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Episode 41: Cost-Sharing Post TCJA

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.

Episode 40: India

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.

Episode 37: Transfer Pricing in the UK

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.

Episode 33: Pillar One is Not BEPS 2

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.

Episode 32: So, You Want to Be In More Than Pictures?

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.

Episode 30: Transfer Pricing New Year's Resolutions

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.

40 episodes

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