Transfer Pricing in focus
The world continues to experience a year of change in 2025. Multinational companies are dealing with growing external
pressures amid unexpected tariffs, volatile capital markets and a changing talent market as generative artificial
intelligence (Gen AI) proliferates.
At the same time, businesses are recognizing the need to transform how they manage transfer pricing in a world where data is key, regulations are evolving, scrutiny and controversy are increasing, and new business models are rapidly emerging.
A robust transfer pricing framework is founded on where and how organizations create value across the group of companies.
It calls for broad-ranging and transparent policies for intercompany transactions — effectively implemented and clearly
reported — to satisfy the demands of tax authorities and other regulatory bodies.
Many organizations are asking how they should organize themselves in this new reality as they strive to balance in-house teams with external resources. They are also focusing on how best to implement new technologies like artificial intelligence (AI) and automation to enhance efficiency, productivity and data quality.
In this article, KPMG professionals share timely insights into today’s challenges and consider the steps senior tax leaders should take to create a tax function ready for the future.
