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EY Transfer Pricing Roundup: Daily Summaries Delivered
by 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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- 2 weeks ago10 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.
- Sep 23, 202613 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
- Sep 12, 20267 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.
- Aug 17, 202616 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
- Jul 16, 202645 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.
- Jul 15, 202611 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.
- Jun 9, 202613 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.
- May 1, 202611 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
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About 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.
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