TPMinds International 2026 brought together tax authorities, policymakers, in-house tax leaders and advisors from around the world to discuss the issues shaping the future of transfer pricing.

The two days of discussion showed how transfer pricing is becoming increasingly interconnected with broader business strategy, technology, governance and global policy developments.

Below are the five themes that stood out most strongly.

1. Transfer Pricing Is Becoming a Strategic Business Function

Historically, transfer pricing was often viewed as a compliance requirement focused on documentation and defending tax positions, but that mindset is rapidly changing.

Throughout the conference, speakers highlighted how transfer pricing now sits at the center of major business decisions, including supply chain transformation, operating model design, customs planning, global mobility, business restructuring and geopolitical risk management.

The challenge facing organizations is no longer simply maintaining compliance but ensuring that transfer pricing outcomes align with how value is genuinely created across the organization.

2. AI Is Transitioning from Concept to Practical Tool

Artificial intelligence dominated discussions throughout TPMinds, but the focus has shifted decisively from theory to practice. Organizations are already deploying AI across the transfer pricing function: automating benchmarking exercises, preparing contemporaneous documentation, reviewing intercompany agreements, monitoring operational outcomes, and flagging audit risks in real time.

One particularly interesting example involved the use of multi-agent AI workflows capable of reviewing legal, transfer pricing, VAT, and withholding tax implications simultaneously before producing draft agreements.

However, speakers were unanimous on one point: AI enhances expertise but does not replace it. Data quality, governance, and human oversight remain fundamental to successful implementation.

3. Pillar Two Has Become an Operational Challenge

While Pillar Two dominated policy discussions in recent years, TPMinds highlighted how attention has now shifted towards implementation.

Businesses shared experiences of redesigning reporting processes, adapting ERP systems, building data collection frameworks, and preparing for ongoing compliance obligations.

A recurring theme was the scale of effort required relative to the tax outcomes generated. Many organizations reported significant compliance work even in situations where no top-up tax liability ultimately arises.

As Pillar Two continues to mature, businesses are increasingly calling for greater simplification, standardization and consistency across jurisdictions.

4. Tax Certainty Is Increasing in Importance

A notable shift across many sessions was the growing emphasis on certainty. As audit activity increases and international tax rules continue to evolve, organizations are investing more heavily in dispute prevention and risk management strategies.

Discussions around APAs, MAPs and controversy management reflected the common goal to reduce uncertainty and mitigate double taxation.

Several speakers also stressed the importance of preparing for disputes long before they arise. Strong governance, contemporaneous evidence, and audit-ready documentation are becoming essential components of effective transfer pricing management.

5. Transparency Is Reshaping Expectations

The rise of public Country-by-Country Reporting and broader tax transparency initiatives is changing how organizations communicate tax information.

Investors, regulators and other stakeholders increasingly expect businesses to explain not only where tax is paid, but also how value is created and how tax outcomes align with commercial activity.

A particularly interesting theme was the growing overlap between tax, ESG reporting, investor relations, and corporate governance. Tax transparency is no longer viewed as a standalone compliance issue but as part of a wider stakeholder communication strategy.

Looking Ahead

Perhaps the most important conclusion from TPMinds International 2026 is that transfer pricing is no longer operating in isolation.

Technology, geopolitics, supply chain disruption, transparency requirements, global mobility and international tax reform are increasingly influencing transfer pricing outcomes.

For businesses, success will depend on more than technical compliance. It will require strong data foundations, effective technology adoption, proactive risk management, and close collaboration across tax, finance, legal and operational teams.

As the global tax landscape continues to evolve, the organizations that can combine technical excellence with strategic agility will be best positioned to navigate the challenges ahead.

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