Assessing recent transfer pricing enforcement trends

The resources the IRS has devoted to transfer pricing enforcement has grown recently due to a number of factors. An organizational change to oversight more than a decade ago has laid the groundwork for the IRS to successfully prosecute some recent high-profile transfer pricing cases.

Steven Wrappe, Grant Thornton National Technical Leader for Transfer Pricing, discusses the impact of this increased level of IRS scrutiny on transfer pricing enforcement in an article for Bloomberg Tax called “Surveying 2024 US Transfer Pricing Enforcement Trends.” Wrappe reviews the establishment of the Transfer Pricing Practice within its Large Business and International division in 2012 and how this sparked an initiative aimed at enforcing compliance. Additional funding from the Inflation Reduction Act allowed added personnel to the initiative.

Wrappe ends the article by calling for multinationals to evaluate their compliance profile and update documentation for operations changes or changed expectations in light of recent IRS wins. Read the Bloomberg Tax article here.