David Ernick

Principal with PwC's Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department

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Nov 15, 2023 • 42min

Pillar Two Safe Harbors: The CbCR journey

Doug McHoney and David Ernick discuss the transitional safe harbor rules for Country-by-country reporting (CbCR) in this podcast. They cover topics such as the safe harbor tests, exclusions, and differences between safe harbor and full GLoBE rules. They also discuss the history and implementation of public CBCR, challenges of transfer pricing adjustments, and the importance of Advance Pricing Agreements (APAs).