Uncontrolled Opinions
Episodes
Inetrco Financing and Swaps
09 Dec 2025
Contributed by Lukas
In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing.Part...
Highlights from NABE 2025 TP Symposium
29 Oct 2025
Contributed by Lukas
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2025 Transfer Pricing Conference. Mik...
Why We Do This
27 May 2025
Contributed by Lukas
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...
Economic Substance and TP
08 Apr 2025
Contributed by Lukas
In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economi...
Amount B / SSA Refresher
26 Mar 2025
Contributed by Lukas
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...
Transfer Pricing for Intragroup Loans
14 Mar 2025
Contributed by Lukas
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing pr...
Apple ECJ State Aid Case TP implications
13 Jan 2025
Contributed by Lukas
In this episode, Mikhail and Silvana dive into the 2024 European Court of Justice (ECJ) decision on Apple’s contested tax arrangements in Ireland. W...
Country Risk Premium Adjustment in TNMM
19 Nov 2024
Contributed by Lukas
In this episode of Uncontrolled Opinions, Mikhail and Silvana discuss the country risk premium adjustment when applying a Transactional Net Margin Met...
Public vs Private Companies in CPM/TNMM Analyses
07 Nov 2024
Contributed by Lukas
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 analys...
TNMM & Local Country Rules
08 Oct 2024
Contributed by Lukas
In this episode, Silvana and Mikhail explore how local country-specific rules impact the use of the Transactional Net Margin Method (TNMM) in transfer...
AI in Transfer Pricing
16 Sep 2024
Contributed by Lukas
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 conversa...
Highlights from the NABE TP Symposium 2024
26 Aug 2024
Contributed by Lukas
In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana recap some of the highlights from the NABE 2024 Transfer Pricing Conference. M...
What is Control?
23 Jul 2024
Contributed by Lukas
What is “Control”? Nope we are not talking about Janet Jackson’s song. The raison d’etre in TP is pricing of “Controlled Transactions”...
Arms' Length Range
15 Jul 2024
Contributed by Lukas
Arm's Length Range:Â In this episode, Mikhail and Silvana dive into the intricacies of the arm's length range, the interquartile range, and various st...
The Evolution and Impact of Amount B
25 Apr 2024
Contributed by Lukas
In this Podcast, Silvana and Mikhail discuss the developments surrounding OECD Amount B guidance as it stands in March 2024. We explore the scope an...