EY Transfer Pricing Roundup

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 the center of the dispute, the IRS's economic substance and Section 482 arguments, and why the court emphasized ex ante pricing using contemporaneous projections, not actual results. The episode also highlights key practical takeaways on documentation, assumptions, and reliance on advisors, with a note that the decision was appealed in late March 2026.

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 EMEIA Tax Policy and Controversy Leader, Jean-Pierre Lieb for a discussion on tax controversy in France and the increasing challenges multinational businesses face in today's complex global tax environment.
The conversation explores evolving transfer pricing dispute trends, heightened enforcement activity, and key considerations for managing tax risk across jurisdictions. The speakers share practical insights on how organizations can navigate scrutiny from tax authorities, prepare for controversies, and respond to a rapidly changing international tax landscape.
Listen to the episode to learn more about the latest developments and what they may mean for multinational businesses operating globally.
#TaxControversy #InternationalTax #TransferPricing #TaxPolicy #GlobalTax #EYTPRU

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 Pricing, Tax Treaties and International Agreements Division, and Ronald van den Brekel, EY Global TP Market and Innovation Leader, to discuss the OECD's consultation on transfer pricing aspects of intra-group services.
Together, they explore the background to the consultation, the key issues the OECD is seeking to address, and the potential implications for multinational enterprises across industries.
The discussion covers:
✅ The policy objectives behind the consultation
✅Areas where existing services guidance may be creating challenges
✅The interaction between services, value creation and transfer pricing outcomes
✅The OECD's work on global mobility
✅Other area's on the OECD's agenda
This was a fascinating discussion that brought together both the OECD's perspective and practical experience from working with multinational groups around the world.
Whether you are involved in transfer pricing, tax policy, controversy, or international tax governance, this episode provides valuable insights into one of the most important OECD initiatives currently under consideration.

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 consultation on documentation and an international controlled transactions schedule. In the middle of all of this, HMRC also released its annual diverted profits tax and Advance Pricing Agreement (APA) statistics. Join EY host and Financial Services Transfer Pricing Leader, Jonathan Thompson as he discusses these statistics with Matthew Bacon, who has recently joined EY from HMRC's APA team.

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 down with EY Singapore Transfer Pricing Partner, Adam Henderson, to unpack the latest transfer pricing guidelines.
In this episode, they explore:
✅ Key changes in the updated IRAS guidance
✅ Practical implications for multinational groups operating in or through Singapore
✅ How taxpayers should approach documentation, substance, and risk allocation in light of the revisions
✅ Common areas where increased scrutiny from the authorities may be expected
Singapore remains a critical hub in many global operating models, and this eighth version of the IRAS guidelines is a clear signal of continued refinement, and heightened expectations for transfer pricing compliance.