EY Transfer Pricing Roundup

Episode 73 marks the start of a four-part EY Transfer Pricing Roundup series focused on Brazil's evolving transfer pricing landscape. In this special edition of EY Transfer Pricing Roundup, recorded in São Paulo, host Jonathan Thompson is joined by Daniel Biagioni, Milton Gonzalez Malla, Charikleia Tsoukia, Sandra Knaepen and Gustavo Carmona to discuss Brazil's OECD-aligned transfer pricing framew...

In this episode of EY Transfer Pricing Roundup, host Ryan J. Kelly is joined by Kent Stackhouse to unpack Perrigo Company v. United States (W.D. Mich.). They discuss the 2006 contract reassignment at the center of the dispute, the IRS's economic substance and Section 482 arguments, and why the court emphasized ex ante pricing using contemporaneous projections, not actual results. The episode also...

In the latest episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader Jonathan Thompson is joined by EY France Transfer Pricing Leader, Nadia Sabin and EY EMEIA Tax Policy and Controversy Leader, Jean-Pierre Lieb for a discussion on tax controversy in France and the increasing challenges multinational businesses face in today's complex global tax environm...

In this episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson is joined by Manuel de los Santos Poveda , Head of the OECD Transfer Pricing, Tax Treaties and International Agreements Division, and Ronald van den Brekel , EY Global TP Market and Innovation Leader, to discuss the OECD's consultation on transfer pricing aspects of intra-g...

UK transfer pricing continues to evolve at a rapid pace. Recently we have seen the release of the Guidelines for Compliance, the outcomes of a number of transfer pricing cases and, a transfer pricing consultation on documentation and an international controlled transactions schedule. In the middle of all of this, HMRC also released its annual diverted profits tax and Advance Pricing Agreement (APA...

The most recent version of the Singapore Transfer Pricing Guidelines, version 8, was published late last year. EY Host and Financial Services Transfer Pricing Leader,  Jonathan Thompson recently sat down with EY Singapore Transfer Pricing Partner, Adam Henderson , to unpack the latest transfer pricing guidelines. In this episode, they explore: ✅ Key changes in the updated IRAS guidance ✅ Practic...

Brazil fundamentally re‑engineered its transfer pricing framework, moving away from its long‑standing formulaic approach and aligning with the #OECD arm's length principle. In this episode, EY host and EY Financial Services Transfer Pricing Leader, Jonathan Thompson and Daniel Biagioni , a Transfer Pricing Partner from EY Brazil discuss what this change really meant in practice for multinationals...

Canada is entering a new era of transfer pricing regulation. With the federal government introducing sweeping amendments through the 2025 budget and Bill C‑15, businesses now face a far more substance‑driven, #OECD‑aligned framework. In the latest EY Transfer Pricing Roundup podcast episode, EY host and Financial Services Transfer Pricing leader Jonathan Thompson sits down with Marlon Alfred , a T...

In the latest episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing leader, Jonathan Thompson and guest Sandra Farhat , a Transfer Pricing and Controversy Partner with EY Sydney, take a deep dive into recent developments in Australian transfer pricing legislation and what they mean for multinational groups operating in—or dealing with—Australia. With heightene...

As many multinational groups begin to think about 2025 transfer pricing compliance, join EY host and Financial Services Transfer Pricing leader, Jonathan Thompson and guest Divya Nair , a Managing Director in EY's Global Center of Excellence, as they discuss the increasingly complex transfer pricing compliance landscape, the relationship between robust transfer pricing documentation, technology us...

As jurisdictions begin implementing the OECD's Pillar Two framework, the interaction between transfer pricing policies and GloBE rules is becoming increasingly complex—and consequential. In this episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader,  Jonathan Thompson is joined by EY International Tax and Transaction Services Partner, Eddie Holland to u...

Advance Pricing Agreements (APAs) are more than just a compliance tool—they're a strategic asset.  In this episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader,  Jonathan Thompson is joined by EY Transfer Pricing Partner, Noel de Santos , a recent addition to EY from the Advance Pricing and Mutual Agreement (APMA) team, and Arnaud Sage , EY France Tran...

As global trade tensions and protectionist policies drive the resurgence of tariffs, multinational enterprises face increasing complexity in aligning their transfer pricing strategies. In this episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing Leader,  Jonathan Thompson is joined by EY Transfer Pricing Partner, Ana Maria Romero from our EY New York office a...

