The Transfer Pricing Show

The Supreme Court ruled 6-3 that IEEPA does not authorize presidential tariffs. Roberts held that "regulate … importation" doesn't include the power to tax — a power the Constitution reserves to Congress. The ruling invalidates the reciprocal and drug-trafficking tariffs but leaves Section 232/301 duties intact. Refund exposure may top $175B. The administration vows to reimpose tariffs under other statutes, but those tools are narrower, capped, and require formal investigations IEEPA never demanded.

India just collapsed four safe harbor categories into one, cut the margin to 15.5%, and raised the threshold to ₹2,000 crore — which means the annual benchmarking fight that has defined Indian TP compliance for two decades might actually be over for most IT services captives. But "streamlined" is not "free," and the price of certainty includes a margin above arm's length, secondary adjustment obligations, and surrendering your right to MAP. This article explains what changed, what it costs, what still applies, and why India decided now was the moment to stop auditing its way to an answer everyone already knew.

CRA’s been aggressive for years—now Canada wants OECD-style “actual conduct” baked into the statute. Bill C-15 shrinks the doc clock to 30 days and makes “contracts say” a weaker defense when reality says otherwise. If your residual lives offshore but decisions live in Canada, expect the phone to ring.

The EU's Anti-Coercion Instrument—nicknamed the "trade bazooka"—lets Brussels retaliate against economic bullying without unanimous member state approval. Adopted in 2023, it authorizes tariffs, procurement bans, IP restrictions, and financial market exclusions against countries weaponizing trade to influence EU policy.Built after Trump's 2018 tariffs and China's pressure on Lithuania, it's now facing its first real test: US threats over Greenland. The legal case looks clear—using tariffs to obtain territory is textbook coercion. But with $1.3 trillion in annual trade at stake, the political will to pull the trigger remains uncertain. Deterrence only works if your adversary believes you'll act.

Amount B promised to simplify transfer pricing for routine distribution—a genuine problem consuming six-figure fees on 3% margin transactions. Instead, it haunts the international tax system as a specter of what could have been. The 2025 OECD Model Convention builds elaborate dispute resolution infrastructure for a framework that, per France's July 2025 guidance, "no jurisdiction meets the conditions" to trigger. Developed economies won't implement domestically; covered jurisdictions haven't adopted. Only the US breathed life into it via Notice 2025-4—while simultaneously repudiating the Global Tax Deal. The ghost of transfer pricing simplification lives. It just hasn't found a body yet.

The US and Pillar Two were never going to be a perfect match. After a threatened tax war, a last-minute G7 deal, and a "revenge tax" that got pulled days before passage, the two systems have agreed to coexist—awkwardly. On January 5, 2026, the OECD made it official: US-parented multinationals can elect out of IIR and UTPR starting this year. But don't cancel your compliance subscriptions just yet. QDMTTs still apply, 2024–2025 filings are still due, and the GIR still needs to be filed. In this episode, we break down what Side-by-Side actually means for US MNEs, why transfer pricing is now your primary Pillar Two battleground, and what happens if you lose an audit in a QDMTT jurisdiction. The honeymoon is over. The paperwork isn't.

Analysis of the how BEAT changes under the OBBA.

Continuing AI generated study guide on the OBBA impact to transfer pricing and international tax.

Continuing study guide into the OBBA's impact on international tax and transfer pricing

Exploring how the new R&D cost treatment impact transfer pricing.