A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026.

President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits.

At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards.

That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing.

On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year.

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