Join EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson , as he delves into the intriguing and often contentious areas of intercompany funding and Advance Pricing Agreements #APAs . In this episode, Jonathan is joined by EY Netherlands Transfer Pricing Partner, Krzysztof Łukosz , and EY Netherlands Tax Manager, Bhavna Daryanani . Together, they explore the latest development...

As Fei-Fei Li said "Artificial intelligence is not a threat, but a tool. It's up to us to use it wisely, to amplify our humanity, not replace it." While so much discussion these days is dedicated to #AI , what does it actually mean when it comes to transfer pricing? Do you know your agentic versus industrial applications, what's a good use case for AI in a transfer pricing function, where have we...

While all businesses respond to the impact of Artificial Intelligence #AI , the Life Sciences sector faces enormous challenges and opportunities. With these changes come the need for a flexible, efficient and effective transfer pricing system to reflect tomorrow's supply chain. Join EY host and EY Financial Services Transfer Pricing Leader, Jonathan Thompson and guests Maaike Muit and Nick Wolley...

In its 26th Annual Advance Pricing Agreement ( #APA ) report, the Internal Revenue Service ( #IRS ) and the Advance Pricing and Mutual Agreement ( #APMA ) program have recently unveiled impressive APA statistics, continuing their trend of success in completing APAs, albeit with a slight reduction in completion time. APAs remain a highly favored dispute resolution mechanism for both transfer pricin...

US/India Advance Pricing Agreements #APAs continue to be one of the biggest success stories of APA programs globally with record numbers of APAs being signed between the two countries. Join us for a special episode of the EY Transfer Pricing Roundup podcast, where EY host Jonathan Thompson interviews co-host Ameet Kapoor . Ameet gives us the latest on the APA statistics and the results of some of...

While we continue to think about Pillar Two, let's not forget Pillar One. Specifically, Amount B, where things are still moving forward.  Join EY host  Jonathan Thompson for a fun #EYTPRU episode where he discusses the latest on Amount B with EY Managing Director, Bill Morgan , who recently joined EY from the US Department of Treasury, Office of Tax Analysis where he served as the Lead US Economis...

Australia has long been known for having a complex transfer pricing compliance regime. However, earlier this year the Australian Taxation Office #ATO introduced significant changes to the Short Form Local File ( #SFLF ) that applies from January 1st, 2025 for reporting periods starting on or after January 1st, 2024.  Join EY host and EY US Financial Services Transfer Pricing Leader,  Jonathan Thom...

Transfer Pricing in the UK continues to evolve at a rapid pace. Recently we have seen the release of the Guidelines for Compliance, the outcomes of a number of transfer pricing cases, and just this week, a transfer pricing consultation on documentation and an international controlled transactions schedule.  In the middle of all of this, HMRC also released its annual diverted profits tax and advanc...

In 2023, the global landscape saw a remarkable surge in the request for Advance Pricing Agreements (APAs), with over 1,100 submissions, alongside more than 2,300 Mutual Agreement Procedures (MAPs). This trend underscores the sustained interest and engagement with various competent authority programs worldwide. Join us for an insightful discussion hosted by  Jonathan Thompson , EY's US Financial Se...

In December 2024, the German Ministry of Finance published the updated administrative principles on transfer pricing. The guidance largely focuses on intercompany financial transactions along with guidance on Amount B.   Given the recent and ongoing changes to the interest rate environment around the world, intercompany financing remains a key topic of interest. This update from Germany only makes...

2024 was a year of change in transfer pricing in Brazil. The mandatory adoption of OECD-style transfer pricing has led to many questions. Today's episode of the EY Transfer Pricing Roundup includes a discussion between EY Brazil Partner Caio Albino and EY host and Financial Services Transfer Pricing leader Jonathan Thompson to provide an update on the latest developments and the key items to be aw...

In today's episode, EY Financial Services Transfer Pricing leader and host Jonathan Thompson dives into a key topic in the world of transfer pricing: the Economic Substance #doctrine . This doctrine is a fundamental principle that has been part of U.S. tax law for over 85 years. However, it recently attracted attention when a Senior Internal Revenue Service ( #IRS ) official confirmed that the IRS...