In this special edition of EY Transfer Pricing Roundup, recorded in São Paulo, host Jonathan Thompson is joined by Daniel Biagioni, Milton Gonzalez Malla, Charikleia Tsoukia, Sandra Knaepen and Gustavo Carmona to discuss Brazil's OECD-aligned transfer pricing framework.

The panel explores early implementation lessons, the importance of aligning transfer pricing policies, agreements and business practices, and the interaction between transfer pricing and Brazil's broader tax regime. They also discuss documentation considerations and Brazil's tax audit and dispute environment.

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.

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