Episode 41: Update on IRS transfer pricing compliance letters

Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation: There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It’s fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interested in this area of Multinational Enterprise (MNE) groups’ organizations.  It was therefore a pleasure to sit down with EY’s Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out what it means and what you should really be thinking about. Listen to Part III now. 

Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation. There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It’s fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interested in this area of Multinational Enterprise (MNE) groups’ organizations.  It was therefore a pleasure to sit down with EY’s Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out what it means and what you should really be thinking about. Listen to Part II now. 

Intercompany Effectiveness, Operational Transfer Pricing (TP), TP implementation. There are lots of terms used to describe all the TP activities beyond planning and documentation. However, what exactly are people referring to? It’s fair to say that robust booking, monitoring, controls and governance of TP is increasingly important with tax authorities, stakeholders and prudential regulators increasingly interested in this area of Multinational Enterprise (MNE) groups’ organizations.  It was therefore a pleasure to sit down with EY’s Intercompany Effectiveness #ICE leaders, Tim Gunning and Matt Gengler as part of our latest EY TP Roundup Mini Series to find out what it means and what you should really be thinking about. Listen to Part I now. 

In September 2024, #HMRC published a series of guidelines to clarify and help #taxpayers understand HMRC’s expectations when it comes to #transferpricing #compliance.   Join EY Host and Financial Services Transfer Pricing Partner Jonathan Thompson, EY Transfer Pricing Partner Tarunya Kumar (She/Her) and EY Transfer Pricing Senior Manager David Baxendale for brief insights on managing compliance risks for businesses in the UK; common compliance risks; and specific risks in designing transfer pricing policies. See the EY Tax Alert here: UK releases new Guidelines for Compliance | 'Help with common risks in transfer pricing approaches' (ey.com) Please reach out to Tarunya, David and your regular EY UK Transfer Pricing contact to discuss this development. #EY #tax #transferpricing #Allin #HMRC #OECD

Since being introduced in 2016, multinational groups have been preparing Country-by-Country Reporting [#CBCR] as part of their annual tax compliance processes. However, groups with operations in Australia and Europe will soon have to contend with some of that information being made public.  Join EY Host and Financial Services Transfer Pricing Partner Jonathan Thompson, EY Financial Services Transfer Pricing Senior Manager Alice Lin and EY Financial Services Transfer Pricing Manager Phoebe Billings for an update on the current Public CBCR [#PCbCR] landscape, the potential implications of these changes and some areas to be thinking about.

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.