IRS Swings Back at Meta, India Delivers: Transfer Pricing Report

Feb. 6, 2026, 10:02 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week the IRS swung back at Meta’s lawsuit challenging the agency’s periodic adjustments. In India, the new budget offers relief for data centers and looks to speed up APAs. Also in India, 3M says it will appeal some new adjustments.

OK, it wasn’t exactly a smackdown, but the IRS’s bland, technical answer to Meta’s recent lawsuit gave more of a peek into the government’s case while asking the judge to deny the company’s bid to nix the agency’s new $16 billion adjustments.

In case you forgot: The ...

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