EY Transfer Pricing Roundup
The EY Transfer Pricing Roundup is a short, transfer pricing news-based podcast. We aim to provide listeners with brief and informative updates covering major legislative changes and controversy trends occurring around the world. In this series we will interview our global transfer pricing professionals to flag and explain global developments in a fun and informative manner.
Episodes
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 unpack the transfer pricing implicati...
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 Transfer Pricing Partner and former France...
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 and EY Partner, Lynlee Brown from EY'...
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 l...
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 func...
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 M...
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 w...
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 ...
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 th...
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.
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 advance pricing agreement Read more
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 Services Transfer Pricing Leader, and L...
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 transfer pricing for intercompany ...
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 aware of as in Brazil for 2025 and be...
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 ( Read more
In today's episode, EY Financial Services Transfer Pricing leader and host Jonathan Thompson unpacks the Internal Revenue Service (#IRS) Priority Guidance Plan. This plan, released annually by the U.S. Department of the Treasury and the IRS, outlines the key tax issues that will be addressed through regulations, revenue rulings, procedures, notices, and other forms of publishe...
As the Kingdom of Saudi Arabia continues to diversify its economy and attract foreign investment, understanding the nuances of transfer pricing has never been more important. Join EY Financial Services Transfer Pricing leader and host Jonathan Thompson and EY Partner Wael Tfaily, CFA as they explore the regulatory landscape, discuss the challenges multinational companies face, and provide insights into best practices for compliance...
Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation: There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It's fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interested in this area of M...
Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation. There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It's fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interes...
Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation. There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It's fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interes...
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