UnitedHealth Group Incorporated confirmed in its 2026 quarterly reports that it is disputing Transfer Pricing adjustments proposed by the U.S. Internal Revenue Service (IRS). The dispute was initially disclosed in its Form 10-Q filed in May 2026 and subsequently reiterated in August. The adjustments relate to how the company determined the prices of certain transactions with a foreign subsidiary during fiscal years 2017 through 2020.
What is at stake?
According to information disclosed by UnitedHealth, on March 6, 2026, the IRS issued Notices of Proposed Adjustment (NOPAs) proposing to significantly increase the company’s taxable income for each of the fiscal years from 2017 to 2020. The company also notes that the tax authority could propose similar adjustments for subsequent fiscal years.
To date, the specific amount of the adjustments, the identity or location of the foreign subsidiary involved, or the exact nature of the transactions in question have not been publicly disclosed.
UnitedHealth maintains that its tax positions are adequately supported and has stated its intention to vigorously challenge the proposed adjustments using all available administrative and judicial remedies. The company has also noted that it considers its reserves related to uncertain tax positions to be adequate based on currently available information.
A Pattern of Disputes Among Large U.S. Multinationals
UnitedHealth’s dispute joins other high-stakes transfer pricing disputes between the IRS and U.S. multinationals.
The beverage giant’s dispute could end up costing approximately $20 billion in taxes and interest. Coca-Cola has already paid the IRS $6 billion for fiscal years 2007 through 2009 while its appeal is pending, and estimates that it could face approximately an additional $14 billion in taxes and interest for the 2010–2025 period if the IRS’s adjustments, as upheld by the Tax Court, are upheld. Its reserves totaled $529 million as of July 3, 2026.
Meta is also involved in a significant dispute with the U.S. tax authority. The company is contesting approximately $15,890 million in additional taxes, plus interest and penalties, for the 2017–2019 tax years, primarily related to Transfer Pricing and international taxation issues.
Why can these disputes drag on for years?
In general, Transfer Pricing disputes of this magnitude can go through various administrative and judicial stages before reaching a final resolution. When there is no agreement between the taxpayer and the IRS, the dispute may lead to administrative proceedings and subsequently to litigation in U.S. courts.
During this process, the proposed adjustments may create uncertainty regarding the company’s tax position. Depending on the course and outcome of the dispute, there could also be effects on the provisions related to uncertain tax positions, the income tax expense, and the reported effective tax rate in future fiscal years.
In the case of UnitedHealth, the company has stated that it considers its current provisions to be adequate based on the available information.
What Does the UnitedHealth Case Mean for Multinational Groups?
The cases involving Coca-Cola, Meta, and now UnitedHealth demonstrate the continued significance of international transactions between related parties within the scope of the IRS’s tax audits.
However, there is one important difference: in the UnitedHealth case, the specific type of transaction being challenged has not yet been publicly disclosed. Therefore, it is not currently possible to determine whether the dispute relates to intangibles, intra-group services, financing, risk allocation, or another type of intercompany transaction.
Regardless of the specific nature of the transaction, the case underscores the importance for multinational groups to maintain up-to-date documentation that demonstrates their related-party transactions reflect the economic reality of the business and that the allocation of functions, assets, risks, and results is properly supported.
For groups with operations between the United States and other jurisdictions, this means not only having formal Transfer Pricing documentation but also ensuring consistency among intercompany contracts, the functional analysis, the actual conduct of the parties, and the economic evidence used to determine each entity’s remuneration.
At TPC Group, we assist multinational groups with operations between the United States and other jurisdictions in evaluating their Transfer Pricing policies and documentation, strengthening the functional analysis and economic rationale of their intercompany transactions in the face of potential challenges from tax authorities.
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