Blog

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Blog

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Blog

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Blog

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Blog

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Why you should download

Why you should watch

Transfer Pricing Strategy and Insights from Aibidia's Report

20.3.2024
In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.


The report, brought to life through a recent webinar featuring speakers Raphaël Barelli Schaefer from Yanfeng International, Samit Shah from Grant Thornton US, and Borys Ulanenko, Advisor to Aibidia and founder of ArmsLength AI, dives deep into the state of transfer pricing practices across various sectors.

Some of the key trends and observations discussed in the webinar are presented below.

Diverse Team Structures Reflecting Company Complexity

The survey highlights diverse approaches in structuring transfer pricing teams, revealing a common trend towards small, focused teams within larger organizations. However, a business's complexity and global reach significantly influence the team's size and structure, impacting how transfer pricing processes are managed internally.


Operational Challenges and Technological Solutions in Data Management

A critical insight from the report is the challenge companies face in managing transfer pricing data. With many relying on manual processes because of data spread across disparate systems, there's a clear move towards integrating technology to streamline operations and improve accuracy.

Webinar speakers also discussed the ubiquitous struggle with data management, emphasizing the ongoing transition towards robust ERP systems to consolidate data handling. Although challenging, this transition is vital for improving operational efficiency in transfer pricing processes.


The Shift Towards Specialized Software

The adoption of technology in transfer pricing processes is on the rise, yet nearly half of the surveyed companies still rely on traditional tools like Excel and Word for their transfer pricing needs. The trend, however, is leaning towards specialized software and comprehensive platforms, signaling a shift towards more sophisticated, automated solutions for transfer pricing documentation and operational efficiency.


The Increasing Intensity of Audits

With increasing scrutiny from tax authorities, companies report spending significant resources on transfer pricing audits. This underscores the importance of robust documentation and proactive risk management strategies to navigate the complex audit landscape effectively.

The webinar speakers touched on the increasing complexity of audits and the essential role of comprehensive and proactive preparation in navigating these challenges effectively. The discussion also covered strategies for managing tax authority scrutiny's escalating demands and complexities.


The Future is Digital and Data-Driven

As we move forward, the role of technology in transforming transfer pricing practices cannot be overstated. With regulatory requirements and the global tax landscape continuously evolving, companies must adapt to maintain compliance and optimize their transfer pricing strategies.

The insights from Aibidia's 2024 Report offer a roadmap for companies looking to benchmark their practices against industry standards and explore how technology can be leveraged to enhance their transfer pricing processes. To dive deeper into these findings and download the full report here.

We thank Raphaël Barelli Schaefer, Samit Shah, and Borys Ulanenko for their expert insights during the webinar.

To watch the full webinar, click here.

Meet the authors

Author
Borys Ulanenko
Advisor to Aibidia and ArmsLength AI founder

Borys Ulanenko is a Digital Transfer Pricing Expert. Borys has more than 10 years of experience in transfer pricing, with a background in industry and consulting. In addition to advising Aibidia, Borys is the founder of the educational platform StarTax Education and the AI-driven solution ArmsLength.ai.

Borys is passionate about sharing his knowledge and experience with others. He loves explaining complex transfer pricing concepts in simple words and sharing his expertise with Aibidia and the tax community. He sees his mission in demystifying transfer pricing and making this exciting area of international tax available to everyone.

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REPORTS

Transfer Pricing Strategy and Insights from Aibidia's Report

In the rapidly evolving world of transfer pricing, staying ahead means understanding the broader landscape of industry practices and technological advancements. Aibidia's 2024 Report, grounded in a survey of over 100 organizations, offers unique insights into how companies adapt their transfer pricing strategies to meet today's challenges and tomorrow's opportunities.

Hereʼs Why You Should Get the Report

0

See how peers are adapting to global change

Understand how 140+ MNEs and advisory firms are responding to shifting regulations, heightened audit scrutiny, and technology-driven change, and where your approach stands in comparison.

0

Learn how others are driving compliance

Explore the approaches to resourcing, data management, and operational transfer pricing that teams are using to tackle growing workloads.

0

Identify emerging trends shaping the profession

Gain insight into how AI, automation, and operating models are redefining transfer pricing, so you can plan for the skills, tools, and processes youʼll need next.

Insights

What youʼll learn inside the Aibidia report 2025

The rising cost of tax scrutiny
01

The rising cost of tax scrutiny

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.

02

The state of OTP maturity

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.

03

The importance of structured data

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.

04

Technology and AI adoption in practice

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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Expert insights

Structured, reliable data is essential for executing a consistent, defensible transfer pricing strategy. Common barriers to structured data include siloed legacy source systems, unclear data ownership, and inconsistent definitions across entities and functions.

Prasad Parwidala
Head of Professional Services, Aibidia
Read the case study

We see significant variation in OTP maturity across companies. In many cases, if existing processes appear to work, there’s less motivation to change. However, where we see this changing, is within MNEs that have faced increased scrutiny or operate with more complex structures.

Pia Honkala
Global Commercial Head - Operational Transfer Pricing, Aibidia
Read the case study

While there are many challenges in accessing the right data for TP calculations and analysis, one of the most significant barriers to OTP adoption can be the misalignment of KPIs between Finance and Tax teams.

Marlon Manto
Director, Transfer Pricing Advisory, Aibidia
Read the case study

We’re seeing practical AI adoption in areas such as navigating country-specific documentation requirements, researching transfer pricing methods, comparing jurisdictional rules, and tracking global compliance timelines.

Maria Helander
VP Product, Aibidia
Read the case study