Explore every episode of the podcast The Fiona Show: Transfer Pricing

Here, a few best practices for 2022 that every transfer pricing professional should embrace. CrossBorder Solutions

Since the introduction of BEPS, "tax transparency" has become a buzz phrase around the globe. What does transparency look like in the U.S.? And how is the IRS beefing up efforts to promote it here at home? In this episode of The Fiona Show, transfer pricing expert and former IRS competent authority analyst, Barbara Mantegani makes it all clear. CrossBorder Solutions

With the introduction of faceless audits in India last year, a new era in tax transparency appears to have dawned – and just in time to compensate for a global lockdown. Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law, joins today's Fiona Show podcast to discuss what the practice could mean for transfer pricing beyond COVID, and how multinationals can prepare for this new wave of efficient examination. CrossBorder Solutions

Stock based compensation is a way of paying company members with equity in the business, which is great for companies and employees. From a transfer pricing perspective, however, it can cause problems. Here, David Chamberlain of California Polytechnic State University-San Luis Obispo explains some of the issues that can arise and what multinational companies can do about them. CrossBorder Solutions

Global tax reform is underway, creating a new framework that comes with constant contradictions. On today's episode, Dr. Lorraine Eden returns to discuss her takeaways from proposals to tax only the 'top 100' companies in Pillar One negotiations. CrossBorder Solutions

Germany's recent compliance initiatives are picking up more speed than the Autobahn. On today's episode, CrossBorder Solutions Tax Director Hasker Hoogenberg and independent German-based transfer pricing  specialist Oliver Treidler examine the transforming audit environment in Germany, and how MNEs can insulate themselves from further examination. CrossBorder Solutions

CrossBorder Chief Economist Mimi Song and transfer pricing expert Johann Muller take a closer look at the impacts of COVID-19 for low-risk distributors. Should these entities be able to absorb losses? Listen here to find out. CrossBorder Solutions

We know you love our expert coverage of the transfer pricing landscape, but did you know we bring that same level of informative analysis to the world of research and development tax incentives? On The Fiona Show: R&D Tax Credit, we—along with leading tax experts—explore how these incentives reward companies for innovation, fuel economic growth, and lead to paradigm-shifting discoveries across industries. If you don’t know R&D tax incentives, you may be part of the tragic majority leaving money on the table. Explore the back catalog of The Fiona Show: R&D Tax Credit to level up your tax knowledge, and subscribe to stay ahead on the latest in global innovation and the tax incentives that very likely come with it. CrossBorder Solutions

Getting the world to agree on a global tax plan is no easy job. This podcast discussion reveals what’s triggering global tax debates, and how MNEs can avoid getting caught in the middle. CrossBorder Solutions

Public country-by-country reporting is very close to becoming a reality in the European Union. How would this transparency initiative impact multinationals and the global tax community? CrossBorder Solutions’ Transfer Pricing Director Pamesh Sharma and Queen Mary University of London Tax Law Professor Christiana HJI Panayi explore the implications. CrossBorder Solutions

This episode explores the landmark Glencore versus the Australian Taxation Office case, and what it means for the future of compliance. Former ATO member Geoff Morris and CrossBorder Solutions’ Director Solutions Engineer Doug Darling discuss CrossBorder Solutions

Chief Economist Mimi Song joins University of Connecticut Professor of Law Richard Pomp to examine Amazon’s latest win against the European Commission and the key transfer pricing takeaways for multinationals. CrossBorder Solutions

Chief Economist Mimi Song defines key tax terms, from tax scrutiny to “the race to the bottom,” and explains how they translate in the global tax conversation. CrossBorder Solutions

Why did the Italian Supreme Court administer two different rulings on inter-company transactions? What can taxpayers learn from it? Chief Economist Mimi Song and University of Ferrara Professor of Law Marco Greggi discuss. CrossBorder Solutions

