Ep. 124: Lessons from global transfer pricing negotiations
June 03, 2026
Kristina Novak, a Principal in PwC’s Washington National Tax Services Transfer Pricing practice, and John Cianfrone, a Director in PwC’s Washington National Tax Services Transfer Pricing practice, are joined by Mona Cairncross, a Principal at PwC and former Assistant Director of the IRS Advance Pricing and Mutual Agreement Program. They discuss Mona's experience at the IRS overseeing hundreds of APA and MAP cases involving treaty partners, key trends from the 2025 APA annual report, negotiation dynamics across jurisdictions, recurring challenges in bilateral APAs, the importance of collaboration and relationship-building, and why consistency between transfer pricing policies, facts, and financial outcomes remains critical for achieving successful dispute resolution and certainty.
Contact us
Kristina Novak
Washington National Tax Services, Transfer Pricing, Principal, PwC US
Tel: +1 (469) 878-4552
John Cianfrone
Washington National Tax Services, Transfer Pricing, Director, PwC US
Tel: +1 (646) 951-7680