Episode 119: When tariffs wag the transfer pricing dog

Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by Kristin Bohl, a Principal in PwC’s US Customs and International Trade Practice. 

Kristina and Kristin discuss the latest developments in global tariffs and how these intersect with transfer pricing strategies. They cover the Trump administration’s rollout of reciprocal and industry-specific tariffs, limited retaliatory actions by US trading partners, and the shift from reactive to proactive planning. Kristin explores tactical mitigation strategies, such as first sale for export, transfer pricing adjustments, and unbundling, emphasizing the convergence of customs and transfer pricing disciplines. The episode also examines the practical limitations of onshoring, implications for limited risk distributors, and rising enforcement risk. Looking ahead, they preview the potential impact of the Supreme Court case addressing IEEPA tariffs and offer strategic recommendations for year-end planning.

For more related content, please see PwC's Transfer Pricing and Customs and International Trade sites, as well as PwC's Policy on Demand Transfer Pricing and Customs channel.