Learning Objectives

• Explain why transfer pricing directly affects global tax risk and cash outcomes.
• Compare IRS and OECD transfer pricing frameworks and their core structural differences.
• Identify key compliance challenges under dual IRS and OECD transfer pricing systems.
• Analyze how OECD Pillar Two interacts with existing transfer pricing strategies.
• Evaluate practical steps firms can take to prepare for upcoming global tax changes.

Is transfer pricing just a technical tax exercise, or a strategic lever that can move millions across borders? In a world where global businesses operate under two competing standards, the IRS on one side and the OECD on the other, transfer pricing has become a high-stake balancing act. This Episode digs into why transfer pricing matters now more than ever, how historical policy choices created today’s split frameworks, and what happens when companies misjudge the line between compliance and strategy. From audit exposure to real cash tax outcomes, the discussion grounds abstract rules in practical consequences firms face every day.

Carl Budenski, Tax Partner and Transfer Pricing Leader at Aprio, brings a practitioner’s lens to this complex terrain. Drawing from decades of advising multinational and mid-market companies, he explains how U.S. and Organisation for Economic Co-operation and Development (OECD) transfer pricing regimes evolved along different philosophical paths, and why that divergence creates friction for modern businesses. Carl also unpacks how companies document, defend, and sometimes rethink their pricing models when operating across jurisdictions, especially as new global tax initiatives approach.