Carol Lynch, Tax Partner and Head of Customs and International Trade, BDO: The last year has been a very challenging time for businesses with trade disputes and the introduction of new US tariffs being an almost constant feature. A particular challenge in this regard for Irish Exporters was the constant amendment and changes to the application of tariffs on steel products and derivatives being imported into the US.

Alongside this there have also been misgivings aired by many in the European Parliament about the EU-US deal agreed last year (the Turnberry agreement). Finally however, in the early hours of Wednesday 20th May the European Parliament and Member States reached a compromise agreement which should enable the Turnberry agreement (agreed last summer) to enter into force. It is expected that this will pave the way for enactment late June, and before the Trump deadline of 4th July (where he has threatened to impose further tariffs if the deal is not in place).

A new input into the agreement by the Parliament however allows the Commission to suspend the implementation of the preferential tariff rates for US imports if the Trump Administration fails to remove steel and aluminium tariffs above 15% by the end of 2026. If successful this will be welcome news for exporters. Along with this a “sunset clause” has been introduced which will allow the deal to expire on 31 December 2029.

Even with this deal finally legally coming into force this is unlikely to eliminate uncertainty and cost pressures. There continues to be uncertainty over the legality of both new US tariffs under section 122 and 301 respectively, for example there has been successful challenges to the current Section 122 tariffs (balance of payments) following the invalidation of the previous IEEPA tariffs by the courts.

As a result, there is likely to be increased uncertainty over the next few months for businesses which makes planning ahead and pricing extremely difficult for exporters. Therefore, we propose a series of recommendations to help businesses navigate this complex business environment:
Cost and tariff analysis should be a priority. Businesses need to assess how different tariff scenarios impact margins and competitiveness, and in many cases, adopt pricing strategies that assume elevated tariffs will continue. Critical steps include ensuring accurate tariff classification of products, confirming origin rules, and - where relevant - understanding requirements such as the “melt and pour” origin rules for steel. Businesses should also explore whether any reliefs apply, such as for US origin goods returning, and review intercompany pricing arrangements to ensure duties are calculated on optimised, compliant values.

Diversification is equally important. Companies should examine opportunities to expand into alternative markets, particularly those covered by EU free trade agreements, where tariffs may be reduced or eliminated. Recent agreements with regions such as Mercosur, India, and Australia highlight the EU’s continued commitment to facilitating trade despite a more protectionist global landscape.

Finally, businesses should leverage available supports. Irish companies may be eligible for funding through Enterprise Ireland, including grants for market research and development of new export strategies. These supports can help offset the costs of analysing tariff exposure and entering new markets.

Arthur Gaskin, Tax Counsel, Ogier: The current strain in EU–US trade relations reflects a deeper structural shift rather than a temporary diplomatic impasse. Although the July 2025 EU–US framework agreement was intended to restore predictability by capping most tariffs at 15%, repeated US threats to raise tariffs - particularly on auto-mobiles to 25% - have exposed the fragility of that settlement. For businesses, the core reality is that transatlantic trade is now subject to recurring political leverage, unilateral action, and implementation disputes. As a result, uncertainty must be treated as a standing operating condition, not a passing phase.

A central lesson for companies is the need to move away from highlevel country exposure analysis and toward productspecific assessment. Tariff risk increasingly turns on individual HS codes, sector carveouts, and overlapping regimes such as US national security (Section 232) tariffs and potential EU countermeasures. This fragmentation means that two products shipped by the same company can face dramatically different trade outcomes. Conducting granular audits of tariff exposure by product line is therefore essential for sound pricing, sourcing, and investment decisions.

Customs and trade planning have simultaneously evolved from compliance exercises into strategic management tools. Lawful tariff engineering—through origin analysis, valuation choices, and use of customs relief mechanisms—can materially reduce or defer duty costs. These tools allow businesses to cope with volatility without resorting immediately to costly restructurings of global supply chains. In the present climate, firms that underinvest in customs strategy are likely to absorb avoidable costs that more agile competitors mitigate.

At the same time, businesses should resist the false binary between full reshoring and maintaining the status quo. Political signals from Washington increasingly favour domestic US production, but wholesale relocation is rarely costeffective or operationally realistic. More nuanced approaches—such as partial localisation, finalstage assembly in the US, or selective joint ventures—can reduce tariff exposure while preserving supplychain flexibility and capital discipline.

Market diversification has also become more strategically important. While the EU–US corridor remains indispensable, overreliance on it amplifies political risk. Firms should accelerate exploitation of EU free trade agreements with other partners and rebalance export portfolios where possible toward jurisdictions with greater regulatory stability. This is less about exiting the US market than about restoring optionality and bargaining power.

Engagement with policymakers is another underappreciated lever. EU countermeasures, safeguard clauses, and anticoercion tools are not automatic; they are shaped through consultation and political choice. Companies that engage early—individually or via trade bodies—have a better chance of influencing how retaliation is targeted and how collateral damage is distributed across sectors.

Finally, contractual and governance frameworks must catch up with trade reality. Commercial agreements that lack tariff reopener clauses and clear riskallocation mechanisms expose firms to sudden margin shocks. Transparent communication with investors and customers about tariff exposure and contingency planning is equally critical, as markets increasingly price geopolitical risk into valuations.

In short, the overriding strategic shift is from pursuing trade stability to managing trade flexibility. The EU–US relationship remains economically vital but is now politically contingent. Businesses that embed flexibility into sourcing, contracts, customs planning, and market strategy will be better placed to withstand further escalation, regardless of whether current tensions subside or intensify.

Deirdre Barnicle, Partner, McCann FitzGerald: Since the February ruling of the US Supreme Court, which declared Trump’s “liberation day” tariffs to be unconstitutional, European companies have begun the process to seek rebates on tariff costs incurred. Meanwhile, the White House Administration swiftly imposed a new blanket levy that was also held to be unlawful by the US Court of International Trade (a specialised federal court in New York). What emerges as evident from the chaos, is that external market uncertainty will remain a prominent feature for businesses trading with the US, as long as the strategy of US protectionism is pursued.

Brexit has given Ireland experience in the crossfire of trade disputes. A key learning from that period is that internal hesitancy in response to or anticipation of external threats, may harm businesses as much as any tariff itself. Proactivity is needed to mitigate this internal uncertainty as soon as possible. Businesses need to conduct scenario modelling to understand where their dependencies are and insulate themselves from any unpredicted changes by diversifying their supply chain where possible. Where exposure exists, companies should be cognisant of the cash flow pressure that often accompany tariffs due to the delays and unexpected nature of the costs.

This article appeared in the May 2026 edition of the Irish Tax Monitor.