Tariff Refunds Would Create a Nightmare: Transfer Pricing Report

Oct. 31, 2025, 9:04 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking to the future, and the transfer pricing mess that could ensue if the Supreme Court orders tariff refunds after hearing the case next week.

The chance that many of President Donald Trump’s tariffs could be ruled illegal has large multinationals salivating at the chance to recoup tariffs already paid—sometimes stretching well into the millions.

It could also mean a nightmare for companies trying to figure out what it means for their transfer pricing, practitioners told me.

The Supreme Court is to hear arguments next ...

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