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Financial Services Transfer Pricing Decoded – A global Tax podcast series

Financial Services (FS) Transfer Pricing (TP) Decoded is a new podcast series exploring global Transfer Pricing issues relevant to the Financial Services industry. Listen to specialists from across the Deloitte network discuss issues ranging from how we work to how to tackle cost allocations for Transfer Pricing purposes, as well specific Banking, Insurance and Investment Management Transfer Pricing insights. With each episode less than 30 minutes, it’s an easy way to learn about some of the key Transfer Pricing matters that could impact your business.

This episode focuses on the real estate sector as we hear from the speakers regarding their experience of some of the transfer pricing issues that arise within that sector.

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Following on from Episode 9, Part 1 on general transfer pricing considerations relevant to financial transactions , Part 2 of this series covers specific transfer pricing considerations relevant to the banking sector, including interactions with a bank’s Funds Transfer Pricing mechanism.

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Episode 9 (Part 1) sets the scene by discussing some important transfer pricing considerations relevant to financial transactions within multinational groups in the context of the final OECD Guidance on Financial Transactions released in 2020.

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Cost allocations are a challenge for many multinationals, creating issues which extend far beyond tax and transfer pricing. In this podcast the speakers discuss these challenges covering controversy, governance and operational implementation.

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This episode, recorded in Summer 2021, discusses factors in the asset management sector which have had an impact on operating models (including regulation, market environment and technology) and the associated transfer pricing considerations.

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The world is changing and so are the banks – what are the implications? This episode of the series focusses on emerging trends in the banking sector and some potential implications on transfer pricing models. In this episode Rasmus, Willy, Pris and Francesco discuss emerging trends in the banking sector across Europe and AsiaPac. Listen in to hear latest trends from Deloitte UK’s risk advisory team and how this translates into transfer pricing considerations.


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Technology in the insurance industry could be in a variety of forms including apps, telematics, digital distribution models and automated underwriting and claims underwriting systems. The fifth episode of the series discusses how transfer pricing models may change as a result of the shift towards the use of technology across the value chain and how data could be treated from a transfer pricing perspective.


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The fourth episode of the series explores common transfer pricing (TP) challenges faced by providers and recipients of intercompany services, transfer pricing controversy related to India and lastly charging for the use of financial services brands and some of the challenges seen which have been raised by tax authorities of both the licensee and licensor.

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The third episode of the series explores the use of technology within Financial Services organisations where this is a key value driver in the business model. This episode also goes into some of the possible key transfer pricing considerations commonly associated with technology-related intangibles.


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The second episode of the series focusses on post-Brexit transfer pricing considerations in the Financial Services sector. Speakers discuss post-Brexit Transfer Pricing (TP) models and their thoughts on recent EU regulatory developments and what these could mean from a transfer pricing perspective.

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The first episode of the series discusses a topic which many organisations are increasingly having to assess and manage from a tax perspective – staff working from outside of their country of employment. So when can such movement of staff create a permanent establishment (PE) for corporate tax purposes and what are some of the key personal tax consequences to think about?

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