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12 February 2025

EY Transfer Pricing Roundup | An introduction to the Economic Substance Doctrine

The EY Transfer Pricing Roundup is a short, transfer pricing news-based podcast. We aim to provide listeners with brief and informative updates covering major legislative changes and controversy trends occurring around the world. In this series, we will interview our global transfer pricing professionals to flag and explain global developments.

In this episode, EY Financial Services Transfer Pricing leader and host, Jonathan Thompson, dives into a key topic in the world of transfer pricing: the Economic Substance Doctrine. This doctrine is a fundamental principle that has been part of US tax law for over 85 years. However, it recently attracted attention when a Senior IRS official confirmed that the IRS can apply the economic substance doctrine to transfer pricing cases.

The podcast is available here.

Find previous editions of this podcast on Apple Podcasts here.

Document ID: 2025-0456

 
 

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