The global transfer pricing landscape continues to evolve rapidly as tax authorities respond to economic uncertainty digitalization and geopolitical developments. In 2025 businesses are facing increased scrutiny more detailed documentation requirements and greater expectations around transparency and substance.

The OECD Inclusive Framework continues to shape global standards while local tax authorities are accelerating audits and enforcement actions. Transfer pricing has become a central pillar of tax risk management for multinational enterprises. Recent developments highlight the importance of proactive planning and alignment between business operations and transfer pricing policies.

Tax authorities are increasingly focused on value creation DEMPE functions and the economic substance of transactions. The post pandemic environment has intensified pressure on profitability and supply chains leading to closer examination of intercompany pricing models. Global minimum tax Pillar Two implementation is influencing transfer pricing considerations especially in relation to effective tax rates and profit allocation across jurisdictions.

Digitalization of tax administration has significantly enhanced the ability of tax authorities to analyze data identify inconsistencies and launch targeted audits. Advanced analytics and information exchange mechanisms allow authorities to compare taxpayer positions across borders. This has increased the likelihood of disputes and the need for robust defensible transfer pricing documentation.

Transfer pricing audits are becoming more frequent and more complex often covering multiple years and involving extensive data requests. Companies are expected to demonstrate clear alignment between their transfer pricing outcomes and the actual conduct of the parties involved. Functional analyses are under greater scrutiny and contractual arrangements alone are no longer sufficient to support pricing positions.

The role of intangibles continues to be a major focus particularly in relation to technology marketing intangibles and data. The allocation of returns from intangibles is closely examined to ensure consistency with DEMPE activities performed by group entities. Tax authorities are challenging structures where significant profits are allocated to entities lacking sufficient substance.

Financing transactions including intercompany loans cash pooling and guarantees remain a key area of attention. Interest rates currency fluctuations and economic volatility have prompted reassessment of pricing and terms. Benchmarking analyses must reflect current market conditions and consider appropriate comparability adjustments. The use of alternative approaches such as internal comparables and economic modeling is becoming more common as traditional databases may not fully capture market realities.

Permanent establishment risks are also closely linked to transfer pricing especially in the context of remote work digital business models and cross border service arrangements. Tax authorities are examining whether activities conducted in a jurisdiction give rise to taxable presence and whether profits have been appropriately attributed.

Advance pricing agreements continue to be an effective tool for managing transfer pricing risk providing certainty and reducing the likelihood of disputes. However the process can be time consuming and resource intensive requiring strong preparation and engagement with tax authorities. Mutual agreement procedures are increasingly used to resolve double taxation arising from transfer pricing adjustments but timelines can be lengthy and outcomes uncertain.

In this environment businesses are placing greater emphasis on dispute prevention strategies including robust documentation consistent implementation and regular monitoring of transfer pricing policies. The integration of transfer pricing with broader tax and business strategies is essential.

Companies are leveraging technology to enhance data management automate calculations and improve reporting accuracy. Transfer pricing governance frameworks are being strengthened to ensure accountability and oversight at both global and local levels. Training and awareness across finance tax and business teams are critical to ensure consistent application of policies and timely identification of risks.

Looking ahead transfer pricing will remain a dynamic and high risk area requiring continuous attention and adaptation. Companies that invest in strong foundations proactive engagement and technological capabilities will be better positioned to manage controversy and support sustainable growth. Effective transfer pricing is not only a compliance requirement but a strategic tool that supports business resilience and long term value creation in an increasingly complex global tax environment.