Episode 63: Transfer Pricing and Pillar Two – Strategic Considerations for MNEs

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.  

As global trade tensions and protectionist policies drive the resurgence of tariffs, multinational enterprises face increasing complexity in aligning their transfer pricing strategies. 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, Ana Maria Romero from our EY New York office and EY Partner, Lynlee Brown from EY’s Global trade team to discuss the challenges of maintaining arm’s length pricing while managing customs duties, the potential for double taxation, and the importance of aligning transfer pricing documentation with customs declarations. 

Join EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson, as he delves into the intriguing and often contentious areas of intercompany funding and Advance Pricing Agreements #APAs. In this episode, Jonathan is joined by EY Netherlands Transfer Pricing Partner, Krzysztof Łukosz, and EY Netherlands Tax Manager, Bhavna Daryanani. Together, they explore the latest developments in intercompany financing and share insights from their recent experiences with APAs, shedding light on the complexities and nuances of transfer pricing in today's dynamic landscape.

As Fei-Fei Li said "Artificial intelligence is not a threat, but a tool. It’s up to us to use it wisely, to amplify our humanity, not replace it." While so much discussion these days is dedicated to #AI, what does it actually mean when it comes to transfer pricing? Do you know your agentic versus industrial applications, what’s a good use case for AI in a transfer pricing function, where have we seen AI successfully deployed? To get to the bottom of these questions, EY host and EY Financial Transfer Pricing Services Leader, Jonathan Thompson spoke with Rebecca Coke and Michael de Haan from EY’s Transfer Pricing technology team to understand more.  

While all businesses respond to the impact of Artificial Intelligence #AI, the Life Sciences sector faces enormous challenges and opportunities. With these changes come the need for a flexible, efficient and effective transfer pricing system to reflect tomorrow’s supply chain. Join EY host and EY Financial Services Transfer Pricing Leader, Jonathan Thompson and guests Maaike Muit and Nick Wolley as they discuss EY’s recent White Paper on the shifting value drivers and what it all means.   Find the related white paper here: https://fp-resources.fiercepharma.com/free/w_defa8090/   

In its 26th Annual Advance Pricing Agreement (#APA) report, the Internal Revenue Service (#IRS) and the Advance Pricing and Mutual Agreement (#APMA) program have recently unveiled impressive APA statistics, continuing their trend of success in completing APAs, albeit with a slight reduction in completion time. APAs remain a highly favored dispute resolution mechanism for both transfer pricing and other international tax matters. Join EY host and EY Financials Services Transfer Pricing leader, Jonathan Thompson and EY TP Roundup podcast regular and EY Americas International Tax and Transaction Services Tax Controversy Leader, Ryan Kelly as we delve into the latest statistics and insights.

US/India Advance Pricing Agreements #APAs continue to be one of the biggest success stories of APA programs globally with record numbers of APAs being signed between the two countries. Join us for a special episode of the EY Transfer Pricing Roundup podcast, where EY host Jonathan Thompson interviews co-host Ameet Kapoor. Ameet gives us the latest on the APA statistics and the results of some of the recent rounds of discussion. 

While we continue to think about Pillar Two, let’s not forget Pillar One. Specifically, Amount B, where things are still moving forward.  Join EY host Jonathan Thompson for a fun #EYTPRU episode where he discusses the latest on Amount B with EY Managing Director, Bill Morgan, who recently joined EY from the US Department of Treasury, Office of Tax Analysis where he served as the Lead US Economist and EY Senior Manager Joana Dermendjieva.

Australia has long been known for having a complex transfer pricing compliance regime. However, earlier this year the Australian Taxation Office #ATO introduced significant changes to the Short Form Local File (#SFLF) that applies from January 1st, 2025 for reporting periods starting on or after January 1st, 2024.  Join EY host and EY US Financial Services Transfer Pricing Leader, Jonathan Thompson, as he discusses these changes and some other recent developments with Kelly Richmond, a Director based in EY’s Sydney office.