In this Year in Review, our global transfer pricing team reflects on the significant developments that shaped 2025 and highlights the trends we anticipate for 2026.
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs valuation now operate together. Rising tariffs and trade tensions intensified scrutiny on supply chains and tax planning, while the growing demand for Advance Pricing Agreements underscored taxpayers’ desire for greater certainty. Throughout the year, our team remained dedicated to delivering thoughtful, fact specific, data driven solutions and supporting clients with clarity and confidence.
Looking ahead to 2026, proactive planning, high quality insights, and effective dispute resolution will be essential. Key transfer pricing issues include changes in business models driven by AI and the rise of cryptocurrency, increasing scrutiny of compensation for high value intragroup services, the first year of public Country by Country reporting for in scope companies, and the continued role of tariffs in supply chain reorganization. Tax authorities around the world are placing greater emphasis on the substance of intercompany arrangements, which makes defensible documentation, forward looking planning, and continuous monitoring more important than ever.
Our team continues to provide customized transfer pricing analysis designed to address each client’s specific business needs. We invite you to read the full 2025 Year in Review from our transfer pricing team.
