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Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2)

07.15.2026 | Duration: 17:19

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 Part 2 of this two-part series, host Brittany Hardin Tanguay and Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) practice, continue their conversation fielding questions from transfer pricing professionals at the TP Minds West Coast event in Palo Alto.

This episode digs into the practical realities of GenAI's impact on transfer pricing, covering three key areas:

  • The evolving value of data (and why a single data point is nearly worthless until it's aggregated, cleansed, and put to work); 
  • How GenAI adoption is — and isn't — reshaping comparability analysis and benchmarking under TNMM and CPM; and 
  • Where tax authorities are most likely to challenge intercompany arrangements tied to AI-driven value creation.

Discover more podcast episodes in this series

More Exploring Transfer Pricing podcast episodes

Meet our podcast team

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

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