Episode 106: CbCR: The evolving landscape

August 14, 2024

In this TP Talks podcast, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice) and David Ernick (Principal in PwC’s US National Tax Services Transfer Pricing practice) discuss the evolving landscape of country-by-country reporting (CbCR) with a focus on the Pillar Two Transitional CbCR Safe Harbor, its three tests, and the importance of accuracy in CbCR data. They then move on to public CbCR, addressing the shift from confidentiality to public disclosure, the potential differences in rules between countries, and important strategic considerations for companies. Kristina and David finish with key takeaways.

Contacts: Kristina NovakDavid Ernick





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Ian Dykes

Ian Dykes

Global Transfer Pricing Network Leader, PwC United Kingdom

Tel: +44 7803 149718

Kristina Novak

Kristina Novak

Washington National Tax Services, Transfer Pricing, Principal, PwC US

Tel: +1 (469) 878-4552

John Cianfrone

John Cianfrone

Washington National Tax Services, Transfer Pricing, Director, PwC US

Tel: +1 (646) 951-7680

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