EY Transfer Pricing Roundup

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

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.

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  

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

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.

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.  

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. 

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.

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.  

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/   

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.

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. 

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.

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. 

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 joined us from HMRC's APA team as they discuss these statistics.  #EY #EYTPRU #UK #TPStatistics

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 of the MAP and APA awards, and explore the future trajectory of the tax certainty agenda. Whether you are currently utilizing the APA/MAP program or contemplating its benefits, this episode promises to be highly informative and valuable. Don't miss out! #EY #EYTPRU #OECD #APA #MAP

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.  #EYTPRU #Germany

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 

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.   #EYTPRU #TransferPricing

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.  

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

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 what it means and what you should really be thinking about. Listen to Part III now. 

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 what it means and what you should really be thinking about. Listen to Part II now. 

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 what it means and what you should really be thinking about. Listen to Part I now. 

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) Please reach out to Tarunya, David and your regular EY UK Transfer Pricing contact to discuss this development. #EY #tax #transferpricing #Allin #HMRC #OECD

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.

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. 

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.  

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 and gain a deeper understanding APMA's current focus and initiatives. Don't miss out on this exciting episode – tune in to gain valuable perspectives that could impact your approach to transfer pricing.

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 developments, and explore the considerations that #MNEs should be mindful of moving forward. 

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

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 valuable insights to help you navigate the complexities of EOI with the IRS.  Access the recently published article in Tax Notes: Exchange of Information in the New Era of Multilateral Transfer Pricing Enforcement. 

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 international tax policy, the EY Transfer Pricing Roundup is designed to keep you informed and ahead of the curve. #PillarOne #AmountB #OECD #TransferPricing #Tax #EYTPRU

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 Procedures #MAPs, essential tools for managing tax disputes in Japan.

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 #APMA #TPControversy #EYTPRU #Disputeresolution Access the 2023 IRS APA Statutory report here: https://www.irs.gov/pub/irs-drop/a-24-16.pdf

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). ICAP, a collaborative initiative between multiple tax authorities, aims to enhance tax compliance and certainty in the international tax arena. Our panel unpack the intricacies of ICAP, discussing its framework, benefits and challenges and discuss the IRS's initial experience of the program.  

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 EY Italy Financial Services Transfer Pricing Partner, Antonfortunato Corneli as they discuss the recent updates and the #alignment between the #Italian tax #regulations and transfer pricing.

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, Jonathan Thompson and EY China Transfer Pricing Partner, Kena Qu as they discuss compliance strategies, and decode the nuances of transfer pricing to help you stay ahead in the ever-evolving regulatory landscape of #china.

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 Tax Principal Jonathan Thompson and joined by EY London Transfer Pricing Partner Andy Martyn, this episode illuminates some key considerations and strategies for taxpayers. 🗞 Access the OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm 🗞 Access the manual here: https://www.oecd-ilibrary.org/docserver/f0cad7f3-en.pdf?expires=1707858430&id=id&accname=guest&checksum=E1B9B1EE600C59C075061324F7902F82

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) environment in Mexico and the process taxpayers can expect when filing APAs with Mexico.

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 covers almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (i.e., non-transfer pricing cases) for 2022 on the: Opening and ending inventory of MAP cases Number of new MAP cases started, completed, closed or withdrawn Average cycle time for MAP cases completed, closed or withdrawn In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with EY US Transfer Pricing Partner and Transfer Pricing Controversy Leader, Ryan Kelly, about the 2022 statistics and what taxpayers should be thinking about. Access the 2022 OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm Access and download the EY Tax Alert here: https://globaltaxnews.ey.com/news/2023-1960-oecds-2022-mutual-agreement-procedure-statistics-show-us-decreasing-map-case-inventories-increasing-time-to-close#:~:text=MAP%20statistics%20for%20all%20countries,and%202019%20(%2B3.5%25).

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 Australian Tax Office's (#ATOs) Top 1,000 income tax and goods and services tax (#GST) assurance program report. The report provides large businesses with an opportunity to gain greater certainty about their tax outcomes and the effectiveness of their tax governance frameworks. It also provides an objective mechanism for large businesses to understand how their tax profile compares to others in the market and their peers. Access the Findings report for the Top 1,000 income tax and GST assurance programs here: https://www.legacy.ato.gov.au/Business/Large-business/In-detail/Findings-report---Top-1,000-income-tax-and-GST-assurance-programs/

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 membership on financial transactions under IRS Section 482. The conversation further explores the long-debated issue of implicit support and its impact on intercompany #loans and #guarantees. Don't miss this insightful episode. Access the latest EY Tax Alert on the GLAM here: https://taxnews.ey.com/news/2024-0132-generic-legal-advice-memorandum-says-irs-can-consider-implicit-support-to-price-intercompany-loans Access the GLAM released by the IRS in December here: https://www.irs.gov/pub/lanoa/am-2023-008.pdf

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 Entertainment Sector Champion, Melody Leung regarding one of the most complex areas of transfer pricing, Intellectual Property and Intellectual Property Alignment. 

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 Entertainment Sector Champion, Melody Leung regarding one of the most complex areas of transfer pricing, Intellectual Property and Intellectual Property Alignment. 

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 Entertainment Sector Champion, Melody Leung regarding one of the most complex areas of transfer pricing, Intellectual Property and Intellectual Property Alignment. 

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.

EY US Partner Ameet Kapoor discusses recent transfer pricing audit trends in the United Kingdom [UK] with EY UK Partner, Ivan Gutierrez.