EY Transfer Pricing Roundup

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

In a special guest episode of the #EY Transfer Pricing Roundup, EY US host Jonathan Thompson, EY US Partner Donna McComber and EY UK Partner Astrid Vroom are joined by the Senior Advisor of Transfer Pricing at Large Business and International (#LB&I) at the Internal Revenue Service (IRS), Karen Kirwan in a comprehensive exploration of the International Compliance Assurance Program (#ICAP). ICAP, a collaborative initiative between multiple tax authorities, aims to enhance tax compliance and certainty in the international tax arena. Our panel unpack the intricacies of ICAP, discussing its framework, benefits and challenges and discuss the IRS's initial experience of the program.

The latest #EY Transfer Pricing Roundup #podcast episode dives into the recent Italian legislative updates and looks at the connection between the Investment Management Exemption (#IME) and transfer pricing. Drawing on experience from the UK's IME, join EY US host and Financial Services Transfer Pricing Principal, Jonathan Thompson, EY London Financial Services Tax Partner, Debbie Knowles and EY Italy Financial Services Transfer Pricing Partner, Antonfortunato Corneli as they discuss the recent updates and the #alignment between the #Italian tax #regulations and transfer pricing.

Dive into the intricacies of transfer pricing regulations in China with our latest episode of the #EY Transfer Pricing Roundup podcast series. From understanding the latest updates in Chinese tax laws to unraveling the complexities of intercompany transactions, our episode provides invaluable insights for multinational businesses operating in China. Join EY host and US Transfer Pricing Principal, Jonathan Thompson and EY China Transfer Pricing Partner, Kena Qu as they discuss compliance strategies, and decode the nuances of transfer pricing to help you stay ahead in the ever-evolving regulatory landscape of #china.

In November 2023, following the Organisation for Economic Co-operation and Development's (#OECD) unveiling of the Mutual Agreement Procedure (#MAP) statistics in 2022 and the earlier publication of the Manual on handling MAPs and #APA cases, the most recent installment of the EY Transfer Pricing Roundup delves into the MAP process and explores the concept of multilateral MAP. Hosted by EY's US Tax Principal Jonathan Thompson and joined by EY London Transfer Pricing Partner Andy Martyn, this episode illuminates some key considerations and strategies for taxpayers.

🗞 Access the OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm

🗞 Access the manual here: https://www.oecd-ilibrary.org/docserver/f0cad7f3-en.pdf?expires=1707858430&id=id&accname=guest&checksum=E1B9B1EE600C59C075061324F7902F82

In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Mexico Transfer Pricing Partner, Enrique Gonzalez Cruz. In this episode, Enrique sheds light on the transfer pricing audit landscape in Mexico and what taxpayers can expect and should be prepared for. Also discussed is the current Advance Pricing Agreement (APA) environment in Mexico and the process taxpayers can expect when filing APAs with Mexico.

Statistics from Organisation for Economic Co-operation and Development (OECD) on Mutual Agreement Procedures (MAP) for 2022 show that increase in global tax disputes and a more accessible MAP process resulting in more taxpayers seeking relief. The 2022 statistics demonstrate that MAP remains an effective way to eliminate double taxation and taxation not in accordance with a treaty. The 2022 data covers almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (i.e., non-transfer pricing cases) for 2022 on the:

• Opening and ending inventory of MAP cases
• Number of new MAP cases started, completed, closed or withdrawn
• Average cycle time for MAP cases completed, closed or withdrawn

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with EY US Transfer Pricing Partner and Transfer Pricing Controversy Leader, Ryan Kelly, about the 2022 statistics and what taxpayers should be thinking about.

Access the 2022 OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm

Access and download the EY Tax Alert here: https://globaltaxnews.ey.com/news/2023-1960-oecds-2022-mutual-agreement-procedure-statistics-show-us-decreasing-map-case-inventories-increasing-time-to-close#:~:text=MAP%20statistics%20for%20all%20countries,and%202019%20(%2B3.5%25).

In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Australia Transfer Pricing Partner, Tony Cooper. In this episode, Tony shares #insights on the latest transfer pricing #audits, Advance Pricing Agreements (#APAs) and Mutual Agreement Procedures (#MAPs) in #Australia. Tony also discusses the latest Australian Tax Office's (#ATOs) Top 1,000 income tax and goods and services tax (#GST) assurance program report. The report provides large businesses with an opportunity to gain greater certainty about their tax outcomes and the effectiveness of their tax governance frameworks. It also provides an objective mechanism for large businesses to understand how their tax profile compares to others in the market and their peers.

Access the Findings report for the Top 1,000 income tax and GST assurance programs here: https://www.legacy.ato.gov.au/Business/Large-business/In-detail/Findings-report---Top-1,000-income-tax-and-GST-assurance-programs/

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with Sandra Gurijala and John Hill about the intricacies of Implicit Support in Transfer Pricing. The discussion focuses on a newly released Generic Legal Advice Memorandum (#GLAM) from the Office of Chief Counsel of the #IRS, shedding light on the implications of group membership on financial transactions under IRS Section 482. The conversation further explores the long-debated issue of implicit support and its impact on intercompany #loans and #guarantees. Don't miss this insightful episode.

Access the latest EY Tax Alert on the GLAM here: https://taxnews.ey.com/news/2024-0132-generic-legal-advice-memorandum-says-irs-can-consider-implicit-support-to-price-intercompany-loans

Access the GLAM released by the IRS in December here: https://www.irs.gov/pub/lanoa/am-2023-008.pdf