Meta, IRS Spar Over Proposed Transfer Pricing Models in Tax Case

Oct. 10, 2025, 6:10 PM UTC

Meta Platforms Inc. and the IRS each accused the other of wrongly reading a recent Tax Court transfer pricing ruling as they seek a final determination of what the company owes in tax for intangibles the tech giant transferred to an Irish subsidiary.

In dueling briefs, the company and agency continued to insist that the court’s computation for entry of a decision favor their respective equations for how to value the intangibles for tax purposes. The two sides held a hearing Sept. 16 before Judge Cary Douglas Pugh to try to resolve the issue, as they each fight for how ...

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