EY Transfer Pricing Roundup

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