Surveying 2024 US Transfer Pricing Enforcement Trends

This article is a research report that discusses recent trends in transfer pricing enforcement by the IRS as of 2024. It outlines how the IRS has improved its enforcement outcomes, particularly due to organizational changes and increased resources. The report emphasizes the importance for taxpayers to reassess their transfer pricing documentation and defense strategies in light of these changes. It details the IRS's establishment of the Transfer Pricing Practice within its Large Business and International division, which has enhanced oversight and case management. The article also highlights recent high-profile transfer pricing cases, including notable rulings against major corporations, and discusses the implications of the Inflation Reduction Act on IRS enforcement capabilities. Additionally, it addresses the IRS's use of data analytics to identify noncompliance and encourages taxpayers to self-correct their transfer pricing policies. The report concludes by noting the increasing complexity and financial stakes associated with transfer pricing disputes, particularly concerning intangible assets.