Episode 65: A transfer pricing postcard from Australia

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 Transfer Pricing Partner from EY Canada, to break down what these changes mean in practice. Marlon shares insights on how taxpayers should approach delineation, documentation, and risk assessment under the new regime—and what multinationals should be doing now to stay ahead of the curve. 👉 Tune in to understand the impact, the opportunities, and the road ahead.

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 ATO scrutiny and continued legislative evolution, transfer pricing is always a hot topic. The conversation explores: 📌 Key legislative and administrative developments shaping Australia's transfer pricing framework 📌 Practical implications for documentation, governance, and disputes 📌 What taxpayers should be prioritizing now to manage risk proactively  

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 usage, and end‑to‑end compliance. This episode unpacks: 📌 How evolving global standards are reshaping transfer pricing documentation requirements 📌 Practical challenges companies face when aligning their documentation 📌 The growing role of technology and data in creating defensible, efficient compliance processes 📌 What organizations can do today to anticipate regulator expectations tomorrow

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.