The Danish Tax Authority’s recent win against Tetra Pak Processing Systems can only mean one thing: increased scrutiny for taxpayers. Chief Economist Mimi Song and international corporate income tax expert Johann Muller analyze how the Tetra Pak win could bolster the tax authority’s confidence, leading to a likely increase in audits. CrossBorder Solutions

What's the relationship between tech and tax? How will the Biden administration’s latest tax proposals impact U.S. tech giants? Chief Economist Mimi Song and Vice President of Global Projects at the Tax Foundation Daniel Bunn unpack these questions and more. CrossBorder Solutions

It's the tax news heard 'round the world: the G7 announced their support for the United States-proposed 15 percent minimum global tax on multinational corporations. CrossBorder Solutions Chief Economist Mimi Song and Director of International Tax Michael Desimone examine the details, contemplate what comes next, and advise MNEs on how they can best prepare. CrossBorder Solutions

Over the last two years, few jurisdictions have heightened their transfer pricing scrutiny with the enthusiasm of Vietnam. CrossBorder Solutions Chief Economist Mimi Song and Duke University professor Eddy Malesky discuss how MNEs can brace themselves for impact. CrossBorder Solutions

How much do we love transfer pricing? Every single of the 100 episodes that make up 'The Fiona Show: Transfer Pricing' podcast lets us count the ways, but to celebrate our centennial episode, we boiled down 10 essential lessons our guests have taught us about how transfer pricing is an art -- not a science.  CrossBorder Solutions

The value chain analysis is essential for planning and defending a multinational's transfer pricing. International corporate income tax expert Johann Muller joins CrossBorder Solutions Chief Economist Mimi Song on today's episode to answer every question on value chains and transfer pricing you're too afraid to ask. CrossBorder Solutions

With new initiatives by the HMRC to claim the £34 billion that it says MNEs owe the UK in unpaid taxes, the message to taxpayers is painstakingly clear: transfer pricing compliance in the UK is an order, not a request. CrossBorder Chief Economist Mimi Song and UK-based transfer pricing expert Pamesh Sharma talk about how MNEs can best prepare for more scrutiny. CrossBorder Solutions

CrossBorder Solutions Director of International Tax Michael Desimone joins Chief Economist Mimi Song to discuss what the Biden administration's 'Made in America' tax plan has in store for MNEs, especially those with operations in low-tax jurisdictions. CrossBorder Solutions

CrossBorder Solutions Chief Economist Mimi Song and Dr. Diana Criclivaia discuss everything you need to know about joint audits, and why they're rising in prevalence. CrossBorder Solutions

While the EU Commission cannot determine tax rates for individual jurisdictions, they do have other weapons in their arsenal to fight BEPS. David Chamberlain, assistant professor of Accounting and Tax at California Polytechnic State University, joins CrossBorder Solutions Chief Economist Mimi Song to discuss the commission's deluge of state aid cases against the biggest household names among MNEs. CrossBorder Solutions

Anticipating the tax scrutiny for FY 2020, CrossBorder Solutions Chief Economist Mimi Song offers her expert strategies for helping MNEs stay compliant in her latest article in Treasury and Risk. CrossBorder Solutions

As the last few years have shown, tariffs can have a big impact on a multinational's transfer pricing. CrossBorder Solutions Chief Economist Mimi Song and transfer pricing expert Hasker Hoogenberg discuss recent trends and the ways Customs enforcement agencies look at their jobs differently than international tax authorities. CrossBorder Solutions

How effective are country-by-country reports in mitigating base erosion and profit shifting? And would making CbCRs public actually end up hurting analysis? Charles University’s Dr. Petr Jansky joins CrossBorder Solutions Chief Economist Mimi Song to discuss. CrossBorder Solutions

Chief Economist Mimi Song discusses her whitepaper, The Future of Benchmarking, and how technology changes the game for transfer pricing compliance. CrossBorder Solutions

Transfer pricing service transactions are one of the most highly scrutinized by tax authorities. Here, find out why and learn the steps you can take to minimize your risk. CrossBorder Solutions

