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.
Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
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 framework.
The panel explores early implementation lessons, the importance of aligning transfer pricing policies, agreements and business practices, and the interaction between transfer pricing and Brazil's broader tax regime. They also discuss documentation considerations and Brazil's tax audit and dispute environment.
Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing
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 highlights key practical takeaways on documentation, assumptions, and reliance on advisors, with a note that the decision was appealed in late March 2026.
Episode 71: Tax Controversy in France: Insights for Multinational Businesses
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 environment.
The conversation explores evolving transfer pricing dispute trends, heightened enforcement activity, and key considerations for managing tax risk across jurisdictions. The speakers share practical insights on how organizations can navigate scrutiny from tax authorities, prepare for...
Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD
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-group services.
Together, they explore the background to the consultation, the key issues the OECD is seeking to address, and the potential implications for multinational enterprises across industries.
The discussion covers:
✅ The po...
Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends
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) statistics. Join EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson as he discusses these statistics with Matthew Bacon, who has recently joined EY from HMRC's APA team.
Episode 68: IRAS Transfer Pricing Update – Version 8.0
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
✅ Practical implications for multinational groups operating in or through Singapore
✅ How taxpayers should approach documentation, substance, and risk allocation in light of the revisions
✅ Common areas where increased scrutiny from the authoriti...
Episode 67: Brazil Transfer Pricing Update: Insights from the first year of Arm's Length Transfer Pricing
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 operating in or with Brazil.
🎙️ Key topics include:
✅ What changed under Brazil's new transfer pricing rules
✅ Lessons from the first year of documentation
✅ Practical challenges businesses are already facing in implementation
✅ What tax leaders...
Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms
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 Transfer Pricing Partner from EY Canada, to break down what these changes mean in practice. Marlon shares insights on how taxpayers should approach delineation, documentation, and risk assessment under the new regime—and what multinationals should be doing now to st...
Episode 65: A transfer pricing postcard from Australia
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 heightened ATO scrutiny and continued legislative evolution, transfer pricing is always a hot topic. The conversation explores:
📌 Key legislative and administrative developments shaping Australia's transfer pricing framework
📌 Practical implications for documentation, governance, and disputes
📌 Wh...
Episode 64: Transfer Pricing Compliance x Technology – where are we at and where are we going?
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 usage, and end‑to‑end compliance. This episode unpacks:
📌 How evolving global standards are reshaping transfer pricing documentation requirements
📌 Practical challenges companies face when aligning their documentation
📌 The growing role of technology and data in creating defensible, efficient compliance processes
📌 What...
Episode 63: Transfer Pricing and Pillar Two – Strategic Considerations for MNEs
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 implications of Pillar Two, including:
☑️ The current status of Pillar 2 implementation
☑️Where TP and Pillar 2 interact
☑️How TP impacts transitional safe harbor calculations
☑️How to address non arm's length transactions and
Episode 62: An Advance Pricing Agreement Special
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 Competent Authority. Together, they delve into the intricate landscape of bilateral APAs between the United States and France. The discussion focuses on how multinational corporations navigate complex negotiations, meet...
Episode 61: Navigating Transfer Pricing in a Tariff-focused World: Strategic Implications and Compliance Challenges
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's Global trade team to discuss the challenges of maintaining arm's length pricing while managing customs duties, the potential for double taxation, and the importance of aligning transfer pricing documentation with customs declarations.
Episode 60: Dutch Financial Transaction Transfer Pricing update
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 developments in intercompany financing and share insights from their recent experiences with APAs, shedding light on the complexities and nuances of transfer pricing in today's dynamic landscape.
Episode 59: An introduction to Artificial Intelligence for transfer pricing
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 seen AI successfully deployed? To get to the bottom of these questions, EY host and EY Financial Transfer Pricing Services Leader, Jonathan Thompson spoke with Rebecca Coke and...
Episode 58: The impact of Artificial Intelligence on Life Sciences Transfer Pricing
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 as they discuss EY's recent White Paper on the shifting value drivers and what it all means.
Find the related white paper here: https://fp-resources.fiercepharma.com/free/w_defa8090/
Episode 57: US Advance Pricing Agreement statistic update
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 pricing and other international tax matters. Join EY host and EY Financials Services Transfer Pricing leader, Jonathan Thompson and EY TP Roundup podcast regular and EY Americas International Tax and Transaction Services Tax Controversy Leader, Ryan Kelly as we delve into...
Episode 56: Recap on recent US / India Advance Pricing Agreements
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 the recent rounds of discussion.
Episode 55: What's going on with Amount B?
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 Economist and EY Senior Manager Joana Dermendjieva.
