All Episodes
Displaying 1 - 13 of 13 in total
Why We Do This
For episode 13, we're getting personal! We're digging into why we started this podcast and the unplanned beginnings of our careers in transfer pricing. Get our "uncont...
Economic Substance and TP
In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economic substance in the...
Amount B / SSA Refresher
In this episode, we refresh on Amount B / Simplified and Streamline Approach (SSA). We cover what has happened since February 2024.For a deeper dive, explore the reso...
Transfer Pricing for Intragroup Loans
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing practitioner with d...
Apple ECJ State Aid Case TP implications
In this episode, Mikhail and Silvana dive into the 2024 European Court of Justice (ECJ) decision on Apple’s contested tax arrangements in Ireland. While the heart of t...
Country Risk Premium Adjustment in TNMM
In this episode of Uncontrolled Opinions, Mikhail and Silvana discuss the country risk premium adjustment when applying a Transactional Net Margin Method (TNMM). This ...
Public vs Private Companies in CPM/TNMM Analyses
In this episode of Uncontrolled Opinions, we explore the pros and cons of using public and private company data in the context of a TNMM or CPM analysis in transfer pr...
TNMM & Local Country Rules
In this episode, Silvana and Mikhail explore how local country-specific rules impact the use of the Transactional Net Margin Method (TNMM) in transfer pricing. They di...
AI in Transfer Pricing
Is there a role for AI in transfer pricing?We believe the simple answer to this question is – yes – but with a few qualifiers. In this conversation, we dive into wha...
Highlights from the NABE TP Symposium 2024
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2024 Transfer Pricing Conference. Mikhail and Silvana ...
What is Control?
What is “Control”? Nope we are not talking about Janet Jackson’s song. The raison d’etre in TP is pricing of “Controlled Transactions”. So, what is control? In thi...
Arms' Length Range
Arm's Length Range: In this episode, Mikhail and Silvana dive into the intricacies of the arm's length range, the interquartile range, and various statistical methods ...
The Evolution and Impact of Amount B
In this Podcast, Silvana and Mikhail discuss the developments surrounding OECD Amount B guidance as it stands in March 2024. We explore the scope and criteria of Amou...