Transfer Pricing Top Priorities for 2026

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A Year of Reinforcement, Readiness, and Realignment

As transfer pricing teams look ahead to 2026, the message from the Aibidia Report 2025: The State of Transfer Pricing is unmistakable, resilience is the new currency.

With audits intensifying, global rules evolving, and technology capabilities catching up to ambition, transfer pricing leaders are no longer asking what’s changing, but how prepared are we to face it?

Drawing on insights from 145+ professionals worldwide, the report highlights five clear priorities that will continue to shape the transfer pricing agenda in 2026. Each priority comes with a percentage; this percentage represent how many TP professionals listed it as their number 1 priority in this year’s research.

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1. Strengthening Audit Defense Strategies (31%)

The undisputed top priority is audit defense - a direct response to the rising cost and complexity of scrutiny.

More than half of MNEs now spend between 50-200 hours per audit, and nearly one in four spends over $500k defending transfer pricing positions.

“Audit defense has become a cost, capacity and capability issue. The data shows preparedness hasn’t caught up with risk, but it can. Structured data, centralized & robust documentation, and proactive risk management are now the real shields against escalating disputes.” - Prasad Pardiwala, Head of Professional Services, Aibidia.

With three in four professionals expecting disputes to increase further, audit defense isn’t just a compliance function, it’s becoming a core strategic discipline.

Implication: Audit defense is no longer reactive compliance, it’s strategic risk management.

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2. Enhancing Operational Transfer Pricing (OTP) (21%)

As scrutiny grows, attention is shifting from documentation to execution. Only 35% of companies report having a well-defined OTP process and most still rely on year-end true-ups or manual adjustments.

Teams are now focused on tightening the connection between policy, data, and actual transactions throughout the year.

“Operational Transfer Pricing is where tax meets the business. The maturity gap we’re seeing isn’t about awareness, it’s about execution. The next wave of progress will come from collaboration between finance, tax, and IT, underpinned by on-time data visibility.” - Pia Honkala, Global Commercial Head, Operational Transfer Pricing, Aibidia.

OTP maturity has become a hallmark of control, not just over pricing, but over operational risk itself.

Implication: OTP maturity = control, accuracy, and audit defensibility.

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3. Implementing Pillar Two (19%)

Despite political uncertainty surrounding global adoption, Pillar Two remains firmly on the radar.

As many MNEs progress through Pillar Two readiness, one point is becoming unmistakable: the interplay between operational TP and Pillar Two cannot be ignored. Accurate, well-governed TP calculations form a critical foundation of the GloBE computation.

“Even with geopolitical turbulence, the principles driving Pillar Two, transparency, data integrity, and real-time reporting, are here to stay. Efficient operational TP, clearly defined cross-functional data flow processes, and aligned roles across tax and non-tax teams have become essential. Tax and TP teams that adapt early will find themselves better equipped for whatever form the next regulatory wave takes.” - Prasad Pardiwala, Head of Professional Services, Aibidia.

The focus for 2026 is less about reacting to new rules, and more about building readiness into the core architecture of tax operations.

Implication: Pillar Two readiness isn’t just about compliance, it’s about future-proofing your data and processes for a more transparent tax era.

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4. Investing in Advanced TP Technology & Tools (18%)

Technology has shifted from only being seen as an efficiency enabler to an ally for defensibility.
Use of specialist transfer pricing software doubled year-on-year, but only 1% of teams run on fully integrated, end-to-end TP platforms.

“Technology isn’t just about automation, it’s about clarity. Teams using consolidated, structured TP data not only work faster but have more confidence when the audit comes. Transformation begins with visibility.” - Maria Helander, VP Product, Aibidia.

2026 could be the year we see more MNEs moving beyond isolated tools and toward connected, structured TP ecosystems that link compliance, OTP, and documentation into one data backbone.

Implication: Technology is becoming the foundation of audit resilience. Structured, connected systems turn data into defensibility.

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5. Expanding and Optimizing TP Teams & Resources (11%)

Headcount alone isn’t the answer, but capacity, capability, and coordination are. With 75% of companies under $10B in revenue still operating with TP teams of just 1–3 people, there’s no sign of a hybrid resourcing decline – or in other words, a reduction in the use of external advisors.

“The winning teams will be those that blend deep in-house knowledge with technology and external expertise, not as outsourcing, but as orchestration.” - Marlon Manto, Director, Transfer Pricing Advisory, Aibidia.

Resourcing models are evolving to leverage data, automation, and partnerships to deliver more with less.

Implication: The future TP team isn’t bigger; it’s smarter, combining people, process, and platforms to deliver agility and assurance.

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2026: The Year of Resilience by Design

The Aibidia Report paints a picture of a profession under pressure but responding with precision. Audit defense may dominate the headlines, but the underlying trends point to data, technology, and collaboration defining competitive TP advantage.

Transfer pricing goes beyond compliance, it’s about control, credibility, and confidence.

Get the complete Aibidia Report 2025: The State of Transfer Pricing for in-depth data, expert commentary, and trend analysis of all things TP.

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