Episode 51: New German Transfer Pricing Administrative Principles

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. 

Transfer Pricing in the UK 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 just this week, 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 statistics. Join EY host and EY US Financial Services Transfer Pricing Leader, Jonathan Thompson, returning guest David Baxendale and EY UK Transfer Pricing Director Matthew Bacon, who has recently joined us from HMRC’s APA team as they discuss these statistics.  #EY #EYTPRU #UK #TPStatistics

In 2023, the global landscape saw a remarkable surge in the request for Advance Pricing Agreements (APAs), with over 1,100 submissions, alongside more than 2,300 Mutual Agreement Procedures (MAPs). This trend underscores the sustained interest and engagement with various competent authority programs worldwide. Join us for an insightful discussion hosted by Jonathan Thompson, EY's US Financial Services Transfer Pricing Leader, and Luis Coronado, EY’s Global Tax Controversy Leader. Together, we will delve into the key insights from the Organisation for Economic Co-operation and Development's (OECD's) Tax Certainty Day. We will cover the latest statistics on MAPs and APAs, the recipients of the MAP and APA awards, and explore the future trajectory of the tax certainty agenda. Whether you are currently utilizing the APA/MAP program or contemplating its benefits, this episode promises to be highly informative and valuable. Don't miss out! #EY #EYTPRU #OECD #APA #MAP

In December 2024, the German Ministry of Finance published the updated administrative principles on transfer pricing. The guidance largely focuses on intercompany financial transactions along with guidance on Amount B.   Given the recent and ongoing changes to the interest rate environment around the world, intercompany financing remains a key topic of interest. This update from Germany only makes transfer pricing for intercompany financial transactions more relevant. On today's episode of the EY Transfer Pricing Roundup, EY host and Financial Services Transfer Pricing leader Jonathan Thompson is joined by EY Germany Partner Andreas Persch to discuss these changes.  #EYTPRU #Germany

2024 was a year of change in transfer pricing in Brazil. The mandatory adoption of OECD-style transfer pricing has led to many questions. Today's episode of the EY Transfer Pricing Roundup includes a discussion between EY Brazil Partner Caio Albino and EY host and Financial Services Transfer Pricing leader Jonathan Thompson to provide an update on the latest developments and the key items to be aware of as in Brazil for 2025 and beyond. #EYTPRU #Brazil #TransferPricing #OECD