Episode 89: EU and UK Transfer Pricing controversy trends and outlook

October 31, 2022

In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC’s US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends, and more.

Discussed in this episode

  • What are tax authorities focusing on in the EU and UK with respect to TP audits and what can taxpayers expect going forward?
  • Is DAC 6 reporting and country-by-country reporting generating audit activity?
  • What transfer pricing litigation trends do you see?
  • Do you see the recently issued bilateral APA manual issued by OECD Forum on Tax Administration having any impact in the near or long term? Also, how is the current global policy environment impacting dispute resolution?
  • Focusing on BEPS 2.0, specifically Pillars One and Two and potential controversy, what discussions are you having with clients?
  • What are your key takeaways for listeners?


David Ernick

Principal, Transfer Pricing, PwC United States


Michael Shaw

Director, PwC United Kingdom

+44 (0)7483 448 414


Stephan Rasch

Partner, Tax, PwC Germany


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