Episode 122: The great services debate: pricing, people, and profit allocation
March 27, 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 Ian Dykes, PwC’s Global Transfer Pricing Leader. Kristina and John discuss with Ian how the OECD’s broader work on Chapter VII in global mobility may reshape the transfer pricing landscape in the context of intercompany services, including potential shifts beyond cost-plus and the implications for pricing and characterization. They then explore how these developments intersect with global mobility, particularly the risks associated with mobile decision-makers and profit allocation. The conversation also turns to Pillar One uncertainty and the continued relevance of digital services taxes, before concluding with recent UK transfer pricing developments.
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