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KPMG report: Year-end tariff refunds

How transfer pricing adjustments may trigger significant tariff refunds

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July 15, 2025

Recent tariffs imposed by the Trump Administration have created financial and compliance burdens on organizations. But they have also created conditions that, when properly planned for, can result in significant year-end tariff refunds for importers.

As a result of increased tariff costs, many multinational enterprises (MNEs) intend to make new or larger-than-usual year-end transfer pricing adjustments to raise U.S. profits to an acceptable range for tax purposes. The mechanism for doing so generally requires the intercompany price of goods to be retroactively decreased. Retroactive reductions to intercompany prices can result in tariff refunds when specific requirements are met.

Read a July 2025 report prepared by KPMG LLP

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