ZBH · 8-K · 20260805PR335108

IRS Transfer Pricing Dispute

ZIMMER BIOMET HOLDINGS, INC. · 2026-08-05 · Importance 40 · Surprise 42 · In source text

The IRS proposed adjustments for tax years 2013–2015 concerning transfer pricing under the cost-sharing agreement between Zimmer Biomet’s U.S. and Swiss affiliates and the reallocation of profits between U.S. and foreign subsidiaries. The IRS also proposed adjustments for tax years 2016–2019 related primarily to the U.S. taxation of foreign earnings and profits. The latter matter would increase U.S. federal taxable income and create approximately $312 million of additional tax expense, plus interest, if Zimmer Biomet is unsuccessful. The company intends to contest both matters through administrative and, if necessary, judicial remedies; no payment is currently required before proceedings conclude.

Key facts

• The IRS has proposed adjustments for tax years 2016-2019 related to U.S. taxation of foreign earnings and profits which could result in tax expense of approximately $312 million, subject to interest, if the company is unsuccessful in defending its position. source
• The IRS has proposed adjustments for tax years 2013-2015 related to transfer pricing and reallocation of profits between U.S. and foreign subsidiaries; no payment required until proceedings completed and company intends to vigorously contest adjustments. source

Impact estimates