With US tariffs on imported pharmaceuticals imminent, I highly recommend an early April piece by @tom_hubert of the Currency outlining how US firms in Ireland could adjust intergroup transfer pricing to reduce their declared import price/ tariff bill ... 1/

The term of art appears to be "unbundling" -- that is reducing the price at customs by changing the "bundle" of goods and services that is formally exchanged between a company's Irish sub and its US sales sub 2/

Unbundling seems to have the same economic effect as a change in the transfer price, but it is easier to square with transfer pricing rules ... so to me (but not the tax and supply chain pros in Ireland) it is pretty much the same thing ... 3/

Good article. It will be interesting to see how quickly "product prices" at customs (and thus the tariff base) adjust ... (though calculation will be complicated by the unwind of the inventory build) 4/4