Transfer pricing has a context problem.

Transfer pricing has always been complex. What is changing is the nature of that complexity.

For years, the challenge for multinational tax teams was largely one of compliance: setting the right policies, documenting them and showing that the organisation had met its obligations.

That challenge has not gone away. But it is being joined by something much bigger.

Today's transfer pricing teams work across hundreds of entities, thousands of transactions and many jurisdictions. They are expected to understand what is actually happening across the business, and to spot the moment business reality starts to drift from policy.

Expectations are rising on every side. Tax authorities have more data and sharper ways of analysing it. Finance leaders want more visibility and control. Regulation keeps expanding. And AI has changed how quickly everyone expects to understand information and act on it.

Our State of Transfer Pricing research shows how wide this tension has become. One in five teams worked on more than nine audits or inquiries in two years. 60% still run operational transfer pricing mainly on Excel and email. Almost every team now uses AI in some form, yet only 22% say their data is ready for it.

This reveals an important distinction.

The industry does not have an information shortage. It has a context problem.

The policies exist. The agreements exist. The financial and transactional data exists. The functional analyses, the documentation, the regulations and the knowledge in people's heads all exist.

What is missing is the ability to connect these pieces into one coherent picture of the organisation's transfer pricing reality, one that stays current.

We call this the Transfer Pricing Intelligence Gap: the distance between everything an organisation knows about its transfer pricing and its ability to understand what that information means, identify what matters and act on it.

Technology has already transformed transfer pricing once. Manual work has been digitised and automated. We have become better at producing documentation, performing calculations, monitoring outcomes and conducting research. But these capabilities grew up separately, and the gap remained.

Closing it takes a new kind of system.

A system of intelligence for transfer pricing.

Imagine a common, machine understandable model of your organisation: its entities, transactions, policies, agreements, functions, assets, risks, financial outcomes, regulatory obligations and the evidence behind them, all connected.

You could see what your policy says, what is actually happening, and whether the two are aligned. You could find emerging risks, inconsistencies and opportunities across the whole transfer pricing architecture. You could trace every conclusion back to the facts that support it. And AI could reason across the economic, financial, legal and regulatory context of your business, rather than simply search individual documents.

That changes the role of technology entirely. Instead of waiting for someone to ask a question, the system continuously senses what is happening, understands it in context, reasons about its significance, recommends decisions, supports action, preserves the evidence and learns from the outcome. Your people stay in control of every decision.

Transfer pricing is ultimately about alignment: between how value is created, the policies you design, the transactions you execute, the profits that result and the positions you report. Today, organisations test that alignment after the fact. Tomorrow, they will understand it continuously.

That is the shift from information to intelligence.

For a long time, the question facing our industry was how to make today's processes more efficient. The question now is bigger:

What becomes possible when the entire transfer pricing environment can finally be understood as one connected whole?

We believe answering it will define the next era of transfer pricing. An era of Transfer Pricing Intelligence, where knowledge is connected, continuously understood and turned into better decisions, stronger control and more defensible outcomes.

That is what we are building at Aibidia. Today, we are sharing a first look, and I invite you to step inside and see it for yourself.