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.
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17:49
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17:49
How Can Companies Plan to Enhance Transfer Pricing in the Current Tax Environment?
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.
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19:33
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19:33
How Do Tariffs and Transfer Pricing Interact?
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.
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20:06
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20:06
Why Are Intercompany Agreements Important?
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.
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20:35
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20:35
Why Are Intercompany Agreements Important?
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.
In the Exploring Transfer Pricing podcast series, brought to you by KPMG TaxRadio, a KPMG manager asks senior transfer pricing professionals the questions on her mind. After listening you'll have a clearer roadmap to traverse the transfer pricing landscape, whether you're a seasoned international tax professional, an inquisitive economist, or simply a curious explorer.
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