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MNEs Face Transfer Pricing True-Up Challenges in Time of Tariffs
The US tariffs threatened, imposed, deferred, and changed throughout 2025 have created uncertainty for transfer pricing compliance. As multinational enterprises that import affected goods from related companies strive to navigate the changing landscape on material, new tariffs, they face increased costs, affecting not only their profitability but also their transfer pricing compliance. MNEs may be required to lower the transfer price paid to related companies for imported goods to remain within the arm’s length profitability ranges expected by the IRS.