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ARTICLE · 20 MARCH 2025

Transfer Pricing In Times Of Tariff Turmoil

The evolving landscape of U.S. tariffs and Canadian countermeasures presents significant challenges for multinational groups...

GlobalTax

The evolving landscape of U.S. tariffs and Canadian countermeasures presents significant challenges for multinational groups, including in the realm of intercompany transfer pricing. As businesses navigate the sudden shifts and reversals of the developments regarding the U.S. and Canadian tariffs, they must grapple with the interaction between tariffs and transfer pricing.

One critical question is how to allocate and absorb the increased costs associated with tariffs across the global value chain. Businesses may need to revisit their intercompany arrangements to ensure they address key risks and continue to reflect arm's length terms and conditions. Tariffs can also significantly affect the comparability of transactions used in transfer pricing analyses. Companies may therefore need to reassess their benchmarking and potentially adjust their comparable sets.

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