Hosted by Silvana and Mikhail · 🇺🇸 US · EN · 15 episodes
Established thought leaders with verified media credentials.
All things transfer pricing. Uncontrolled Opinions is an open-ended exploration of all things transfer pricing. Silvana and Mikhail, share their views and insights from a practical transfer pricing economists lens.
Silvana and Mikhail hosts Uncontrolled Opinions, a business show with 15 episodes published.
In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing. Part 1 — Intercompany Financing: Foundations, Challenges & Evolving Pract
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2025 Transfer Pricing Conference. Mikhail and Silvana explore several of the most interesting panels, includi
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2025 Transfer Pricing Conference. Mikhail and Silvana explore several of the most interesting panels, includi
For episode 13, we're getting personal! We're digging into why we started this podcast and the unplanned beginnings of our careers in transfer pricing. Get our "uncontrolled opinion" on why the TP world needs more open d
In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economic substance in the context of transfer pricing. We dive into the economi
In this episode, we refresh on Amount B / Simplified and Streamline Approach (SSA). We cover what has happened since February 2024. For a deeper dive, explore the resources below, including guidance, fact sheets, tools,
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing practitioner with deep expertise in intercompany (IC) financial transact
In this episode, Mikhail and Silvana dive into the 2024 European Court of Justice (ECJ) decision on Apple’s contested tax arrangements in Ireland. While the heart of the matter centers on “illegal state aid,” the convers
In this episode of Uncontrolled Opinions, Mikhail and Silvana discuss the country risk premium adjustment when applying a Transactional Net Margin Method (TNMM). This discussion is particularly timely, given the recent e
In this episode of Uncontrolled Opinions, we explore the pros and cons of using public and private company data in the context of a TNMM or CPM analysis in transfer pricing. We discuss practical aspects such as data avai
In this episode, Silvana and Mikhail explore how local country-specific rules impact the use of the Transactional Net Margin Method (TNMM) in transfer pricing. They discuss how different regulations affect the selection
Is there a role for AI in transfer pricing? We believe the simple answer to this question is – yes – but with a few qualifiers. In this conversation, we dive into what is AI, Generative AI and how next-word prediction ca
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2024 Transfer Pricing Conference. Mikhail and Silvana explore several of the most interesting panels, includi
What is “Control”? Nope we are not talking about Janet Jackson’s song. The raison d’etre in TP is pricing of “Controlled Transactions”. So, what is control? In this episode of Uncontrolled Opinions, hosts Silvana and Mik
Arm's Length Range: In this episode, Mikhail and Silvana dive into the intricacies of the arm's length range, the interquartile range, and various statistical methods used in transfer pricing. They discuss the importance
In this Podcast, Silvana and Mikhail discuss the developments surrounding OECD Amount B guidance as it stands in March 2024. We explore the scope and criteria of Amount B, emphasizing its focus on tangible goods and excl
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Uncontrolled Opinions is hosted by Silvana and Mikhail. The show is categorised under business and has published 15 episodes.
Uncontrolled Opinions has published 15 episodes.
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