Aibidia's annual industry report explores how transfer pricing professionals are responding to rising audit scrutiny, operational complexity, fragmented data environments, and the growing role of AI. Join the waitlist to be first to know when it launches, or explore insights from the 2025 edition while you wait.
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Compare your team's approach against how transfer pricing professionals worldwide are responding to rising audit scrutiny, operational complexity, and the growing role of AI.
The report captures how transfer pricing professionals are working in practice, from audit readiness and operational maturity to data management and AI adoption.
Heightened tax authority demands are driving up the time and money TP teams spend on audits. Companies with stronger documentation processes, centralised data, and proactive OTP practices are better positioned to contain both costs and risk.
Only 35% of companies have a well-defined OTP process, while 24% have none at all. Barriers to OTP maturity include poor data access, complex business models, and limited coordination between tax, finance, and IT.
With 72% of companies in fragmented data environments, the report shows how centralised data helps TP teams insource more processes, ensure consistent compliance, and handle audits more efficiently.
42% of MNEs are investing in specialist software, reducing reliance on traditional tools. AI interest is steady rather than explosive, hinting that TP teams need clean, structured data before advanced analytics can add value.
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138 professionals share how their transfer pricing functions operate today, from data sourcing and audit pressure to AI readiness.
Get the reportTransfer pricing has always been complex. What is changing is the nature of that complexity.
For years, the challenge for multinational tax teams was largely one of compliance: setting appropriate policies, documenting them, and demonstrating that the organization had met its obligations.
That challenge has not disappeared. But it is being joined by something much bigger.

Transfer pricing has always been complex. What is changing is the nature of that complexity.
For years, the challenge for multinational tax teams was largely one of compliance: setting appropriate policies, documenting them and demonstrating that the organization had met its obligations.
That challenge has not disappeared. But it is being joined by something much bigger.
Today's transfer pricing teams operate across increasingly complex global businesses, fragmented systems and enormous volumes of information. They are expected to monitor outcomes, respond to changing regulations, defend positions under scrutiny and increasingly demonstrate how transfer pricing decisions connect to the wider financial performance of the business.
At the same time, expectations are rising.
Tax authorities have greater access to data and increasingly sophisticated ways of analyzing it. Technology is enabling greater automation and scrutiny, increasing the potential exposure of organizations that may previously have attracted less attention. Finance leaders expect greater visibility and control. And advances in AI are changing expectations around how quickly organizations should be able to understand information and act upon it.
The findings in this year's State of Transfer Pricing research bring this tension into sharp focus.
Some of the world's largest and most sophisticated tax functions are experiencing extraordinary levels of audit activity. Teams continue to spend significant amounts of time gathering and reconciling data. Critical transfer pricing processes still depend heavily on spreadsheets, email and manual intervention. And while enthusiasm for AI is growing rapidly, many organizations recognize that the information required to power it remains fragmented across documents, systems and teams.
This reveals an important distinction.
The industry does not have an information shortage. It has a context problem.
The policies exist. The agreements exist. The financial data exists. The documentation exists. The organizational knowledge exists.
But these pieces rarely exist as one connected, continuously understandable picture of the transfer pricing environment.
The result is a growing gap between the amount of transfer pricing information organizations possess and their ability to understand what it means, identify what matters and act upon it.
We think of this as the Transfer Pricing Intelligence Gap.
Technology has already transformed transfer pricing once. Individual processes that were once overwhelmingly manual have progressively been digitized and automated. We have become better at producing documentation, performing calculations, monitoring outcomes and conducting research.
But these capabilities have largely evolved independently.
The next stage will be different.
It will be about connecting those activities, and the knowledge behind them, so that the transfer pricing function can understand its environment as a whole.
Imagine a transfer pricing function where the organization can understand not only what its policy says, but how that policy relates to its agreements, entities, transactions, financial outcomes and regulatory obligations. Where emerging risks and opportunities can be identified across the entire estate. Where every conclusion can be traced back to the evidence supporting it. And where AI can reason across that context rather than simply search individual documents or datasets.
That is a fundamentally different way of thinking about transfer pricing technology.
It represents a shift from information to intelligence.
The findings in this report suggest that the conditions for that change are now emerging.
The organizations represented here are not being asked for less sophistication from transfer pricing. They are being asked to manage more complexity, under greater scrutiny and at greater speed.
The question facing our industry is therefore no longer simply how we make today's transfer pricing processes more efficient.
It is what the transfer pricing function should look like when all of its knowledge can finally work together.
We believe answering that question will define the next era of transfer pricing.
An era that moves beyond the digitization of individual workflows towards Transfer Pricing Intelligence: the ability to connect the knowledge of the transfer pricing estate, understand what it means and turn that understanding into better decisions.
Hannu-Tapani Leppänen
Co-founder & CEO, Aibidia

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Tax authorities have more data and far better analysis. Finance leaders expect unprecedented visibility. AI is raising expectations for speed across the board. Yet, the foundations of operational transfer pricing remain fragmented.
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