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All aboard as we kick off our world tour, beginning with a visit to the Middle Kingdom. Navigating transfer pricing in China has never been more challenging or consequential for businesses operating within or expanding their footprint abroad. In this episode, we explore the evolving landscape for U.S. multinationals operating in China and for Chinese-headquartered groups expanding globally. From emerging controversy trends and heightened documentation expectations to practical strategies for risk management and alignment with value creation, we unpack key considerations for managing existing China structures and managing new investments in the region. As part of our Country Series, Exploring Transfer Pricing tours different jurisdictions with specialists to discuss some of what makes the particular region and country unique, and the impact it has on global transfer pricing. Join host Brittany Hardin Tanguay as she welcomes Tommy Tang (Managing Director, KPMG Philadelphia, with extensive experience in the China corridor) and Mimi Wang (Transfer Pricing Partner, KPMG Shanghai). Together, they share insights into audit expectations, the increasingly complex transfer pricing environment, and practical steps that multinational businesses can take to navigate challenges from both a Chinese and U.S. perspective.

Transfer pricing may be routed in rules and regulations, but the people who shape the field bring their own stories, perspectives, and motivations. In this special 'Get to Know' episode, host Brittany Hardin Tanguay sits down with three recent arrivals to KPMG who bring decades of experience from the IRS and Office of Chief Counsel. They discuss how they discovered tax and transfer pricing, what drew them into public service, and how their government experience now informs their work with multinational businesses. Join our host Brittany Hardin Tanguay as she welcomes Jayme Reynolds (Managing Director, Tax Controversy and Dispute Resolution (TCDR) and former IRS APMA official),Kathleen Agbayani (Managing Director, TCDR and former IRS Office of Chief Counsel attorney), and Doug O'Donnell (Senior Managing Director, TCDR and former Acting Commissioner and Deputy Commissioner of the IRS). Together, they discuss pivotal career moments, their first real exposure to transfer pricing, and the lessons they carry forward as they now advise multinational groups form the private-sector side of the table.

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In Part 2 of this two-part series, host Brittany Hardin Tanguay and Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) practice, continue their conversation fielding questions from transfer pricing professionals at the TP Minds West Coast event in Palo Alto. This episode digs into the practical realities of GenAI's impact on transfer pricing, covering three key areas: - The evolving value of data (and why a single data point is nearly worthless until it's aggregated, cleansed, and put to work) - How GenAI adoption is - and isn't - reshaping comparability analysis and benchmarking under TNMM and CPM, and - Where tax authorities are most likely to challenge intercompany arrangements tied to AI-driven value creation.

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, Brittany Hardin Tanguay, comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto. We explore the implications of GenAI on transfer pricing: - Does GenAI-generated content constitute new intellectual property? - How does automation shift the allocation of intercompany costs? - What steps can companies take to stay proactive amid the rapid adoption of this technology? From understanding the evolving role of data to tackling comparability challenges, this discussion explores the dynamic intersection of GenAI and transfer pricing in Part 1 of this two-part episode.

ICAP - the OECD's International Compliance Assurance Program - offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way? This episode presents a unique opportunity to hear directly from both perspectives: Doug O'Donnell, former IRS Acting Commissioner and Deputy Commissioner, who was instrumental in shaping ICAP for tax administrations, and Erik Skarstad, who has navigated the program during his time as a Transfer Pricing leader for Fortune 100 companies. Their firsthand experiences reveal the practical realities, challenges and benefits of participating in ICAP. Join our host Brittany Hardin Tanguay as she speaks with Doug O'Donnell (Senior Managing Director, Washington National Tax, Tax Controversy and Dispute Resolution) and Erik Skarstad (Managing Director, Tax, Transfer Pricing) to unpack ICAP's origins, objectives, and real-world impact. Together, they share insights from both sides of the table, government and taxpayer, on building trust, navigating challenges, and finding value in multinational cooperation.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses. This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next. Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.

On this episode of Exploring Transfer Pricing, we discuss utilizing process improvement tools to pinpoint where GenAI can truly shine in transfer pricing. With generative artificial intelligence (GenAI) taking the spotlight in innovation, organizations are asking: Where do we start? In this episode of Exploring Transfer Pricing, we discuss how process improvement methodologies can help businesses identify the best opportunities to integrate GenAI into transfer pricing processes. From reducing mundane manual tasks to scaling solutions globally, we explore how defining, discovering, and solving through structured frameworks can demystify GenAI's role in transforming your transfer pricing processes. Join our guest host Seth Salenger (Manager, Tax, Transfer Pricing), for a conversation with Amanda Carey (Managing Director, Tax, WNT - Transfer Pricing) and Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing). Together, they break down actionable steps for organizations to embrace GenAI as a tool for efficiency and innovation - while balancing quality and accuracy in a rapidly transforming tax landscape.

