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EY Transfer Pricing Roundup

EY Transfer Pricing Roundup

EY - International Tax and Transaction Services 68 Episodes Sep 23, 2026

The EY Transfer Pricing Roundup is a short, transfer pricing news-based podcast. It provides listeners with brief and informative updates covering major legislative changes and controversy trends around the world. The series features interviews with global transfer pricing professionals who explain developments in a fun and informative manner.

Episodes

Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation
Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation Sep 23, 2026 13:20 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 Daniel Biagioni, Milton Gonzalez Malla, Charikleia Tsoukia, Sandra Knaepen and Gustavo Carmona to discuss Brazil's OECD-aligned transfer pricing frame
Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing
Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing Sep 12, 2026 07:10 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 substance and Section 482 arguments, and why the court emphasized ex ante pricing using contemporaneous projections, not actual results. The episode also
Episode 71: Tax Controversy in France: Insights for Multinational Businesses
Episode 71: Tax Controversy in France: Insights for Multinational Businesses Aug 17, 2026 16:37 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 Lieb for a discussion on tax controversy in France and the increasing challenges multinational businesses face in today's complex global tax environm
Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD
Episode 70: Understanding the OECD Consultation on Intra-Group Services: Insights and more from the OECD Jul 16, 2026 45:28 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 Division, and Ronald van den Brekel, EY Global TP Market and Innovation Leader, to discuss the OECD's consultation on transfer pricing aspects of intra-gro
Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends
Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends Jul 15, 2026 11:53 UK transfer pricing continues to evolve at a rapid pace. Recently we have seen the release of the Guidelines for Compliance, the outcomes of a number of transfer pricing cases and, a transfer pricing consultation on documentation and an international controlled transactions schedule. In the middle of all of this, HMRC also released its annual diverted profits tax and Advance Pricing Agreement (APA
Episode 68: IRAS Transfer Pricing Update – Version 8.0
Episode 68: IRAS Transfer Pricing Update – Version 8.0 Jun 9, 2026 13:35 The most recent version of the Singapore Transfer Pricing Guidelines, version 8, was published late last year. EY Host and Financial Services Transfer Pricing Leader, Jonathan Thompson recently sat down with EY Singapore Transfer Pricing Partner, Adam Henderson, to unpack the latest transfer pricing guidelines. In this episode, they explore: ✅ Key changes in the updated IRAS guidance ✅ Practical i
Episode 67: Brazil Transfer Pricing Update: Insights from the first year of Arm's Length Transfer Pricing
Episode 67: Brazil Transfer Pricing Update: Insights from the first year of Arm's Length Transfer Pricing May 1, 2026 11:49 Brazil fundamentally re‑engineered its transfer pricing framework, moving away from its long‑standing formulaic approach and aligning with the #OECD arm's length principle. In this episode, EY host and EY Financial Services Transfer Pricing Leader, Jonathan Thompson and Daniel Biagioni, a Transfer Pricing Partner from EY Brazil discuss what this change really meant in practice for multinationals o
Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms
Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms Feb 9, 2026 29:12 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 Tr
Episode 65: A transfer pricing postcard from Australia
Episode 65: A transfer pricing postcard from Australia Feb 2, 2026 11:35 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
Episode 64: Transfer Pricing Compliance x Technology – where are we at and where are we going?
Episode 64: Transfer Pricing Compliance x Technology – where are we at and where are we going? Jan 26, 2026 13:54 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 usa
Episode 63: Transfer Pricing and Pillar Two – Strategic Considerations for MNEs
Episode 63: Transfer Pricing and Pillar Two – Strategic Considerations for MNEs Oct 14, 2025 12:46 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 un
Episode 62: An Advance Pricing Agreement Special
Episode 62: An Advance Pricing Agreement Special Sep 9, 2025 26:34 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 Transfe

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