KHC · 10-Q · 2026Q3 · Full report

IRS Transfer Pricing Investigation

Kraft Heinz Co · 2026-11-04 · Importance 40 · Surprise 42

The IRS is examining Kraft Heinz’s income taxes for 2018 through 2022 and issued transfer-pricing Notices of Proposed Adjustment concerning transactions with foreign subsidiaries. The notices propose increases to U.S. taxable income and assert penalties, but the filing’s dollar amounts for potential tax liabilities and penalties are not provided in the supplied text. Kraft Heinz said it has recorded no reserves, continues to use the same operating model and transfer-pricing methodology, and intends to contest the IRS positions. The company said the ultimate outcome is uncertain and that required additional taxes, interest, or penalties could materially affect results and cash flows.

Key facts

• Kraft Heinz Co is under IRS examination for income taxes for 2018 through 2022 and received two transfer-pricing NOPAs in 2023 relating to 2018 and 2019. source
• Kraft Heinz Co received two IRS NOPAs in 2025 for tax years 2020 through 2022 concerning transfer pricing with its foreign subsidiaries. source
• Kraft Heinz Co strongly disagrees with the IRS transfer-pricing positions, intends to contest them through available administrative and judicial remedies, and has recorded no reserves for the issue. source
• Kraft Heinz Co says an adverse IRS transfer-pricing outcome requiring additional U.S. taxes, interest, or penalties could materially affect its results of operations and cash flows. source