⚠ The IRS Questions the Transfer PricesModerate threat

UnitedHealth Group (UNH) — threat to the moat

The IRS says UnitedHealth's prices between its own businesses understated taxable income in 2017-2020, and it has not yet said by how much.

When one part of a company sells to another, the price is set internally, and tax authorities can disagree with it. On 6 March 2026 UnitedHealth received Notices of Proposed Adjustment from the Internal Revenue Service on the transfer pricing of its 2017 to 2020 tax years, "seeking to significantly increase taxable income"1. No amount has been disclosed.

Effective tax rate (%)20.5%202324.1%202412.9%2025about 18.5%2026 guideUnitedHealth Group Form 10-K FY2025; Q2 2026 results release
A tax rate that swings by eleven points.

The company's tax rate has already moved a great deal: 20.5% in 2023, 24.1% in 2024 and 12.9% in 20252, with about 18.5% guided for 20263. A group that routes $168 billion of sales between its own segments4 has many prices for an auditor to question.

The immediate risk is a tax bill for past years. The longer one is that the internal prices that make Optum look profitable could be judged too generous.

The years in question predate much of the recent growth in internal sales. Corporate eliminations were $90,867 million in 20215 and $167,956 million in 20256, so the pricing framework under review now covers far more money than it did in 2017 to 2020.

The disclosure to watch is any amount attached to the notices in a future 10-Q. A figure large relative to a year's $12,056 million of net earnings7 would turn an accounting question into a real cost.

References
  1. ReportedOn 6 March 2026 UnitedHealth received Notices of Proposed Adjustment from the Internal Revenue Service on the transfer pricing of its 2017 to 2020 tax years, "seeking to significantly increase taxable income".
    UnitedHealth Group Form 10-Q for the quarter ended 30 June 2026 - segment note on the 2026 basis, share repurchases, legal matters and the IRS notices. — Q2 2026 · publ. 10 August 2026 · source ↗
  2. ReportedThe company's tax rate has already moved a great deal: 20.5% in 2023, 24.1% in 2024 and 12.9% in 2025, with about 18.5% guided for 2026.
    UnitedHealth Group Form 10-K for fiscal 2025 - financial statements and notes: segment note, CMS concentration, balance sheet, cash flow and capital. — FY2025 · publ. 2 March 2026 · source ↗
  3. ReportedThe company's tax rate has already moved a great deal: 20.5% in 2023, 24.1% in 2024 and 12.9% in 2025, with about 18.5% guided for 2026.
    UnitedHealth Group second-quarter 2026 results release, Form 8-K exhibit 99.1 - consolidated results, medical care ratio, cash flow, balance sheet and the raised 2026 outlook. — Q2 2026 · publ. 16 July 2026 · source ↗
  4. ReportedA group that routes $168 billion of sales between its own segments has many prices for an auditor to question.
    UnitedHealth Group Form 10-K for fiscal 2025 - financial statements and notes: segment note, CMS concentration, balance sheet, cash flow and capital. — FY2025 · publ. 2 March 2026 · source ↗
  5. ReportedCorporate eliminations were $90,867 million in 2021 and $167,956 million in 2025, so the pricing framework under review now covers far more money than it did in 2017 to 2020.
    UnitedHealth Group Form 10-K for fiscal 2023 - segment revenue including affiliated revenue for 2021-2023, Optum Rx scripts for 2022-2023, and CMS premium revenue as a share of revenue for 2021-2023. — FY2023 · publ. February 2024 · source ↗
  6. ReportedCorporate eliminations were $90,867 million in 2021 and $167,956 million in 2025, so the pricing framework under review now covers far more money than it did in 2017 to 2020.
    UnitedHealth Group Form 10-K for fiscal 2025 - financial statements and notes: segment note, CMS concentration, balance sheet, cash flow and capital. — FY2025 · publ. 2 March 2026 · source ↗
  7. ReportedThe disclosure to watch is any amount attached to the notices in a future 10-Q. A figure large relative to a year's $12,056 million of net earnings would turn an accounting question into a real cost.
    UnitedHealth Group Form 10-K for fiscal 2025 - financial statements and notes: segment note, CMS concentration, balance sheet, cash flow and capital. — FY2025 · publ. 2 March 2026 · source ↗
Sources
Generated September 26, 2026