- this is what every multinational company needs to know now.