Om denne podcast
All things transfer pricing. Uncontrolled Opinions is an open-ended exploration of all things transfer pricing. Silvana and Mikhail, share their views and insights from a practical transfer pricing economists lens.
Episoder
- Interco Financing and Swaps · 41 min. · Episode 15In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing. Part 1 — Intercompany…
- Highlights from NABE 2025 TP Symposium · 44 min. · Episode 14In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2025 Transfer Pricing Conference. Mikhail and Silvana explore…
- Why We Do This · 25 min. · Episode 13For 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 "uncontrolled…
- Economic Substance and TP · 50 min. · Episode 12In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economic substance in the context of…
- Amount B / SSA Refresher · 38 min. · Episode 11In 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 resources…
- Transfer Pricing for Intragroup Loans · 41 min. · Episode 10In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing practitioner with deep…
- Apple ECJ State Aid Case TP implications · 35 min. · Episode 9In 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 the matter…
- Country Risk Premium Adjustment in TNMM · 23 min. · Episode 8In this episode of Uncontrolled Opinions, Mikhail and Silvana discuss the country risk premium adjustment when applying a Transactional Net Margin Method (TNMM). This discussion…
- Public vs Private Companies in CPM/TNMM Analyses · 27 min. · Episode 7In 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 pricing. We…
- TNMM & Local Country Rules · 26 min. · Episode 6In 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 discuss how…
- AI in Transfer Pricing · 28 min. · Episode 5Is 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 what is AI…
- Highlights from the NABE TP Symposium 2024 · 28 min. · Episode 4In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2024 Transfer Pricing Conference. Mikhail and Silvana explore…
- What is Control? · 32 min. · Episode 3What 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 this episode of…
- Arms' Length Range · 27 min. · Episode 2Arm'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 used in…
- The Evolution and Impact of Amount B · 33 min. · Episode 1In 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 Amount B…
