Transfer pricing at the crossroads: disruption, data, and the decade ahead
Twenty-five years ago, transfer pricing (TP) barely registered on the radar of most tax authorities, let alone most boardrooms. It was a technical discipline practised by a small community of specialists, lightly regulated, confined largely to a handful of advanced economies, and viewed by most multinationals as a documentation exercise to be completed, filed, and forgotten.
The work itself reflected that status. A benchmarking study – the centrepiece of any TP file – meant weeks of manual labour: pulling a thousand-company database shortlist, printing company documents by the ream, and working through each one manually to determine a few so-called comparable companies and establish the arm’s-length range. Six to eight weeks, minimum, for a single exercise. Painstaking, expensive, and subjective.
