EY Transfer Pricing Roundup

Episode 72: Perrigo v. United States: Court Rejects Government's Blanket Assertion of Lack of Economic Substance and Hindsight in Transfer Pricing

September 12, 2026·7 min
Episode Description from the Publisher

In this episode of EY Transfer Pricing Roundup, host Ryan J. Kelly is joined by Kent Stackhouse to unpack Perrigo Company v. United States (W.D. Mich.). They discuss the 2006 contract reassignment at the center of the dispute, the IRS's economic substance and Section 482 arguments, and why the court emphasized ex ante pricing using contemporaneous projections, not actual results. The episode also highlights key practical takeaways on documentation, assumptions, and reliance on advisors, with a note that the decision was appealed in late March 2026.

Podzilla Summary coming soon

Sign up to get notified when the full AI-powered summary is ready.

Get Free Summaries →

Free forever for up to 3 podcasts. No credit card required.

Listen to This Episode

Get summaries like this every morning.

Free AI-powered recaps of EY Transfer Pricing Roundup and your other favorite podcasts, delivered to your inbox.

Get Free Summaries →

Free forever for up to 3 podcasts. No credit card required.