EY Transfer Pricing Roundup

In September 2024, #HMRC published a series of guidelines to clarify and help #taxpayers understand HMRC's expectations when it comes to #transferpricing #compliance .   Join EY Host and Financial Services Transfer Pricing Partner  Jonathan Thompson , EY Transfer Pricing Partner Tarunya Kumar (She/Her) and EY Transfer Pricing Senior Manager David Baxendale for brief insights on managing compliance...

Since being introduced in 2016, multinational groups have been preparing Country-by-Country Reporting [ #CBCR ] as part of their annual tax compliance processes. However, groups with operations in Australia and Europe will soon have to contend with some of that information being made public.  Join EY Host and Financial Services Transfer Pricing Partner  Jonathan Thompson , EY Financial Services Tr...

In October 2023, the Internal Revenue Service ( #IRS ) announced ( IR-2023-194 ) that it planned to send transfer pricing  #compliance letters to approximately 150 US-based subsidiaries (see Tax Alert  2023-1907 ) . The IRS updated this number to 180 in January 2024. In this episode, EY host and Financial Services Transfer Pricing Partner,  Jonathan Thompson is joined by EY's Americas National Tra...

While Singapore is ranked as one of the most business-friendly locations in the world (source worldbank.org), it's also one of the most active locations when it comes to updating its Transfer Pricing Guidelines ( #TPGuidelines ). Recently the Inland Revenue Authority ( #IRA ) of Singapore released the Seventh Edition of its TP Guidelines. Join EY host and Partner Jonathan Thompson and EY Partner R...

Get ready for an engaging turn of events in the latest episode of the #EY Transfer Pricing Roundup podcast! We're thrilled to invite you to a special Q&A session featuring EY Partners Donna McComber and Ameet Kapoor as they delve into the latest developments at the Internal Revenue Service's Advance Pricing and Mutual Agreement Program ( #IRS #APMA ). Join Donna and Ameet as they interview APMA Di...

As we continue to discuss the adoption of  #PillarTwo , it's important not to forget Pillar One. In this episode of the #EY Transfer Pricing Roundup, EY host and Transfer Pricing Partner, Jonathan Thompson is joined once again by Ronald van den Brekel as they catch up on #AmountB of Pillar One, its current status and likely next steps. 

In this episode of the #EY Transfer Pricing Roundup, we refocus on Pillar 1's Amount A. Despite Pillar 2's prominence in the news, Pillar 1 has resurfaced as a topic of interest, with the United States Secretary of the Treasury, Janet Yellen, acknowledging its steady advancement. EY Partners  Jonathan Thompson and Ronald van den Brekel provide an update on the current progress, outline forthcoming...

In this episode of the EY Transfer Pricing Roundup, join EY host and Transfer Pricing Partner  Jonathan Thompson and EY Switzerland Partner, Francisco Palacios as they discuss the Swiss transfer pricing landscape. Topics covered include a brief overview of swiss transfer pricing law, updates on recent detailed transfer pricing guidance from Swiss tax authorities, practical strategies for businesse...

In this episode of the EY Transfer Pricing Roundup, EY Transfer Pricing Partner and host, Ameet Kapoor along with EY Transfer Pricing Partners, Donna McComber and Kent P. Stackhouse break down the different types of ways taxpayer information is shared with the Internal Revenue Service (IRS). These Exchanges of Information ( #EOI ) include Automatic, Spontaneous, and On-Request exchanges. This epis...

While Pillar Two continues to make the headlines, let's not forget Pillar One, which is steadily evolving. Join EY host and Transfer Pricing Partner,  Jonathan Thompson for a quick recap and update with EY Transfer Pricing Partner and Global Transfer Pricing Market and Innovation Leader, Ronald van den Brekel on recent developments related to Amount B. In this episode, our EY Partners provide you...

Join EY host and US Transfer Pricing Partner, Ameet Kapoor in a deep dive into Japan's dynamic tax environment with EY Japan Transfer Pricing Partner Karl Gruendel . Discover the latest trends in #transferpricing and #Controversy , including the evolving review practices by tax authorities and the integration of #AI . Gain valuable insights on Advance Pricing Agreements #APAs and Mutual Agreement...

In the latest episode of the EY Transfer Pricing Roundup, EY host and US Transfer Pricing Partner, Ameet Kapoor discusses the highlights from the recent #IRS Annual Advance Pricing Agreement ( #APA ) Statutory Report with EY US Transfer Pricing Partner, Donna McComber . With a record breaking number of APAs executed in 2023, its an episode that you don't want to miss! #Statistics #Controversy #APM...

