Exploring Transfer Pricing

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.

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.

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.