Interco Financing and Swaps
In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing.Part 1 — Intercompany Financing: Foundations, Challeng...
9 Des 202541min
Highlights from NABE 2025 TP Symposium
In 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 several of the most intere...
29 Okt 202543min
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 context of transfer pricing. We...
8 Apr 202550min
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 resources below, including guidance, ...
26 Mar 202538min
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 deep expertise in intercompany (IC...
14 Mar 202540min
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 the matter centers on “illegal sta...
13 Jan 202535min
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 discussion is particularly timely...
19 Nov 202422min
