6 Top Insights from TP Minds 2025: What’s Next for Transfer Pricing?

“AI won’t steal you job, but someone who uses AI will.”

This memorable quote from the AI panel this year from TP Minds 2025 (courtesy of Tom Nuorivaara, Head of AI and Design at Aibidia), summed up a key theme at TP Minds this year.

As the transfer pricing landscape evolves, so does the conversation around how businesses manage it. At TP Minds International, the global TP community gathered to explore how regulation, technology, and data are shaping the future. Here are our top six takeaways from the event.

1. Operational TP is Becoming Strategic

Operational TP (OTP) dominated discussions, with many businesses acknowledging their continued reliance on manual processes. However, more companies increasingly see OTP not just as a compliance requirement, but as an enterprise-wide journey impacting everything from strategic planning to supply chain optimisation and financial reporting. This positions OTP as a business-critical process that requires a change management piece alongside technology. In other words, technology will not be a quick fix as business alignment needs to happen across, process, people, and data.

And while the recognition for this is growing, many companies are still tied down by manual work relying primarily on Excel (30% of MNEs according to the upcoming 2025, Aibidia Report). It comes as no surprise that the shift from reactive compliance to proactive, tech-enabled TP requires rethinking OTP as a long-term journey; one that calls for integration, automation, and cross-functional alignment

2. Data Still a Bottleneck

A recurring challenge discussed was the fragmented nature of data that is spread across systems, teams, and business. It’s no surprise that organisations continue to struggle with siloed systems and a lack of a unified data source. This lack of a “single source of truth” causes challenges when it comes to data accuracy, efficiencies, and slows down any automation process.

Aibidia’s own findings in our annual report confirm this, data quality and integration remain foundational hurdles for successful TP transformation. 44% of MNEs listed their core challenge as a difficulty in gathering timely, high-quality TP data.

3. Pillar Two: A Call for Caution

Pillar Two’s implementation was another hot topic, particularly in light of recent developments in the U.S. There is growing sentiment that a pause may be needed as the complexity of achieving global consistency, along with ongoing political and technical challenges, raises concerns about feasibility and fairness. Many TP champions are urging policymakers to take a step back and reassess before moving forward.

4. The Emergence of AI in TP

AI made a strong entrance into TP conversations. Practical use cases are beginning to surface, particularly in research areas like benchmarking and document drafting. Tools like TP Aurora are clear examples of how generative AI can assist in streamlining TP tasks. However, as emphasised during a panel featuring Aibidia’s Tom Nourivaara, AI is a powerful co-pilot, not a replacement. Gen AI can get you 80% of the way, but human expertise remains essential to ensure accuracy and context.

5. Surge in TP Tech Solutions

We’re seeing a wave of innovation across the TP tech landscape. From interest rate benchmarking tools to automated documentation platforms and holistic OTP systems, technology is rapidly reshaping how TP functions are managed. These developments are not only improving efficiency, but also enabling better strategic alignment with business objectives

6. OECD Guidelines Revision in Progress

The OECD is currently working on a revised edition of the Transfer Pricing Guidelines. Updates are expected to offer clearer, more practical guidance, particularly in Chapter VII (intra-group services). Of special interest are the implications of globally mobile workforces and how their taxation will impact TP policy. These updates reflect a broader effort to modernise the TP framework in line with today’s economic realities.

Final Thoughts

TP Minds made one thing clear: the transfer pricing function is at an inflection point. Businesses are reimagining OTP, cautiously navigating Pillar Two, and embracing AI and tech solutions, all while preparing for regulatory change.

At Aibidia, we see this as an exciting moment to lead with innovation and support companies on their journey toward smarter, more strategic transfer pricing.