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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
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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.
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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.
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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.
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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.
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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.
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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.
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In this episode of the EY Transfer Pricing Roundup, join EY host and Transfer Pricing Partner Jonathan Thompson and EY Switzerland Partner, Francisco Palacios as they discuss the Swiss transfer pricing landscape. Topics covered include a brief overview of swiss transfer pricing law, updates on recent detailed transfer pricing guidance from Swiss tax authorities, practical strategies for businesses to ensure compliance and insights into how these changes align with global transfer pricing trends.
If you have any questions or would like to speak with Jonathan or Francisco, find them on LinkedIn here: Jonathan Thompson / Francisco Palacios
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In this episode of the EY Transfer Pricing Roundup, EY Transfer Pricing Partner and host, Ameet Kapoor along with EY Transfer Pricing Partners, Donna McComber and Kent P. Stackhouse break down the different types of ways taxpayer information is shared with the Internal Revenue Service (IRS). These Exchanges of Information (#EOI) include Automatic, Spontaneous, and On-Request exchanges.
This episode explores how these mechanisms work, their implications for taxpayers and tax authorities, and the global impact on tax compliance and enforcement. Whether you're a tax practitioner, a business owner, or simply curious about tax policy, this podcast offers valuable insights to help you navigate the complexities of EOI with the IRS.
Access the recently published article in Tax Notes: Exchange of Information in the New Era of Multilateral Transfer Pricing Enforcement.
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While Pillar Two continues to make the headlines, let’s not forget Pillar One, which is steadily evolving. Join EY host and Transfer Pricing Partner, Jonathan Thompson for a quick recap and update with EY Transfer Pricing Partner and Global Transfer Pricing Market and Innovation Leader, Ronald van den Brekel on recent developments related to Amount B. In this episode, our EY Partners provide you with the latest insights, analyze real-world implications, and provide practical advice for navigating the complex terrain of Amount B. Whether you're a tax professional, a multinational corporation, or simply interested in the evolving world of international tax policy, the EY Transfer Pricing Roundup is designed to keep you informed and ahead of the curve.
#PillarOne #AmountB #OECD #TransferPricing #Tax #EYTPRU
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Join EY host and US Transfer Pricing Partner, Ameet Kapoor in a deep dive into Japan's dynamic tax environment with EY Japan Transfer Pricing Partner Karl Gruendel. Discover the latest trends in #transferpricing and #Controversy, including the evolving review practices by tax authorities and the integration of #AI. Gain valuable insights on Advance Pricing Agreements #APAs and Mutual Agreement Procedures #MAPs, essential tools for managing tax disputes in Japan.
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In the latest episode of the EY Transfer Pricing Roundup, EY host and US Transfer Pricing Partner, Ameet Kapoor discusses the highlights from the recent #IRS Annual Advance Pricing Agreement (#APA) Statutory Report with EY US Transfer Pricing Partner, Donna McComber. With a record breaking number of APAs executed in 2023, its an episode that you don’t want to miss!
#Statistics #Controversy #APMA #TPControversy #EYTPRU #Disputeresolution
Access the 2023 IRS APA Statutory report here: https://www.irs.gov/pub/irs-drop/a-24-16.pdf
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In a special guest episode of the #EY Transfer Pricing Roundup, EY US host Jonathan Thompson, EY US Partner Donna McComber and EY UK Partner Astrid Vroom are joined by the Senior Advisor of Transfer Pricing at Large Business and International (#LB&I) at the Internal Revenue Service (IRS), Karen Kirwan in a comprehensive exploration of the International Compliance Assurance Program (#ICAP). ICAP, a collaborative initiative between multiple tax authorities, aims to enhance tax compliance and certainty in the international tax arena. Our panel unpack the intricacies of ICAP, discussing its framework, benefits and challenges and discuss the IRS’s initial experience of the program.
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The latest #EY Transfer Pricing Roundup #podcast episode dives into the recent Italian legislative updates and looks at the connection between the Investment Management Exemption (#IME) and transfer pricing. Drawing on experience from the UK’s IME, join EY US host and Financial Services Transfer Pricing Principal, Jonathan Thompson, EY London Financial Services Tax Partner, Debbie Knowles and EY Italy Financial Services Transfer Pricing Partner, Antonfortunato Corneli as they discuss the recent updates and the #alignment between the #Italian tax #regulations and transfer pricing.
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Dive into the intricacies of transfer pricing regulations in China with our latest episode of the #EY Transfer Pricing Roundup podcast series. From understanding the latest updates in Chinese tax laws to unraveling the complexities of intercompany transactions, our episode provides invaluable insights for multinational businesses operating in China. Join EY host and US Transfer Pricing Principal, Jonathan Thompson and EY China Transfer Pricing Partner, Kena Qu as they discuss compliance strategies, and decode the nuances of transfer pricing to help you stay ahead in the ever-evolving regulatory landscape of #china.
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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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In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Mexico Transfer Pricing Partner, Enrique Gonzalez Cruz. In this episode, Enrique sheds light on the transfer pricing audit landscape in Mexico and what taxpayers can expect and should be prepared for. Also discussed is the current Advance Pricing Agreement (APA) environment in Mexico and the process taxpayers can expect when filing APAs with Mexico.
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Statistics from Organisation for Economic Co-operation and Development (OECD) on Mutual Agreement Procedures (MAP) for 2022 show that increase in global tax disputes and a more accessible MAP process resulting in more taxpayers seeking relief. The 2022 statistics demonstrate that MAP remains an effective way to eliminate double taxation and taxation not in accordance with a treaty. The 2022 data covers almost all MAP cases worldwide. Separate statistics are provided for transfer pricing cases and "other" cases (i.e., non-transfer pricing cases) for 2022 on the:
Opening and ending inventory of MAP cases Number of new MAP cases started, completed, closed or withdrawn Average cycle time for MAP cases completed, closed or withdrawnIn the latest episode of the EY Transfer Pricing Roundup, EY US Tax Principal Jonathan Thompson hosts a detailed discussion with EY US Transfer Pricing Partner and Transfer Pricing Controversy Leader, Ryan Kelly, about the 2022 statistics and what taxpayers should be thinking about.
Access the 2022 OECD MAP Statistics here: https://www.oecd.org/tax/dispute/mutual-agreement-procedure-statistics.htm
Access and download the EY Tax Alert here: https://globaltaxnews.ey.com/news/2023-1960-oecds-2022-mutual-agreement-procedure-statistics-show-us-decreasing-map-case-inventories-increasing-time-to-close#:~:text=MAP%20statistics%20for%20all%20countries,and%202019%20(%2B3.5%25).
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In the latest episode of the EY Transfer Pricing Roundup, EY US Transfer Pricing Partner Ameet Kapoor hosts a detailed discussion with EY Australia Transfer Pricing Partner, Tony Cooper. In this episode, Tony shares #insights on the latest transfer pricing #audits, Advance Pricing Agreements (#APAs) and Mutual Agreement Procedures (#MAPs) in #Australia. Tony also discusses the latest Australian Tax Office’s (#ATOs) Top 1,000 income tax and goods and services tax (#GST) assurance program report. The report provides large businesses with an opportunity to gain greater certainty about their tax outcomes and the effectiveness of their tax governance frameworks. It also provides an objective mechanism for large businesses to understand how their tax profile compares to others in the market and their peers.
Access the Findings report for the Top 1,000 income tax and GST assurance programs here: https://www.legacy.ato.gov.au/Business/Large-business/In-detail/Findings-report---Top-1,000-income-tax-and-GST-assurance-programs/
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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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