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Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 1)

06.01.2026 | Duration: 13:23

If GenAI is reprogramming the value chain and taxing traditional approaches to intangible property (IP) and cost allocation, what is the impact on transfer pricing?

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The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, Brittany Hardin Tanguay, comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto.

We explore the implications of GenAI on transfer pricing:

  • Does GenAI-generated content constitute new intellectual property?
  • How does automation shift the allocation of intercompany costs?
  • What steps can companies take to stay proactive amid the rapid adoption of this technology?

From understanding the evolving role of data to tackling comparability challenges, this discussion explores the dynamic intersection of GenAI and transfer pricing in Part 1 of this two-part episode.

Discover more podcast episodes in this series

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Meet our podcast team

Image of Brittany Hardin Tanguay
Brittany Hardin Tanguay
Senior Manager, Washington National Tax, KPMG US

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