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.