Episode 48: Decoding the IRS Priority Guidance Plan: What You Need to Know!

Episode 48: Decoding the IRS Priority Guidance Plan: What You Need to Know!

In today's episode, EY Financial Services Transfer Pricing leader and host Jonathan Thompson unpacks the Internal Revenue Service (#IRS) Priority Guidance Plan. This plan, released annually by the U.S. Department of the Treasury and the IRS, outlines the key tax issues that will be addressed through regulations, revenue rulings, procedures, notices, and other forms of published guidance over the next year.

Jonathan is joined by EY's National Transfer Pricing Controversy Leader, Ryan Kelly for his take on the latest priority guidance for transfer pricing, what it means and what #MNEs should be thinking about for 2025.

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Avsnitt(72)

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 Juli 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 Juli 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 Juni 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 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

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