In a special guest episode of the #EY Transfer Pricing Roundup, EY US host Jonathan Thompson , EY US Partner Donna McComber and EY UK Partner Astrid Vroom are joined by the Senior Advisor of Transfer Pricing at Large Business and International ( #LB &I) at the Internal Revenue Service (IRS), Karen Kirwan in a comprehensive exploration of the International Compliance Assurance Program ( #ICAP ). IC...

The latest #EY Transfer Pricing Roundup #podcast episode dives into the recent Italian legislative updates and looks at the connection between the Investment Management Exemption ( #IME ) and transfer pricing. Drawing on experience from the UK's IME, join EY US host and Financial Services Transfer Pricing Principal, Jonathan Thompson , EY London Financial Services Tax Partner, Debbie Knowles and E...

Dive into the intricacies of transfer pricing regulations in China with our latest episode of the #EY Transfer Pricing Roundup podcast series. From understanding the latest updates in Chinese tax laws to unraveling the complexities of intercompany transactions, our episode provides invaluable insights for multinational businesses operating in China. Join EY host and US Transfer Pricing Principal,...

In November 2023, following the Organisation for Economic Co-operation and Development's ( #OECD ) unveiling of the Mutual Agreement Procedure ( #MAP ) statistics in 2022 and the earlier publication of the Manual on handling MAPs and #APA cases, the most recent installment of the EY Transfer Pricing Roundup delves into the MAP process and explores the concept of multilateral MAP. Hosted by EY's US...

In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Mexico Transfer Pricing Partner, Enrique Gonzalez Cruz. In this episode, Enrique sheds light on the transfer pricing audit landscape in Mexico and what taxpayers can expect and should be prepared for. Also discussed is the current Advance Pricing Agreement (APA)...

Statistics from Organisation for Economic Co-operation and Development (OECD) on Mutual Agreement Procedures (MAP) for 2022 show that increase in global tax disputes and a more accessible MAP process resulting in more taxpayers seeking relief. The 2022 statistics demonstrate that MAP remains an effective way to eliminate double taxation and taxation not in accordance with a treaty. The 2022 data c...

In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Australia Transfer Pricing Partner, Tony Cooper. In this episode, Tony shares #insights on the latest transfer pricing #audits , Advance Pricing Agreements ( #APAs ) and Mutual Agreement Procedures ( #MAPs ) in #Australia. Tony also discusses the latest Australi...

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with  Sandra Gurijala and John Hill about the intricacies of Implicit Support in Transfer Pricing. The discussion focuses on a newly released Generic Legal Advice Memorandum ( #GLAM ) from the Office of Chief Counsel of the #IRS , shedding light on the implications of group m...

Join EY US Financial Services Transfer Pricing Leader and host Jonathan Thompson and Rebecca Coke , EY US Central Region Transfer Pricing Leader; Americas Transfer Pricing Transformation Leader; Global Transfer Pricing Account Leader, as they explore the evolving interplay between transfer pricing and #technology in the latest installment of the EY Transfer Pricing Roundup #podcast series. 

In this three part series, EY US Partner and host Jonathan Thompson engages in an in depth discussion with three EY US Transfer Pricing professionals; EY US Partner and Tax Technology Sector Lead of Digital Tax, Channing Flynn, EY US Principal and Global Intellectual Property Center of Excellence Leader, Stephen Bates and EY US Principal and Americas Operating Model Effectiveness Media and Enterta...

In this three part series, EY US Partner and host Jonathan Thompson engages in an in depth discussion with three EY US Transfer Pricing professionals; EY US Partner and Tax Technology Sector Lead of Digital Tax, Channing Flynn, EY US Principal and Global Intellectual Property Center of Excellence Leader, Stephen Bates and EY US Principal and Americas Operating Model Effectiveness Media and Enterta...

In this three part series, EY US Partner and host Jonathan Thompson engages in an in depth discussion with three EY US Transfer Pricing professionals; EY US Partner and Tax Technology Sector Lead of Digital Tax, Channing Flynn, EY US Principal and Global Intellectual Property Center of Excellence Leader, Stephen Bates and EY US Principal and Americas Operating Model Effectiveness Media and Enterta...

In this episode of the EY Transfer Pricing Roundup, EY US Principal Jonathan Thompson discusses recent transfer pricing developments in the Life Sciences and Medtech Industry with EY Senior Manager Samuel Brill.