business
Hosted by Silvana and Mikhail · business · EN
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.
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Contact path
Public web form
Booking probability
17%
Guest openness
Selective
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Signup to Generate a PitchAll 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.
Uncontrolled Opinions is hosted by Silvana and Mikhail. The show has published 15 episodes to date.
Recent episodes include "Interco Financing and Swaps" (9 December 2025, 41 minutes), "Highlights from NABE 2025 TP Symposium" (29 October 2025, 44 minutes), and "Highlights from NABE 2025 TP Symposium" (29 October 2025, 44 minutes).
Uncontrolled Opinions publishes roughly monthly, with episodes averaging 34 minutes across 15 episodes.
Booking probability for Uncontrolled Opinions is 17%, and the host is rated Selective on guests. Uncontrolled Opinions requires a Pod Score of 80 or higher. Uncontrolled Opinions's contact route on record: public web form.
The strongest fits for Uncontrolled Opinions are Accounting, Tax & Payroll and Business & Management Consulting. Uncontrolled Opinions has a business audience.
Silvana and Mikhail hosts Uncontrolled Opinions, a business podcast with 15 episodes published.
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Episode #15
<p>In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing.</p><p>Part 1 — Intercompany Financing: Foundations, Challenges &...
Episode #14
<p>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...
Episode #14
<p>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...
Episode #13
<p>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...
Episode #12
<p>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. </p><p>We dive into...
Episode #11
<p><br>In this episode, we refresh on Amount B / Simplified and Streamline Approach (SSA). We cover what has happened since February 2024.</p><p>For a deeper dive, explore the resources below, including guidance, fact...
Episode #10
<p>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...
Episode #9
<p>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...
Episode #8
<p>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...
<p>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...
Episode #6
<p>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...
Episode #5
<p>Is there a role for AI in transfer pricing?</p><p>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...
<p>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...
Episode #3
<p>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? </p><p> </p><p>In this episode of Uncontrolled Opinions...
Episode #2
<p>Arm's Length Range: </p><p>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...
Episode #1
<p>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...
Recent guests on Uncontrolled Opinions. Study who booked and why before you pitch.
Quantera Global
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