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Transfer Pricing
OECD
Advanced Pricing Agreements
Artificial Intelligence
IRS
Amount B
BEPS
Pillar 1
Brazil
HMRC Guidance For Compliance For Transfer Pricing
Netherlands
Inter-Company Effectiveness
Advance Pricing Agreements
Economic Substance Doctrine
Singapore
Financial Transactions
Life Sciences
Operational Transfer Pricing
Amount A
UK Transfer Pricing Environment

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.

PublishesMonthlyEpisodes73Founded3 years ago
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Artwork for EY Transfer Pricing Roundup

Latest Episodes

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 D... more

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 subs... more

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... more

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 Divis... more

Key Facts

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Recent Guests

Sandra Knaepen
EY, Global Transfer Pricing Controversy Leader
EY
Episode: Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
Gustavo Carmona
EY International Tax Leader for Brazil
EY
Episode: Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
Harili Tsutsuyoka
EY Financial Services Transfer Pricing Leader
EY
Episode: Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
Milton Gonzalo Malla
EY Transfer Pricing Leader for Brazil
EY
Episode: Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
Nadia Sabin
Transfer pricing partner and economist
EY France, Paris
Episode: Episode 71: Tax Controversy in France: Insights for Multinational Businesses
Jean-Pierre Lieb
Tax controversy specialist
EY Paris
Episode: Episode 71: Tax Controversy in France: Insights for Multinational Businesses
Manuel de los Santos
Head of division Transfer Pricing Tax Treaties and International Agreements
OECD
Episode: Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD
Matt Bacon
Director in UK Transfer Pricing Team, formerly HMRC
EY
Episode: Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends
Adam Henderson
Partner in Singaporean Transfer Pricing Teams
EY
Episode: Episode 68: IRAS Transfer Pricing Update – Version 8.0

Host

Jonathan Thompson
Host of the Transfer Pricing Roundup

Reviews

4.8 out of 5 stars from 40 ratings
  • Always Informative

    The TP Roundup is always a good listen.

    Apple Podcasts
    5
    ca_keto
    United States2 years ago

Listeners Say

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Interesting depth on OECD and global mobility topics.
Practical takeaways for tax teams and documentation.
Consistently insightful with clear implications for TP strategy.

Chart Rankings

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Apple Podcasts
#236
India/Business

Talking Points

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Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing
Q: What was the court holding in Perrigo v. United States?
The court largely sided with Perrigo, finding real business purpose and activity, rejecting the economic substance challenge, affirming ex ante valuation with a discounted cash flow framework, rejecting hindsight, and throwing out penalties while recognizing Perrigo's good faith reliance on advisors.
Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing
Q: What did the IRS assert for the basis of their adjustments here?
The IRS argued the 2006 assignment lacked economic substance and should be disregarded, and, alternatively, that even if respected, the pricing was not arm's length under Section 42, relying on hindsight to claim the original pricing was too low.
Episode 71: Tax Controversy in France: Insights for Multinational Businesses
Q: Why is controversy important at the beginning of a transfer pricing process?
Early controversy involvement strengthens the robustness of the pricing model by stress-testing it against how tax authorities may interpret a structure, ensuring that the narrative and documentation hold up under scrutiny across multiple jurisdictions.
Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD
Q: Could you walk us through the main areas of focus in the consultation paper and what practitioners should be thinking about?
The central points are the benefit test, the new documentation guidance, and the need to ensure documentation is proportional to the service and materiality, avoiding unnecessary granularity while providing clarity for both tax authorities and businesses.
Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends
Q: What should multinational groups be doing now to stay ahead of potential changes in TP regulation in the UK?
Enhance data collection, prepare for increased reporting requirements (ICTS, CBCR, Local/Master Files), and develop proactive TP risk management and documentation strategies in anticipation of broader APAs and automated data processing.

Audience Metrics

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Frequently Asked Questions About EY Transfer Pricing Roundup

What is EY Transfer Pricing Roundup about and what kind of topics does it cover?

A concise, news-driven series focused on transfer pricing developments around the world. Episodes routinely feature EY TP professionals discussing policy shifts, enforcement trends, and regional updates—from OECD guidance and Pillar Two to country-specific reforms and documentation rules. The show stands out for its practical, business-facing take on complex TP topics, timely commentary, and real-world implications for multinationals. Listeners are likely TP practitioners, tax and finance professionals, and in-house teams seeking clear, actionable updates in a compact format.

Across recent episodes, expect discussions that balance principled theory with pragmatic implementation, coverage of global regulatory changes, and insights into how ... more

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Which podcasts are similar to EY Transfer Pricing Roundup?

These podcasts share a similar audience with EY Transfer Pricing Roundup:

1. TP Talks - PwC's Global Transfer Pricing podcast
2. Cross-border Tax Talks
3. EY Cross-Border Taxation Alerts
4. PwC's accounting podcast
5. Brussels Playbook Podcast

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EY Transfer Pricing Roundup launched 3 years ago and published 73 episodes to date. You can find more information about this podcast including rankings, audience demographics and engagement in our podcast database.

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What guests have appeared on EY Transfer Pricing Roundup?

Recent guests on EY Transfer Pricing Roundup include:

1. Sandra Knaepen
2. Gustavo Carmona
3. Harili Tsutsuyoka
4. Milton Gonzalo Malla
5. Nadia Sabin
6. Jean-Pierre Lieb
7. Manuel de los Santos
8. Matt Bacon

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