The U.S. Inflation Reduction Act (IRA) allocates nearly $80 billion in new funding to the Internal Revenue Service (IRS). More than $45 billion of that amount is dedicated to compliance enforcement efforts with additional amounts for operations, systems modernization, and taxpayer service. The substantial increase in IRS enforcement funding, along with technology investments, is expected to result in additional scrutiny of transfer pricing arrangements. Multinational entities should take steps now to support their transfer pricing positions and explore opportunities for advance tax certainty.

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