Episode 128: Transfer pricing, transparency, and what comes next
October 13, 2026
Kristina Novak and John Cianfrone sit down with former PwC principal David Ernick to reflect on the evolution of transfer pricing. David discusses his career at the US Treasury Department and PwC, including his experience representing the United States at the OECD’s Working Party No. 6, the impact of BEPS 1.0, and the rise of public country-by-country reporting (CbCR). They also examine the limitations and compliance challenges of public CbCR, potential transfer pricing pressures from AI-driven profits, and what may lie ahead for the field.
Contact us
Kristina Novak
Washington National Tax Services, Transfer Pricing, Principal, PwC US
Tel: +1 (469) 878-4552
John Cianfrone
Washington National Tax Services, Transfer Pricing, Director, PwC US
Tel: +1 (646) 951-7680