Another Trip Around the Transfer Pricing Sun: Four Bold Predictions for 2026

It's hard to make predictions – especially about the future. Today we indulge in the late-December tradition of throwing Yogi Berra’s wise words to the wind, as we wrap up the year in transfer pricing with a few squints into the crystal ball. Here are some hot takes on what 2026 might have in store for transfer pricing professionals:

• The Large Business & International Division of the IRS attracts the attention of the Trump Administration for its potential to raise politically-popular revenue from large multinationals via transfer pricing audits. Bewildered transfer pricing professions adjust to this newfound goodwill toward the taxman by bolstering the scope and quality of transfer pricing compliance and defense.
• Border-adjusted taxes eclipse tariffs as the topic any self-respecting transfer pricing discussion must include, with the accompanying wise nods and murmurs of “good point.” Also cleverly termed destination-based cash flow taxes, the idea is to levy taxes based on where goods and services are consumed rather than where they are produced, and has been pitched as an alternative to corporate income tax, a replacement for tariffs, and a silver bullet for eliminating the possibility for income shifting via transfer pricing. Despite the intention to render their occupation obsolete, transfer pricing professionals recognize the immense legal and practical clusters to come and accelerate hiring and investment.
• Comparable company benchmarking goes open source, as a college kid with AI wizardry and a weird interest in intercompany pricing unleashes a free-to-use, web-based tool. Transfer pricing professionals indignantly point out the flaws and risks, while secretly trying to engineer a version of their own.
• A “circuit split” – in which two or more circuit courts issue decisions that are incompatible or contradictory – arises on the IRS's power to interpret and enforce Section 482, setting the stage for the first transfer pricing Supreme Court case. Transfer pricing professionals stock up on popcorn and plan watch parties, with disappointing RSVP results.

We'll check back in next December with a report card on our clairvoyance. In the meantime, a very happy new year from the Eide Bailly transfer pricing team!