The Fiona Show: Transfer Pricing

Episode 50: What You Need to Know About Transfer Pricing in Italy

The Italian way of life is pretty easy-going, but the Italian tax authorities? Not so much.

3 Jun 2020 45 min

Episode 49: Transfer Pricing in the Time of COVID-19

Transfer pricing compliance in 2020 promises to be tricky. CrossBorder Solutions' experts reveal what to keep an eye on now.

20 May 2020 48 min

Episode 48: Meet Dennis Blackburn, Technical Consumer Products, Inc.

Tax scrutiny, compliance, the effects of Covid-19—it’s all in a day’s work for this transfer pricing exec.

15 May 2020 44 min

Episoode 47: Think Globally—Comply Locally

The secret to fail-proof transfer pricing compliance? We’ve got it right here.

6 May 2020 45 min

Episode 46: Transfer Pricing in Poland

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.

29 Apr 2020 53 min

Episode 45: Will the Coronavirus Change Your Transfer Pricing Policy?

We spoke with three tax executives to see how they’re adjusting to the impact of COVID-19.

22 Apr 2020 53 min

Episode 44: Tax Transparency and the Future

Will public reporting make tax transparency even more revealing? All signs point to, yes.

15 Apr 2020 51 min

Episode 43: Transfer Pricing in the Netherlands

Can this so-called tax haven clean up its act?

9 Apr 2020 1 hr 10 min

Episode 42: Are You Transfer Pricing Audit-Ready?

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.

1 Apr 2020 59 min

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…

25 Mar 2020 1 hr 13 min

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.

18 Mar 2020 55 min

Episode 39: Just What You Needed: Another Reporting Requirement

Welcome to DAC6.

11 Mar 2020 58 min

Episode 38: The Client: Meet Willy Ong from Harsco

This transfer pricing exec says audits aren’t a question of “if,” they’re a question of “when.” Here, he explains why.

4 Mar 2020 36 min

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…

26 Feb 2020 57 min

Episode 36: Permanent Establishments’ Shaky Grounds

Given the brave new digital economy, the definition of permanent establishment is anything, but well, permanent.

20 Feb 2020 42 min

Episode 35: The Client - Doug Darling

This transfer pricing expert has seen it all.

12 Feb 2020 54 min

Episode 34: Could a Global Minimum Tax Really Work?

It's certainly not out of the question. Here, Dr. Lorraine Eden, a transfer pricing expert, professor, author -- and lately, podcast rockstar -- explains why.

5 Feb 2020 58 min

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…

29 Jan 2020 1 hr 23 min

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.

22 Jan 2020 33 min

Episode 31: You Say You Want a Resolution...

What happens when you take your transfer pricing dispute to the competent authority? Tax attorney—and former competent authority analyst—Barbara Mantegani tells all.

15 Jan 2020 1 hr 02 min