Transfer pricing may be one of the most talked-about and least understood tax topics right now. The underlying concept is simple: it’s the method for pricing transactions between related parties. But what qualifies as “related parties” and how those transactions are valued have become increasingly complicated in a more global and more digital world.

Companies facing international taxation are navigating transfer pricing in an ever-changing business landscape.

On today’s episode of the Taxgirl podcast, Kelly is joined by Andrew O’Brien-Penney and Tamara Levin to tackle the intricacies of transfer pricing. Andrew is the Director of Economics at Baker McKenzie LLC in Chicago. He has experience in transfer pricing and valuation matters, assisting major multinational companies in advising clients and audit and dispute resolution situations, supply chain restructuring, planning, advance pricing agreements (APAs), and intellectual property migration opportunities. Tamara is a partner at Baker McKenzie’s Palo Alto Tax Practice Group. She advises mostly tech-based companies on transfer pricing and tax planning matters, including structuring and implementing international operations, cross-border transactions, and post-acquisition integrations.

Andrew and Tamara recently co-authored a special report, Digital Revolution: Transfer Pricing on the Global Tax Battlefield (link below), together with other members of Baker McKenzie’s global tax practice. In this podcast episode, they discuss some of the details of that report along with their experiences advising multinational companies.

Listen to Kelly, Andrew, and Tamara talk about:

  • What is transfer pricing and why is it being talked about so much right now?
  • What happens as global companies develop new digital intellectual property
  • The extent to which multinational companies deal with transfer pricing
  • How machine learning and artificial intelligence factor into valuation matters
  • Advising multinational companies with different views on jurisdiction or location
  • How to document existing international taxation frameworks to support new kinds of data
  • How the EU is tackling transfer pricing with working groups
  • Changes in the audit space and where tax authorities are targeting most
  • How has the pandemic changed things in the international tax world?
  • Does widespread remote work change or influence multinational business tax advice?
  • Projecting changes and technological adaptations to come in the next few years
  • How much do you try to learn about how multinational companies conduct their business?
  • Conducting functional interviews as tax professionals and how they inform tax advice
  • A typical day in the life of transfer pricing tax professionals
  • How are clients feeling about increased transparency and public reporting? 

More about Kelly:

Kelly Phillips Erb created and hosts the Taxgirl podcast, your home for tax news, tax info, and tax policy. In each episode, she shares conversations about taxes, money, and the choices we make. Kelly is a tax attorney who works with taxpayers and tax practitioners like you every day. She helps folks out of tax jams, and hopefully, keeps others from getting into them.

You can find out more about Kelly here and you can follow her on Twitter, Facebook, Instagram, and Linkedin.

To subscribe to the podcast (it’s free!) using Apple, Spotify, or your favorite listening app, click here.

Kelly’s Website: Taxgirl

Baker McKenzie: Website

A Brave New World: Transfer Pricing for Digital Transformation Bloomberg Insights

Digital Revolution: Transfer Pricing on the Global Tax Battlefield Bloomberg Tax International Journal (subscription required)

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