Read the Top 5 Transfer Pricing Insights of 2025

Transfer pricing developments affected many parts of the world this year in the form of litigation and evolving enforcement approaches. Below are several Bloomberg Tax Insights that examined the interaction of transfer pricing and tariff volatility, possible strategies for multinational companies, and how countries scrutinized and regulated transfer pricing in 2025.

Creating Tariff Strategies? Get the Tax Department to Weigh In. As multinational enterprises grapple with the Trump administration’s tariffs, they need to involve their tax departments and advisers to help ensure any benefits from tariff mitigation aren’t offset by unexpected tax consequences. Multinationals can consider adjustment of transfer prices between related parties—and how any additional costs related to tariffs may affect their overall transfer pricing policies. Forvis Mazars’ Michael Cornett wrote this in April. Read More

New Transfer Pricing Scrutiny Requires Transactional Resilience. Financial transactions have become one of the most closely examined areas for multinational enterprises in today’s transfer pricing landscape. Multinationals must build financial transaction frameworks that are compliant and resilient, as well as grounded in commercial logic and economic substance. Those that proactively adapt their intra-group financing strategies will turn regulatory challenges into competitive advantages. Exactera’s Mili Diaz Colodrero wrote this in June. Read More

How Australia’s Tax Agency Is Trying to Redefine Transfer Pricing. The Australian Taxation Office is on a mission to redefine the landscape of transfer pricing. As Australia’s tax framework continues to expand, more litigation is to be expected. Regardless of outcomes, the ATO undoubtedly will recalibrate its approach, becoming more targeted and strategic in its scrutiny of taxpayers. Few taxpayers can match the ATO’s resources, making it imperative to invest early in robust tax governance, thorough record-keeping, and defensible transfer pricing policies. Grant Thornton Australia’s Jason Casas and Keith To wrote this in September. Read More

3M’s Transfer Pricing Victory Puts Brakes on IRS Overreach. The US Court of Appeals for the Eighth Circuit’s decision in 3M Co. v. Commissioner marks a turning point in transfer pricing disputes. The Eighth Circuit affirmed a long-standing doctrine that the IRS can’t tax amounts that a taxpayer is legally barred from receiving. But for taxpayers, the message remains clear: Invest in documentation, anticipate disputes, and be prepared to defend positions that reflect both economic reality and legal constraints. Dentons’ Rezan Ökten, Linda Pfatteicher, and Cali Krajnik wrote this in October. Read More

Canada Transfer Pricing Reforms Would Make Compliance Pricier. Canada’s proposed transfer pricing reforms aim to bring the country’s tax laws more in line with international guidelines by tightening how corporations justify pricing within their own global operations. If enacted, the reforms are likely to add complexity, uncertainty, and compliance costs. Multinationals should watch closely to gauge how the new rules might affect investment and Canada’s broader business climate. Blakes’ Pooja Mihailovich and Erich Schultze wrote this in November. Read More

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law, Bloomberg Tax, and Bloomberg Government, or its owners.

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