3M, Perrigo Wins Mean Big IRS Losses: Transfer Pricing Report

Oct. 3, 2025, 9:04 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re taking a look at two back-to-back losses for the IRS, and what they could mean for transfer pricing cases in the works and in the future.

Another week, another big transfer pricing loss for the IRS.

3M’s win in federal district court Wednesday is sending shock waves through the tax world, as practitioners warn of a potential pivotal shift in how multinationals think about transfer pricing and tax disputes.

The significance of the decision “is hard to overstate,” Chad Martin at Eide Bailly told my ...

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