ARTICLE
10 December 2025

Developments In Tariffs And Their Interaction With Transfer Pricing

Tariffs are by no means a new phenomenon, but recent developments have had a profound impact on global supply chains and international trade. From the US tariff waves introduced under the Trump administration...
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Tariffs are by no means a new phenomenon, but recent developments have had a profound impact on global supply chains and international trade. From the US tariff waves introduced under the Trump administration to the retaliatory measures imposed by key trading partners, including the European Union, protectionist policies have re-emerged as a defining feature of the international trade landscape. As tariffs represent a cost in the supply chain, these may trigger important transfer pricing considerations for multinational enterprises.

In light of these developments, our tax and customs experts published two articles that address the growing impact of tariff measures on multinational enterprises and their transfer pricing and supply chain structures. Both articles provide practical guidance for US headquartered businesses navigating the effects of recent international tariff developments.

Below you will find an overview of the articles as well as link for you to read them.

How the forthcoming tariffs will impact transfer pricing

This article explains how sudden tariff increases create immediate cost shocks and raise questions about how these costs should be allocated within a group. It outlines short-, mid- and long-term observed approaches to manage the transfer pricing impact, from supply chain reviews to potential restructurings. The authors emphasize that any measures taken must be well substantiated and documented.

You can read the full article on Bloomberg Tax here.

US tariffs: the EU perspective – turning tensions into business opportunities

This article explains how recent US and EU tariff measures are reshaping global trade and creating challenges for supply chain management and compliance. It highlights practical strategies such as supply chain mapping, correct product classification. The authors emphasize aligning customs valuation with transfer pricing and taking a proactive approach to mitigate risks.

You can read the full article on TEI US Tariffs: The EU Perspective | Tax Executive.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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