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  • Taxing Times: 2024 Transfer Pricing Recap and Beyond

    Taxing Times: 2024 Transfer Pricing Recap and Beyond
    2024/10/17
    Reflecting on the international and transfer pricing landscape of 2024, and anticipating what's on the horizon for 2025. As the curtain falls on 2024, we take a retrospective journey back through the key tax initiatives that have carved the contours of the transfer pricing arena this year. This episode casts its navigational net wide, exploring topics from foreign derived intangible income (FDII) and base erosion and anti-abuse tax (BEAT) Planning, to generative artificial intelligence (GenAI), and on-going controversies and compliance changes in transfer pricing. Join our guest host Seth Salenger, along with guests from the KPMG U.S. Washington National Tax Practice Jessie Coleman and Brittany Hardin Tanguay, as they come together to discuss the highlights and developments of the year gone by, and consider the challenges and opportunities set to shape the year ahead.
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    15 分
  • DEMPE Demystified: Navigating Intangible Assets in Transfer Pricing

    DEMPE Demystified: Navigating Intangible Assets in Transfer Pricing
    2024/09/26
    From development to exploitation, refining our understanding of DEMPE in transfer pricing. Dive into the ever-changing world of DEMPE (Development, Enhancement, Maintenance, Protection and Exploitation) in this episode of the KPMG TaxRadio podcast Exploring Transfer Pricing, where we reflect on insights from the DEMPE session during the KPMG 2024 U.S. Cross-Border Tax Conference. Building on the results of our live survey with a diverse group of tax professionals representing multinational enterprises, we explore their perspectives and potential trends, offering a comprehensive and insightful view of the current and future state of transfer pricing. What are the key challenges companies face when integrating new acquisitions or managing dispersed senior management? How do different tax authorities mold DEMPE with their unique interpretations? And what strategies can businesses employ to mitigate risks and prepare for potential audits? Join our host, Brittany Hardin Tanguay, alongside Jack O'Meara and Prita Subramanian, both Principals in the KPMG U.S. Washington National Tax Practice, as they answer these questions and unpack the results of a recent survey conducted at the KPMG 2024 U.S. Cross-Border Tax Conference.
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    17 分
  • What's Shaping Tax Controversy in Latin America?

    What's Shaping Tax Controversy in Latin America?
    2024/09/04
    From the Samba to Merengue, exploring the tax dance in the Latin American region. Rhumba-ing into the complicated dance of transfer pricing controversy, this episode discusses the tax controversy trends seen in the region of Latin America, or LATAM. What avenues are there for companies to address tax certainty and controversy in LATAM? Which transactions draw the most scrutiny for the LATAM tax authorities? And how can companies look to mitigate some of the risks of operating in the LATAM region? Join our host, Brittany Hardin Tanguay, as she explores the secret spices of LATAM tax issues with Alejandro Barran, Partner, Tax - Transfer Pricing, KPMG Mexico, former head of the Competent Authority office in Mexico in charge of the Advance Pricing Agreements and Mutual Agreements Procedures, and Juan Carlos Vidal, Partner, Tax - KPMG Peru. Together, they explore the transfer pricing issues and difficulties operating within the LATAM region.
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    17 分
  • What's Shaping Tax Controversy in Ireland and the UK?

    What's Shaping Tax Controversy in Ireland and the UK?
    2024/08/06
    From cliffs to castles, exploring the tax terrain of Ireland and the UK. Diving into the stormy seas of transfer pricing disputes, this episode unveils the escalating challenges and evolving trends in the United Kingdom and Ireland. How has Brexit reshaped the transfer pricing relationship between the competent authorities in Ireland and the UK? What impact has the OECD and G20's Base Erosion and Profit Shifting, or BEPS, initiative had on transfer pricing disputes in these regions? And how effective are tools like Advance Pricing Agreements, or APAs, and Mutual Agreement Procedures, or MAPs, in mitigating these disputes? Join our host Brittany Hardin Tanguay as she and her guests Neil Casey, Partner, Transfer Pricing, KPMG Ireland and Nick Stevart, Director, Global Transfer Pricing Controversy Management, KPMG UK explore the latest trends, notable cases, and the evolving landscape of transfer pricing in these two jurisdictions.
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    16 分
  • Unraveling the Intricacies of Legal Entity Rationalization and Transfer Pricing

    Unraveling the Intricacies of Legal Entity Rationalization and Transfer Pricing
    2024/06/28
    Trim down with legal entity rationalization and streamline your transfer pricing. Legal entity rationalization, a strategic method of streamlining corporate structures, plays a pivotal role in enhancing business efficiency and cost-effectiveness. But how does this process help businesses meet their objectives? And what is its significance in the face of ever-changing tax landscapes and regulatory requirements? In this episode, we discuss how businesses are assessing their current legal entity structure, as well as how and why they pinpoint opportunities for rationalization, all while considering transfer pricing. Join our host, Brittany Hardin Tanguay, as she delves into this captivating discussion with Ashley Marx, Managing Director, Tax - Mergers and Acquisitions (KPMG US), and Adam Kelfer, Managing Director, Tax - Transfer Pricing (KPMG US).
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    16 分
  • Will GenAI Revolutionize Transfer Pricing?

    Will GenAI Revolutionize Transfer Pricing?
    2024/06/06
    Unlocking the potential of GenAI throughout the Transfer Pricing lifecycle. Within the complex landscape of transfer pricing, the introduction of generative artificial intelligence (GenAI) is stirring up a new era of possibilities. But how is GenAI influencing this multifaceted field? What novel trends are emerging, propelled by GenAI advancements? And how should we incorporate this cutting-edge technology into the traditional transfer pricing approach? Delve into the discussion as we navigate the exciting intersection of GenAI and transfer pricing. Join our host Brittany Hardin Tanguay as she poses the questions you asked at TP Minds held in San Francisco last December, to Thomas Herr, KPMG US National Leader in Transfer Pricing and Innovation. Listen as Thomas reflects on how AI will automate and transform transfer pricing in the future.
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    18 分
  • What's shaping Tax Controversy in Germany and the Netherlands?

    What's shaping Tax Controversy in Germany and the Netherlands?
    2024/04/29
    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 分
  • How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?

    How Do Treaty-Based Resolutions Solve Transfer Pricing Disputes?
    2024/03/20
    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 分