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Transfer Pricing Arrangements: IRS and OECD Requirements, IRS Challenges, Impact of Tariffs

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Monday, June 9, 2025

Recorded event now available

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This webinar will review the governing rules surrounding transfer pricing arrangements, including IRC Section 482 and OECD requirements. Our panel of notable international tax professionals will analyze the shifting landscape of these arrangements, considering the imposition of global tariffs and the current IRS campaign targeting multinational entities (MNEs).

Description

Transfer pricing is the determination of prices between related entities for transactions, including the purchase of goods or services, intercompany loans, and intangible assets. Section 482, as well as the regulations of most countries, requires the prices charged and paid be arm's length. In other words, they should be comparable to prices agreed upon by unrelated parties.

In early 2024, the IRS announced its Large Foreign-Owned Corporations Transfer Pricing Initiative targeting U.S. subsidiaries of foreign companies. Airbnb, Coca-Cola, and Newell Brands have all had their transfer pricing positions subjected to IRS scrutiny. The ramifications of noncompliance are substantial. Nondeductible penalties under IRC Code Section 6662 are 20%, or 40% if the underpayment exceeds $20 million. Many other countries may also impose penalties for lack of compliance with transfer pricing regulations.

Section 482 and guidelines from the Organisation for Economic Cooperation and Development (OECD) list several methods for determining income for commonly controlled entities and dictates that companies choose the "best method." The importance of documenting the pricing method selected cannot be overemphasized. Now, with significant tariffs charged on overseas goods, MNEs and international tax practitioners need to incorporate these assessments in their transfer pricing policies and procedures.

Listen as our panel of transfer pricing and valuation experts explains how to establish and support a transfer pricing arrangement for MNEs and international tax advisers.

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Outline

  1. Transfer pricing: introduction
  2. Rules governing transfer pricing agreements
  3. Transfer pricing life cycle for a multinational
  4. The importance of intercompany agreements
  5. Transfer pricing in an acquisition environment
  6. OECD and the shifting TP landscape
  7. Tariffs and transfer pricing
  8. Tax authority challenges to transfer pricing

Benefits

The panel will cover these and other critical issues:

  • Establishing a transfer pricing arrangement that meets Section 482 and OECD requirements
  • Transfer pricing in an acquisition environment
  • The rules governing transfer pricing arrangements
  • Withstanding IRS scrutiny of transfer pricing
  • The impact of tariffs on transfer pricing

Faculty

Faulkner, Sean
Sean Faulkner
Senior Director
Armanino

Mr. Faulkner is a Senior Director in Armanino’s New York office and has practiced transfer pricing since...  |  Read More

Walls, Joshua
Josh Walls
Partner
Valentiam Group

Mr. Walls brings more than 20 years of transfer pricing and valuation experience in Big 4, boutique, and...  |  Read More

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