In this episode of Exploring Transfer Pricing, we discuss utilizing operational transfer pricing to move from a manual mess to an automated success. As global regulations intensify and the demand for accuracy grows, having a robust operational transfer pricing (OTP) strategy is no longer a luxury - it is a necessity. Many believe that implementing an OTP solution requires a large front investment, but a solution may not be out of reach. Our host Brittany Hardin Tanguay is joined by Raj Bodapati (Principal, Tax - National Leader, Operational Transfer Pricing) and Magdalena Bonna (Partner, Global Transfer Pricing Services - KPMG Germany), and together they examine how to turn your operational transfer pricing challenges into a competitive advantage.

What does the G7 agreement mean for Pillar Two in the US? How do changes to Foreign Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) influence transfer pricing strategies? Why is modeling more crucial than ever? This episode tackles these questions and more, offering insights into IP planning, cost sharing agreements, and the services cost method. Whether you're curious about the nuances of the G7 agreement or the implications of updates to the Base Erosion and Anti-Abuse Tax (BEAT), this episode provides insights and practical guidance to help taxpayers navigate the evolving transfer pricing landscape under OB3. Our host Brittany Hardin Tanguay is joined by Marissa Rensen (Managing Director, Washington National Tax - International Tax) and Thomas Bettge (Senior Manager, Washington National Tax - Transfer Pricing), and together they examine the legislative changes introduced by the One Big, Beautiful Bill (OB3) and its implications for transfer pricing.

Companies are rethinking tax strategies with an eye on transparency and responsibility in today's evolving landscape. On this episode of Exploring Transfer Pricing, we'll highlight the important role played by tax planning to support business growth objectives, and the important role of comprehensive transfer pricing documentation to mitigate audit risks. Join our host Brittany Hardin Tanguay as she, along with her guests Kristin Essary (Principal and National Transfer Pricing Advisory Leader), and Marissa Rensen (Managing Director, WNT - International Tax), explore how companies can leverage their intellectual property, navigate the intricacies of foreign tax credits, and manage the Base Erosion and Anti-Abuse Tax (BEAT). Discover how strategic collaboration and detailed modeling can unlock tax savings opportunities to ensure your business remains buoyant amidst today's turbulent tax tides.

Strap in for the rollercoaster of tariffs - How transfer pricing can help smooth out the ride. Join us for this episode as we attempt to unravel the complexities of tariffs and transfer pricing, and discuss what taxpayers need to be aware of to stay ahead of the rapidly changing tariff landscape. Join our host Brittany Hardin Tanguay as she, along with her guests Nicole Porpiglia (Managing Director, Tax, Trade and Customs) and Adam Kelfer (Managing Director, Tax, Transfer Pricing), share their experiences and reveal how strategic collaboration between transfer pricing and trade and customs teams can unlock significant value for businesses.

Let's agree to agree on the importance of intercompany agreements. In this episode, we delve into the critical role that intercompany agreements play in the realm of transfer pricing and global business operations. As businesses navigate the complexities of today's economic landscape, these agreements serve as essential tools for delineating risk, ensuring compliance, and maintaining audit readiness. Join our host Brittany Hardin Tanguay as she, along with her guest Mark Horowitz (Principal, Tax - KPMG US), react to the thoughts of other transfer pricing practitioners on the nuances of intercompany agreements. Brittany and Mark discuss the evolution of intercompany agreements, the importance of clear risk allocation, and the necessity of maintaining flexibility to adapt to unforeseen circumstances. Discover how businesses can effectively manage their intercompany agreements to align with tax authority expectations and safeguard against potential disputes, all while fostering a robust framework for global operations.

Understanding the critical link between Pillar 2 and transfer pricing. Delve into the intricate relationship between Pillar Two and transfer pricing in this episode of the KPMG Exploring Transfer Pricing podcast. As the OECD's Inclusive Framework introduces Pillar Two to ensure a minimum level of taxation for multinational groups, understanding its implications on transfer pricing has become paramount. How does Pillar Two affect the preparation and use of Country-by-Country reports? What are the critical components of the transitional Safe Harbor test under Pillar Two? And what role does operational transfer pricing play in managing Pillar Two compliance? Join our host, Brittany Hardin Tanguay, as she explores these pivotal questions with Lucia Barone, a tax partner with KPMG Italy, and Kathy Lim, a tax partner based in Belgium. Together, they provide valuable insights and practical advice to help multinational groups navigate the complexities of Pillar Two.

Reflecting on the international and transfer pricing landscape of 2024, and anticipating what's on the horizon for 2025. As the curtain falls on 2024, we take a retrospective journey back through the key tax initiatives that have carved the contours of the transfer pricing arena this year. This episode casts its navigational net wide, exploring topics from foreign derived intangible income (FDII) and base erosion and anti-abuse tax (BEAT) Planning, to generative artificial intelligence (GenAI), and on-going controversies and compliance changes in transfer pricing. Join our guest host Seth Salenger, along with guests from the KPMG U.S. Washington National Tax Practice Jessie Coleman and Brittany Hardin Tanguay, as they come together to discuss the highlights and developments of the year gone by, and consider the challenges and opportunities set to shape the year ahead.