# Episode 63: Transfer Pricing and Pillar Two – Strategic Considerations for MNEs

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Podcast: [EY Transfer Pricing Roundup](https://stenobird.com/podcast/ey-transfer-pricing-roundup-6595051)
Published: 2025-10-14T12:58:00+00:00
Episode link: https://20880d1f-90f6-438f-a416-f68457b78bb4.libsyn.com/episode-63-transfer-pricing-and-pillar-two-strategic-considerations-for-mnes
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Duration seconds: 766

## Resource

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.

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## Transcript

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