IRS Appeals Perrigo Co. Ruling in Transfer Pricing Tax Dispute

The IRS appealed its district court loss against Perrigo Co. after the court awarded the company $89.2 million for overpaid taxes, interest, and penalties earlier this year.

In January, Judge Robert J. Jonker of the US District Court for the Western District of Michigan approved the proposed amount following his September 2025 ruling that Perrigo’s transactions with an Israeli affiliate didn’t lack economic substance, as was asserted by the IRS, and thus weren’t simply a tax avoidance scheme.

• The IRS appealed the ruling to the Sixth Circuit on Friday.
• The $89.2 million the court awarded was less then the ...