EXPE · 10-Q · 2026Q3 · Full report

IRS Transfer Pricing Audits

Expedia Group, Inc. · 2026-11-05 · Importance 71 · Surprise 60 · No source text

In the third quarter of 2026, the IRS replaced its prior transfer-pricing adjustments for tax years 2011–2016 with new proposed adjustments using a different method, and also issued proposed adjustments for 2017–2018. The proposed federal income tax amounts are approximately $287–$313 million for 2011–2013, $488–$531 million for 2014–2016, and $213–$380 million for 2017–2018, all subject to interest. Expedia disputes the adjustments and says it will defend its position through administrative procedures; the IRS indicated the matter is not relevant to tax years 2019–2020.

Key facts

• The IRS’s proposed transfer-pricing adjustments imply federal income tax of approximately $287–$313 million for 2011–2013, $488–$531 million for 2014–2016, and $213–$380 million for 2017–2018, plus interest; Expedia Group disagrees and will defend its position through administrative procedures. source
• In Q3 2026, the IRS replaced prior adjustments and issued new transfer-pricing adjustments for tax years 2011–2016 using a different method, and also issued adjustments for 2017 and 2018. source
• For tax years 2011–2013 and 2014–2016, prior IRS transfer-pricing adjustments would have resulted in federal income tax of approximately $244 million and $431 million, respectively, plus interest. source
• The IRS indicated its transfer-pricing adjustments are not relevant for tax years 2019–2020. source

Impact estimates