Circular AI Deals Raise Control Issues: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at how recent circular deals with flashy AI big guns and startups could trigger transfer pricing issues for unwary tax departments. Also, the IRS and Meta spar at Tax Court, a Coca-Cola trial date is set, and Australia tightens some rules.

The recent explosion in circular deals among billion-dollar companies funding AI’s explosive growth could—in addition to freaking out the markets—be hiding a tax concern, maybe unrecognized: the risk of transfer pricing regulation.

Circular deals occur when a company invests in a business that ...