Exploring Transfer Pricing

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.