CrossBorder Solutions transfer pricing expert, Doug Darling, explains the OECD's Guidance on Financial Transactions and offers strategies that promise to keep you in compliance in every jurisdiction. CrossBorder Solutions

China was the first country struck by the pandemic, but it was also the first economy to recover. CrossBorder Chief Economist Mimi Song joins the podcast to discuss lessons the world can learn from its quick revival, and address specific concerns of MNEs with Chinese operations. CrossBorder Solutions

Law360 reporter Alex Parker returns to the Fiona Show to discuss the likely impact that President Biden's plans to reform GILTI will have on the OECD's digital service tax proposals. CrossBorder Solutions

CrossBorder Solutions’ Chief Economist Mimi Song and Director Solutions Engineer Doug Darling discuss how tax jurisdictions are cracking down on profit shifting through transfer pricing, and ways MNEs can avoid extra examination. CrossBorder Solutions

Chief Economist Mimi Song discusses taxation of the digital economy, and the implications for MNEs. CrossBorder Solutions

 CEO of Royalty Stat Dr. Ednaldo Silva discusses what new OECD guidance for transfer pricing regimes in developing countries means for MNEs. CrossBorder Solutions

On this episode of 'The Fiona Show' find out which 5 jurisdictions are on our "must-watch" list for increased transfer scrutiny in 2021. CrossBorder Solutions

Transfer pricing expert—and arm's-length standard crusader—Dr. Lorraine Eden returns to The Fiona Show to talk about what Pillar One means for the global tax landscape. CrossBorder Solutions

We recap the year in transfer pricing litigation across the world with 25 year-plus industry veteran and former IRS competent authority analyst, Barbara Mantegani. CrossBorder Solutions

As the latest member of the OECD, Colombia is making a name for itself as a no-nonsense jurisdiction from clamping down on commodities to DIAN's unique tax value units system. CrossBorder Solutions

We recap our year of advice on transfer pricing amid a pandemic from experts on the 'Fiona Show' podcast with CrossBorder Solutions Chief Economist Mimi Song. CrossBorder Solutions

Mimi Song is not only CrossBorder Solutions’ Chief Economist but also an economy news pundit rock star all in her own right. We talk to her in-depth about about her new article in Bloomberg, “Tax Scrutiny and What You Can Expect in 2021” and what new OECD guidelines mean for the post-COVID transfer pricing landscape. CrossBorder Solutions

Looking to avoid a tax audit in the former Soviet Union? On this episode, learn more about Russia’s transfer pricing rules and regulations, and how technology can help. CrossBorder Solutions

Big news: Italy is changing its transfer pricing regulations. This episode uncovers everything you need to know about the updated requirements and the implications for taxpayers. CrossBorder Solutions

An OECD enhanced participation status; an assigned transfer pricing account representative; 4 days to produce documentation when under audit. Transfer pricing in Indonesia proves to be a windy road. In this episode, learn how to navigate this unique jurisdiction’s rules and regulations. CrossBorder Solutions

What does it take to stay in compliance with the Turkish Ministry of Finance? It’s more complicated than you think. CrossBorder Solutions

Don’t be fooled by Vietnam’s low thresholds. It ranks high on the audit scale. Find out the tax compliance boxes you need to check in this developing country. CrossBorder Solutions

What does it take to stay on the Israeli Tax Authority's good side? Here's everything you need to know. CrossBorder Solutions

Lax on the outside with its own set of preferences on the inside. Transfer pricing in Thailand just isn't what it seems. CrossBorder Solutions

Strictly loose or loosely strict? Learn more about New Zealand’s intricate transfer pricing rules and regulations. CrossBorder Solutions

What do the regulations in this dimensional jurisdiction reveal about the country itself? Find out in Part Two of a two-part discussion with South Africa transfer pricing expert Dr. Keith Engel. CrossBorder Solutions