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EY Transfer Pricing Roundup

EY - International Tax and Transaction Services

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.

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S1 · E74
October 26 · 10 min
Episode 74: Brazil's New Transfer Pricing Landscape: Implementation and Documentation Part II
Episode 74 continues the four-part EY Transfer Pricing Roundup series focused on Brazil's evolving transfer pricing landscape. In this second episode, recorded in São Paulo, host Jonathan Thompson is joined again by Daniel Biagioni, Milton Gonzalez Malla, Charikleia Tsoukia, Sandra Knaepen and Gustavo Carmona to take a deeper look at the practical implications of Brazil's OECD-aligned transfer pricing framework. The panel explores what the new rules mean in practice for multinational groups operating in Brazil, bringing together perspectives from Brazil and around the globe. They also discuss practical considerations and insights for companies as they continue to navigate the significant changes to Brazil's transfer pricing regime. Part 2 of 4.
S1 · E73
September 23 · 13 min
Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
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 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
S1 · E72
September 12 · 7 min
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.
S1 · E71
August 17 · 16 min
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 controversies, and respond to a rapidly changing international tax landscape. Listen to the episode to learn more about the latest developments and what they may mean for multinational businesses operating globally. #TaxControversy #InternationalTax #TransferPricing #TaxPolicy #GlobalTax #EYTPRU
S1 · E70
July 16 · 45 min
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 policy objectives behind the consultation ✅Areas where existing services guidance may be creating challenges ✅The interaction between services, value creation and transfer pricing outcomes ✅The OECD's work on global mobility ✅Other area's on the OECD's agenda This was a fascinating discussion that brought together both the OECD's perspective and practical experience from working with multinational groups around the world. Whether you are involved in transfer pricing, tax policy, controversy, or international tax governance, this episode provides valuable insights into one of the most important OECD initiatives currently under consideration.
S1 · E69
July 15 · 11 min
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.
June 9 · 13 min
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 authorities may be expected Singapore remains a critical hub in many global operating models, and this eighth version of the IRAS guidelines is a clear signal of continued refinement, and heightened expectations for transfer pricing compliance.
S1 · E67
May 1 · 11 min
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 should be prioritizing now in terms of governance, systems, and controversy risk #EYTPRU #TPCompliance #Brazil #TransferPricing
S1 · E66
February 9 · 29 min
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 stay ahead of the curve. 👉 Tune in to understand the impact, the opportunities, and the road ahead.
S1 · E65
February 2 · 11 min
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 📌 What taxpayers should be prioritizing now to manage risk proactively
S1 · E64
January 26 · 13 min
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 organizations can do today to anticipate regulator expectations tomorrow
S1 · E63
Oct 14, 2025 · 12 min
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 ☑️What you should be thinking about going into year end This discussion offers timely insights into how TP and Pillar Two intersect—and what that means for your global tax posture.
S1 · E62
Sep 9, 2025 · 26 min
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 regulatory expectations, and adapt to the evolving dynamics of tax authorities.
S1 · E61
Aug 1, 2025 · 12 min
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.
S1 · E60
Jul 21, 2025 · 14 min
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.
S1 · E59
Jun 30, 2025 · 23 min
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 Michael de Haan from EY's Transfer Pricing technology team to understand more.
S1 · E58
Jun 23, 2025 · 18 min
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/
S1 · E57
Jun 16, 2025 · 11 min
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 the latest statistics and insights.
S1 · E56
Jun 9, 2025 · 12 min
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.
S1 · E55
May 20, 2025 · 19 min
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.

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