『The Transfer Pricing Show』のカバーアート

The Transfer Pricing Show

The Transfer Pricing Show

著者: Josh Post
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International tax and transfer pricing explained from the ground up. I’m Josh Post, a Transfer Pricing Principal at Ryan, passionate about automating and modernizing TP with AI. Each episode tackles the basic questions you were too embarrassed to ask, drawn from my current learning and research. I use NotebookLM/AI to help organize sources and prompts—AI can make mistakes, so please verify. No client/confidential info. Views are mine, not Ryan’s. Educational only—not tax/legal advice.Josh Post 経済学
エピソード
  • Benefit Test 2.0: Same Rules, Better Examples
    2026/06/04

    Review of the OECD 's draft rewrite of Chapter VII on intra-group services,. The but the biggest story isn't new rules—it's better examples. In this episode, we break down the consultation draft's treatment of expected benefits, failed ERP and SAP implementations, shareholder activities, duplication, pass-through costs, and method selection.

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    52 分
  • PCbCR: Congratulations, You're Transparent Now!
    2026/05/13

    For years, your country-by-country data sat in a government database that nobody read. That's over. The EU and Australia now require the same jurisdiction-level revenues, profits, and tax figures to be published on the open internet — in machine-readable formats explicitly designed for automated analysis. In this episode, we break down what's actually required, who's caught by thresholds they didn't see coming, why hub entity selection in Europe can make or break your compliance strategy, and what it means that a journalist can now write one script and fish for headlines across every multinational's filing simultaneously. The data is what it is. The question is whether you see your own story before someone else tells it for you.


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    32 分
  • The International Emergency Economic Podcast — SCOTUS Strips White House of Its Favorite Trade Weapon
    2026/02/20

    The Supreme Court ruled 6-3 that IEEPA does not authorize presidential tariffs. Roberts held that "regulate … importation" doesn't include the power to tax — a power the Constitution reserves to Congress. The ruling invalidates the reciprocal and drug-trafficking tariffs but leaves Section 232/301 duties intact. Refund exposure may top $175B. The administration vows to reimpose tariffs under other statutes, but those tools are narrower, capped, and require formal investigations IEEPA never demanded.


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    18 分
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