Transfer Pricing Forum – Transfer Pricing For The International Practitioner

Introduction

There is no doubt that the recent implementation of the new tariffs in the first half of the year on global imports to and exports from the United States has significantly reshaped the global trade landscape. While much attention has been given to the broader economic and political implications of such measures, their impact on multinational groups (MNEs) and their daily operations, including the areas of transfer pricing (TP) and customs, has been profound. In an environment of increasing tax compliance and administrative burden by the MNEs, these tariffs, beyond increasing the direct cost of imports, have wide implications on TP and customs valuation, challenging long-standing intercompany pricing policies and potentially raising questions around consistency.