Corporate Finance Explained | Transfer Pricing and the Battle Over Global Profits

Corporate Finance Explained | Transfer Pricing and the Battle Over Global Profits

May 7, 2026 · 25 min · Episode 226

About this episode

This episode explains transfer pricing and its impact on global tax policy and corporate finance.

Transfer pricing is one of the most important concepts in corporate finance, international tax, and multinational business strategy. In this episode of Corporate Finance Explained, we break down how multinational corporations allocate profits across countries, how profit shifting works, and why transfer pricing disputes involving Apple, Coca-Cola, Amazon, Microsoft, and Starbucks have reshaped global tax policy. You’ll learn how transfer pricing works, how the arm’s length principle is applied, and why OECD BEPS rules, Country-by-Country Reporting, and Pillar Two are changing the future of international taxation and corporate finance. This episode explores: • What transfer pricing is and why multinational corporations use it • The arm’s length principle explained • OECD transfer pricing methods and profit allocation • How Apple structured profits through Ireland • Why Coca-Cola, Amazon, Microsoft, and Starbucks faced tax disputes • OECD BEPS and Country-by-Country Reporting rules • Pillar Two and the global minimum corporate tax • Why economic substance now matters more than tax arbitrage • How transfer pricing impacts valuation, treasury, FP&A, and corporate strategy If you…

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