Episode 28: Rethinking MAP in today's Transfer Pricing environment

Episode 28: Rethinking MAP in today's Transfer Pricing environment

In November 2023, following the Organisation for Economic Co-operation and Development's (#OECD) unveiling of the Mutual Agreement Procedure (#MAP) statistics in 2022 and the earlier publication of the Manual on handling MAPs and #APA cases, the most recent installment of the EY Transfer Pricing Roundup delves into the MAP process and explores the concept of multilateral MAP. Hosted by EY's US Tax Principal Jonathan Thompson and joined by EY London Transfer Pricing Partner Andy Martyn, this episode illuminates some key considerations and strategies for taxpayers.

🗞 Access the OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm

🗞 Access the manual here: https://www.oecd-ilibrary.org/docserver/f0cad7f3-en.pdf?expires=1707858430&id=id&accname=guest&checksum=E1B9B1EE600C59C075061324F7902F82

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Episoder(73)

Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation

Episode 73: Brazil's New Transfer Pricing Landscape: Implementation and Documentation

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 Gustav...

23 Sep 13min

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

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 ...

12 Sep 7min

Episode 71: Tax Controversy in France: Insights for Multinational Businesses

Episode 71: Tax Controversy in France: Insights for Multinational Businesses

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 EM...

17 Aug 16min

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

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 Pricin...

16 Jul 45min

Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends

Episode 69: UK Transfer Pricing Update: HMRC Statistics and Enforcement Trends

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 ...

15 Jul 11min

Episode 68: IRAS Transfer Pricing Update – Version 8.0

Episode 68: IRAS Transfer Pricing Update – Version 8.0

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 do...

9 Jun 13min

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

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 an...

1 Mai 11min

Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms

Episode 66: Navigating Canada's Transformative Transfer Pricing Reforms

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...

9 Feb 29min

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