Episode 54: An Australia Transfer Pricing Update
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 Thompson, as he discusses these changes and some other recent developments with Kelly Richmond, a Director based in EY's Sydney office.
Episode 53: Navigating UK Transfer Pricing Updates
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 #APA statistics. Join EY host and EY US Financial Services Transfer Pricing Leader, Jonathan Thompson, returning guest David Baxendale and EY UK Transfer Pricing Director Matthew Bacon, who has recently joi...
Episode 52: The continued rise of Advance Pricing Agreements and Mutual Agreement Procedures
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 Luis Coronado, EY's Global Tax Controversy Leader. Together, we will delve into the key insights from the Organisation for Economic Co-operation and Development's (OECD's) Tax Certainty Day. We will cover the latest statistics on MAPs and APAs, the recipients o...
Episode 51: New German Transfer Pricing Administrative Principles
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 financial transactions more relevant. On today's episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing leader Jonathan Thompson is joined by EY Germany Partner Andreas Persch to discuss these changes.
#E...
Episode 50: Brazil Transfer Pricing update
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 beyond.
#EYTPRU #Brazil #TransferPricing #OECD
Episode 49: An introduction to the Economic Substance Doctrine
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 can apply the economic substance doctrine to transfer pricing cases.
Jonathan is joined by EY Principal, Kent P. Stackhouse to discuss what this means for transfer pricing and what taxpayers should be considering.
#EYTP...
Episode 48: Decoding the IRS Priority Guidance Plan: What You Need to Know!
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 published guidance over the next year.
Jonathan is joined by EY's National Transfer Pricing Controversy Leader, Ryan Kelly for his take on the latest priority guidance for transfer pricing, what it means and what #MNEs should be thinking about for 2025.
Episode 47: Transfer Pricing updates in Saudi Arabia
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 in Saudi Arabia. Please take a listen as we unravel the complexities of transfer pricing in one of the world's most dynamic economies.
#TransferPricing #SaudiArabia #EYTPRU
Episode 46: Intercompany Effectiveness Mini-Series: Part III
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 Multinational Enterprise (MNE) groups' organizations.
It was therefore a pleasure to sit down with EY's Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out w...
Episode 45: Intercompany Effectiveness Mini-Series: Part II
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 Multinational Enterprise (MNE) groups' organizations.
It was therefore a pleasure to sit down with EY's Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out w...
Episode 44: Intercompany Effectiveness Mini-Series: Part I
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 Multinational Enterprise (MNE) groups' organizations.
It was therefore a pleasure to sit down with EY's Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out w...
Episode 43: Help with common risks in transfer pricing approaches
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 risks for businesses in the UK; common compliance risks; and specific risks in designing transfer pricing policies.
See the EY Tax Alert here: UK releases new Guidelines for Compliance | 'Help with common risks in transfer pricing approaches' (ey.com)
Pl...
Episode 42: A public CBCR announcement
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 Transfer Pricing Senior Manager Alice Lin and EY Financial Services Transfer Pricing Manager Phoebe Billings for an update on the current Public CBCR [#PCbCR] landscape, the potential implications of these changes and some areas to be thinking about.
Episode 41: Update on IRS transfer pricing compliance letters
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 Transfer Pricing Leader, Ryan Kelly, to discuss the latest status of the IRS initiative, the responses we have seen to the letters and the likely next steps.
Episode 40: Singapore Transfer Pricing update
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 Rajesh Bheemanee as they discuss the latest Singapore TP developments and the impact these changes will have on transfer pricing.
Episode 39: Q&A session with IRS APMA Director, John Wall, Episode 1
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 Director John Wall to discuss the most recent updates and insights that are shaping the future of transfer pricing. This is a unique opportunity to hear directly from subject matter professionals...
Episode 38: Pillar One: Is it still standing?
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.
Episode 37: Amount A: A need to Know
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 developments, and explore the considerations that #MNEs should be mindful of moving forward.
Episode 35: Understanding EOI: Navigating Information Exchanges with the IRS
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 businesses to ensure compliance and insights into how these changes align with global transfer pricing trends.
If you have any questions or would like to speak with Jonathan or Francisco, find them on LinkedIn here: Jonathan Thompson / Francisco Palacios
Episode 35: Understanding EOI: Navigating Information Exchanges with the IRS
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 episode explores how these mechanisms work, their implications for taxpayers and tax authorities, and the global impact on tax compliance and enforcement. Whether you're a tax practitioner, a business owner, or simply curious about tax policy, this podcast offers...
Episode 34: Pillar One Focus: Amount B Updates
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 with the latest insights, analyze real-world implications, and provide practical advice for navigating the complex terrain of Amount B. Whether you're a tax professional, a multinational corporation, or simply interested in the evolving world of in...
