EY Transfer Pricing Roundup

• 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 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

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• 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.  #EYTPRU #Germany

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• 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 

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• 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.   #EYTPRU #TransferPricing

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• 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.  

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