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 pricing. We discuss practical aspe...
7 Nov 202426min
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 discuss how different regulations a...
8 Okt 202426min
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 what is AI, Generative AI and how ne...
16 Sep 202428min
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 explore several of the most inter...
26 Aug 202427min
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 this episode of Uncontrolled Opinion...
23 Juli 202431min
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 used in transfer pricing. They di...
15 Juli 202426min
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 Amount B, emphasizing its focus on ta...
25 Apr 202433min
