EY Transfer Pricing Roundup

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.