Three things happened in US transfer pricing in 2025 and each one matters.

The IRS lost nearly 25% of its workforce. Enforcement is slower, but the case pipeline hasn't gone away. Facebook v. Commissioner (May 2025) confirmed the IRS's methodology on intangible CSA valuations these disputes will keep moving.

The US formally rejected BEPS 2.0. No Pillar One. No Pillar Two. That's now settled law domestically whatever the rest of the world does.

And from January 2025, the IRS introduced the Amount B Simplified and Streamlined Approach (Notice 2025-04) as an elective safe harbour for routine distribution arrangements. Less benchmarking, more certainty if the other jurisdiction accepts it.

The issue nobody is talking about enough: tariffs. New US tariffs at up to 200% change your cost base overnight. Three-year average TNMM benchmarks don't capture that. Many groups' existing pricing is technically out of arm's length and they don't know it yet.