Aibidia Report 2025: The State of Transfer Pricing

The 2025 edition captures insights from 140+ multinational enterprises and advisory firms. It reveals how TP teams globally are responding to intensifying audit scrutiny, operational challenges, and the impact of technology and AI.

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Hereʼs Why You Should Get the Report

See how peers are adapting to global change

Understand how 140+ MNEs and advisory firms are responding to shifting regulations, heightened audit scrutiny, and technology-driven change, and where your approach stands in comparison.

Learn how others are driving compliance

Explore the approaches to resourcing, data management, and operational transfer pricing that teams are using to tackle growing workloads.

Identify emerging trends shaping the profession

Gain insight into how AI, automation, and operating models are redefining transfer pricing, so you can plan for the skills, tools, and processes youʼll need next.

What youʼll learn inside the Aibidia report 2025

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01 The rising cost of tax scrutiny

Heightened tax authority demands are driving up the time and money TP teams spend on audits. Companies with stronger documentation processes, centralised data, and proactive OTP practices are better positioned to contain both costs and risk.

02 The state of OTP maturity

Only 35% of companies have a well-defined OTP process, while 24% have none at all. Barriers to OTP maturity include poor data access, complex business models, and limited coordination between tax, finance, and IT.

03 The importance of structured data

With 72% of companies in fragmented data environments, the report shows how centralised data helps TP teams insource more processes, ensure consistent compliance, and handle audits more efficiently.

04 Technology and AI adoption in practice

42% of MNEs are investing in specialist software, reducing reliance on traditional tools. AI interest is steady rather than explosive, hinting that TP teams need clean, structured data before advanced analytics can add value.

Expert insights

"Structured, reliable data is essential for executing a consistent, defensible transfer pricing strategy. Common barriers to structured data include siloed legacy source systems, unclear data ownership, and inconsistent definitions across entities and functions."

Prasad Parwidala, Head of Professional Services, Aibidia

"We see significant variation in OTP maturity across companies. In many cases, if existing processes appear to work, there’s less motivation to change. However, where we see this changing, is within MNEs that have faced increased scrutiny or operate with more complex structures."

Pia Honkala, Global Commercial Head - Operational Transfer Pricing, Aibidia

"While there are many challenges in accessing the right data for TP calculations and analysis, one of the most significant barriers to OTP adoption can be the misalignment of KPIs between Finance and Tax teams."

Marlon Manto, Director, Transfer Pricing Advisory, Aibidia

"We’re seeing practical AI adoption in areas such as navigating country-specific documentation requirements, researching transfer pricing methods, comparing jurisdictional rules, and tracking global compliance timelines."

Maria Helander, VP Product, Aibidia