Transfer pricing in the AI age: New tools, same rules for now

AI is quickly becoming part of how multinational enterprises run HR, finance, regulatory affairs and R&D. But does putting AI into the value chain change how those activities should be characterized and priced?

In this whitepaper, Aibidia’s Prasad Pardiwala and Katheryn Weiller work through four examples from a multinational pharmaceutical group, from an HR chatbot to proprietary AI for drug discovery. They show why the transfer pricing outcome depends on each group member’s economic contribution, not on the fact that AI is involved.

What you’ll learn:

• How the OECD Guidelines apply to AI-related services, intangibles and highly integrated contributions
• When AI development may justify a non-routine return, and when it won’t
• Wider tax issues to watch, from business restructurings and cost-plus erosion to Pillar Two substance
• Five practical actions for heads of tax and transfer pricing