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The Transfer Pricing Show

The Transfer Pricing Show

Written by: Josh Post
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International tax and transfer pricing explained from the ground up. I’m Josh Post, a Transfer Pricing Principal at Ryan, passionate about automating and modernizing TP with AI. Each episode tackles the basic questions you were too embarrassed to ask, drawn from my current learning and research. I use NotebookLM/AI to help organize sources and prompts—AI can make mistakes, so please verify. No client/confidential info. Views are mine, not Ryan’s. Educational only—not tax/legal advice.Josh Post Economics
Episodes
  • PCbCR: Congratulations, You're Transparent Now!
    May 13 2026

    For years, your country-by-country data sat in a government database that nobody read. That's over. The EU and Australia now require the same jurisdiction-level revenues, profits, and tax figures to be published on the open internet — in machine-readable formats explicitly designed for automated analysis. In this episode, we break down what's actually required, who's caught by thresholds they didn't see coming, why hub entity selection in Europe can make or break your compliance strategy, and what it means that a journalist can now write one script and fish for headlines across every multinational's filing simultaneously. The data is what it is. The question is whether you see your own story before someone else tells it for you.


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    32 mins
  • The International Emergency Economic Podcast — SCOTUS Strips White House of Its Favorite Trade Weapon
    Feb 20 2026

    The Supreme Court ruled 6-3 that IEEPA does not authorize presidential tariffs. Roberts held that "regulate … importation" doesn't include the power to tax — a power the Constitution reserves to Congress. The ruling invalidates the reciprocal and drug-trafficking tariffs but leaves Section 232/301 duties intact. Refund exposure may top $175B. The administration vows to reimpose tariffs under other statutes, but those tools are narrower, capped, and require formal investigations IEEPA never demanded.


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    18 mins
  • 15.5% and Chill: India Finally Makes the Safe Harbor Worth Taking
    Feb 19 2026

    India just collapsed four safe harbor categories into one, cut the margin to 15.5%, and raised the threshold to ₹2,000 crore — which means the annual benchmarking fight that has defined Indian TP compliance for two decades might actually be over for most IT services captives. But "streamlined" is not "free," and the price of certainty includes a margin above arm's length, secondary adjustment obligations, and surrendering your right to MAP. This article explains what changed, what it costs, what still applies, and why India decided now was the moment to stop auditing its way to an answer everyone already knew.


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    17 mins
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