Tax Coda

Tax Coda

Transfer pricing enters a new era of volatility and scrutiny in 2025

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Tax Coda
Dec 05, 2025
∙ Paid

The transfer pricing environment in 2025 has shifted faster than the IRS can hire, fire, or reinstate employees.

Years of expanded enforcement gave way to steep budget cuts, workforce churn, and operational instability. Despite that turbulence, the IRS continues to refine case selection, push penalties under §6662, and develop litigation positions.

Comp…

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