EY - BorderCrossings: Navigating a transfer pricing adjustment

EY International Tax Webcast

BorderCrossings with EY's transfer pricing and tax professionals

Navigating a transfer pricing adjustment

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US- and foreign-initiated transfer pricing adjustments are likely to increase as tax authorities add audit resources, implement the final recommendations of the OECD’s Base Erosion and Profit Shifting (BEPS) project, and begin receiving more information from taxpayers, such as global and local transfer pricing studies and country-by-country reports.

If all or part of these adjustments are sustained, taxpayers will need to understand the implications for tax, accounting, and customs purposes.

This month’s webcast will focus primarily on the tax consequences of a sustained transfer pricing adjustment and will address such issues as:

  • The primary types of transfer pricing adjustments (primary, compensating, and collateral)
  • The different types of collateral adjustments (collateral, conforming, and set-offs)
  • Available relief provisions, including repatriation options (e.g., under IRS Revenue Procedure 99-32), withholding tax considerations, and foreign tax credit implications
  • State tax consequences of adjustments
  • Customs effects

During this live, interactive webcast, you will have the opportunity to ask questions through the website, and the panelists will answer as many of your questions as time permits.

This program will be of interest to vice presidents/directors of tax/state and local tax/international tax/transfer pricing/global trade, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We hope you will be able to join us.


  • Kenneth Christman, Ernst & Young LLP (US), Transfer Pricing, International Tax Services
  • Tina Egbert, Ernst & Young LLP (US), Indirect, State and Local Tax
  • Paul Mulvihill, Ernst & Young LLP (Canada), Transfer Pricing Controversy Leader
  • Tom Ralph, Ernst & Young GmbH Wirtschaftsprüfungsgesellschaft, US Transfer Pricing Desk for Europe


  • Craig Sharon, Ernst & Young LLP (US), Transfer Pricing, International Tax Services