Episode 102: Stock-based compensation: One size does not fit all

February 06, 2024


In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC’s US Workforce Transformation practice), and Matt Haag (Principal in PwC’s US Transfer Pricing practice) discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations when analyzing whether to put a recharge agreement in place. They finish with a discussion of the interplay between recharge agreements and Pillar Two and final takeaways.

Contacts: Kristina NovakJennifer George and Matt Haag

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Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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