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How CFOs Can Navigate Stricter Transfer Pricing Tax Enforcement

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Also In The Forbes CFO Newsletter: CFOs Are All In On AI, Lower-Than-Expected Inflation Fuels Hopes Of Rate Cuts, IRS Commissioner Quickly Removed, 401(k)s May Add Private Equity Investments Soon

CFOs are all in on AI. According to new research from Salesforce, only 4% of CFOs surveyed say they have a conservative approach to the technology—a precipitous drop from the 70% who were careful about it in 2020, and the 34% who were slowly approaching it in 2023. According to Salesforce, nearly four out of five CFOs are leveraging AI to inform business decisions.

Across industries and throughout enterprises, CFOs are realizing the power AI can give them to more quickly and efficiently analyze, prepare and streamline work tasks. In a discussion of the survey results last week, Salesforce Chief Financial and Operating Officer Robin Washington said that AI is more than just technology.

“I always think about people, process and technology,” Washington said. “AI revolution is all of those things. It’s cultural, it’s operational, it’s organizational. And when you think about AI agents, my boss always says we’re probably the last set of managers to just manage humans. We’re going to have AI autonomously working side by side, helping us make decisions, being part of our decision-making teams in ways that are going to transform our businesses for the positive.”

The survey found that CFOs are, on average, dedicating a quarter of their AI budgets to agents. About three-quarters say they feel AI agents, performing more mundane tasks and providing digital labor, will both cut costs and drive revenue. The top tasks they’re delegating to AI agents include risk assessments, financial forecasting and expense management.

PayPal Chief Finance and Operations Officer Jamie Miller joined Washington at Salesforce’s virtual event last week to discuss the survey results and how they apply to the CFO’s role. She said she sees the AI revolution being all about velocity and productivity—being able to do more things faster, with the same number of people. Finance jobs, she said, have traditionally been an 80-20 split: 80% of time is spent manipulating data, and 20% doing insightful analysis.

“AI is going to be the thing that can finally really help flip that to be 80-20 the other direction: More time really having an impact and really leaning into the business in ways that can drive important change,” Miller said.

One area where the finance department of multinational companies should pay closer attention is transfer pricing—the method used to set prices of international goods and services —for taxation purposes. President Donald Trump has indicated this might be an area that sees more enforcement, though the number of people to enforce it at the IRS is diminished. I talked to Mimi Song, a transfer pricing expert and COO of financial software company Exactera, about what to do. An excerpt from our conversation is later in this newsletter.


This is the published version of Forbes’ CFO newsletter, which offers the latest news for chief finance officers and other leaders focused on the budget.