The Transfer Pricing Method
The Transfer Pricing Method
Podcast Description
Welcome to the Quantera Global transfer pricing method podcast! Your go-to source for the latest insights and updates on transfer pricing. Hosted by Adriaan van der Heijden, Director at Quantera Global, this podcast delves into all different topics regarding transfer pricing, offering expert advice and practical solutions for upcoming changes and challenges in the field. Join us every month to explore transfer pricing one episode at a time.
Podcast Insights
Content Themes
The podcast focuses on key topics related to transfer pricing, including OECD guidelines, country-by-country reporting, and advanced pricing agreements (APAs). For instance, one episode discusses Brazil's adoption of OECD guidelines and the implications for multinationals, while another explores the intricacies of public country-by-country reporting through the perspectives of Dutch and Romanian experts.
Welcome to the Quantera Global transfer pricing method podcast! Your go-to source for the latest insights and updates on transfer pricing. Hosted by Adriaan van der Heijden, Director at Quantera Global, this podcast delves into all different topics regarding transfer pricing, offering expert advice and practical solutions for upcoming changes and challenges in the field. Join us every month to explore transfer pricing one episode at a time.
Transfer pricing controversy is rarely won on theory alone. In practice, outcomes are shaped by preparation, evidence, and the ability to explain a consistent story under pressure.
In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by:
- Katrine Ernest Haunstrup, Country Leader at Censio Tax
- Emile Monfils, Partner at Quantera Global
Together, they break down what really drives transfer pricing audits today, what “audit-ready” documentation looks like in practice, and how to manage the first steps of an audit without creating unnecessary risk.
You will learn:
- Why TP audits start today, and what tax authorities look at first
- How to move from “we have documentation” to “we are in control”
- What makes documentation truly audit-ready
- Why data and evidence often become the decisive factor
- How to respond when the tax authority has a point
- How to think about audit strategy early, including escalation and double taxation considerations
Prefer reading? The blog summarising this episode is available here.
Timestamps
00:00 Introduction & Guest Backgrounds
01:17 Why TP audits start today (data visibility and inconsistencies)
03:55 Typical audit triggers (financial outcomes and documentation risk signals)
04:55 Prevention and the shift from “tell me” to “show me”
06:50 Audit readiness starts before documentation (policies, processes, controls)
09:35 Audit-ready TP documentation: approach and structure
12:41 What makes transfer pricing documentation audit-ready?
17:49 Evidence and data: can you actually prove your position?
20:10 Practical tips for audit readiness (what to do in practice)
23:30 What to do when the tax authority has a point
27:45 Summary & Closing Remarks
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