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Episode 20: Tales of Excruciating Audits

As any tax executive knows, by-the-book transfer pricing audits are difficult enough. So how does an MNE play by the rules when there are no rules? A.C.N.’s Laurie McDonough shares her audit survival strategies.

Episode 19: Tax Certainty, Fact or Fiction?

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.

Episode 18: Transfer Pricing in A Recession

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.

Episode 17: The OECD-Brazil Project

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.

Episode 14: Intracompany Service Transactions

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.

Episode 13: Intercompany Agreements and What You Need To Know Now

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.

Episode 12: The Client

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.

Episode 11: Argentina Under the Microscope

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.

Episode 10: Altera vs the IRS—and What the Outcome Means for You

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 effected by the verdict.

Episode 9: Red Flags for Audits

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.

20 episodes

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