Surveying 2024 US Transfer Pricing Enforcement Trends

The Internal Revenue Service has meaningfully improved its transfer pricing enforcement outcomes in recent years. Largely due to an organizational change to examination oversight over a decade ago, the IRS has had recent success in some high-profile transfer pricing cases. Current IRS hiring and enforcement efforts are intended to expand and continue that trend. Further, the IRS has increased its assertion of 20% and 40% transfer pricing penalties. Due to these changes, and a general increase in the amounts in transfer pricing disputes, the financial reporting for transfer pricing as an uncertain tax position (“UTP”) under Accounting Standards Codification (ASC) ...