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Cross-border Tax Talks

Tariff Tug-of-War: Coordinating your trade strategy

06 Nov 2025

Description

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, a Principal in PwC’s Customs & Trade Practice. Chris leads PwC US’s Global Trade Services. Doug and Chris, while at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague, discuss the Supreme Court’s expedited review of IEEPA‑based tariffs, possible outcomes, and the implications of an estimated ~$108B refund exposure across multiple industries (See our PwC Insight: IEEPA Tarrif: Understanding the Potential outcomes ahead of the Supreme Court’s Ruling for more details). They cover how persistent tariffs elevate customs to the C‑suite and require close integration with transfer pricing and Pillar Two modeling. They also discuss practical mitigations including first sale for export, duty drawback, Harmonized Tariff Schedule (HTS) reclassification and origin analysis, transfer‑pricing alignment, and use of foreign‑trade zones -- paired with rigorous controls as US government scrutiny intensifies. The episode closes with sector‑specific developments and a data‑driven playbook.  

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