Advertise on podcast: TP Talks - PwC's Global Transfer Pricing podcast

An examination of how transfer pricing has evolved, as former PwC principal David Ernick reflects on public CBCR, tax transparency, and what may lie ahead. Support the show

Hear how AI is transforming financial transactions in transfer pricing, from tax audits and documentation to market data analysis, and why human judgment remains key. Support the show

PwC’s Sarah Kafka joins Kristina and John to discuss tariff strategy, transfer pricing, customs documentation and readiness amid growing CBP scrutiny. Support the show

Kristina and John are joined by Eric Mehta to discuss the significant transfer pricing reforms announced as part of India's Union Budget 2026. Support the show

Kristina Novak and John Cianfrone sit down with Mona Cairncross for an inside look at global transfer pricing negotiations and lessons from her time as Assistant Director of the IRS APMA Program. Support the show

This episode explores how AI is reshaping transfer pricing, including real-time monitoring, evolving documentation, and tax authority enforcement. Support the show

This episode explores OECD Chapter VII and global mobility, Pillar One and DSTs, and recent UK transfer pricing developments. Support the show

This TP Talks episode explores the evolving transfer pricing audit landscape, including voluminous IDRs, MAP and APA strategy, and a look at potential 2026 controversy risks. Support the show

Kristina Novak is joined by Nick Houseman, PwC Australia’s Transfer Pricing Leader, to discuss Australia’s tax and transfer pricing enforcement landscape. Support the show

Kristina Novak and Kristin Bohl discuss the evolving global tariff landscape and what it means for transfer pricing. Support the show

David Ledure and his panel discuss the most pressing challenges companies face in managing intercompany financial transactions, drawing on feedback received directly from clients and colleagues. Support the show

Kristina Novak, Marco Fiaccadori, and John Cianfrone discuss the complex and evolving landscape of intercompany services transactions. Support the show

In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact. Support the show

Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader).  Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today. Support the show

In this TP Talks Special Edition podcast, David Ledure (Global Financial Transactions Transfer Pricing Leader, PwC Belgium) sits down with Kristina Novak (Transfer Pricing Principal, PwC US) Michael Douglas (Transfer Pricing Director, PwC Ireland), and Jake Roche (Transfer Pricing Director, PwC Australia) to discuss tax controversy with respect to intercompany financing, focusing on recent case law. They examine the challenges posed by tax authorities when it comes to benchmarking interest rates and the factors that influence these decisions, including credit risk assumptions and implicit guarantees. The speakers delve into the approaches of tax authorities in different jurisdictions, including Ireland, the United States, and Australia, particularly how they handle debt recharacterization and the application of implicit guarantees. They also discuss strategic consideration of APAs and MAPs to potentially avoid litigation and achieve double taxation relief. Support the show