Episode 24: The Intricacies of Implicit Support in Transfer Pricing

Episode 24: The Intricacies of Implicit Support in Transfer Pricing

In the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with Sandra Gurijala and John Hill about the intricacies of Implicit Support in Transfer Pricing. The discussion focuses on a newly released Generic Legal Advice Memorandum (#GLAM) from the Office of Chief Counsel of the #IRS, shedding light on the implications of group membership on financial transactions under IRS Section 482. The conversation further explores the long-debated issue of implicit support and its impact on intercompany #loans and #guarantees. Don't miss this insightful episode.

Access the latest EY Tax Alert on the GLAM here: https://taxnews.ey.com/news/2024-0132-generic-legal-advice-memorandum-says-irs-can-consider-implicit-support-to-price-intercompany-loans

Access the GLAM released by the IRS in December here: https://www.irs.gov/pub/lanoa/am-2023-008.pdf

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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 Maj 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

Episode 65: A transfer pricing postcard from Australia

Episode 65: A transfer pricing postcard from Australia

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 ...

2 Feb 11min

Episode 64: Transfer Pricing Compliance x Technology – where are we at and where are we going?

Episode 64: Transfer Pricing Compliance x Technology – where are we at and where are we going?

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 Dire...

26 Jan 13min

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

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 episo...

14 Okt 202512min

Episode 62: An Advance Pricing Agreement Special

Episode 62: An Advance Pricing Agreement Special

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 L...

9 Sep 202526min

Episode 61: Navigating Transfer Pricing in a Tariff-focused World: Strategic Implications and Compliance Challenges

Episode 61: Navigating Transfer Pricing in a Tariff-focused World: Strategic Implications and Compliance Challenges

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...

1 Aug 202512min

Episode 60: Dutch Financial Transaction Transfer Pricing update

Episode 60: Dutch Financial Transaction Transfer Pricing update

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 #APA...

21 Juli 202514min

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