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Transfer Pricing New Year’s Resolutions for 2025

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Looking to achieve new goals for your transfer pricing department in 2025? These new year’s resolutions—recommended by Exactera’s transfer pricing experts—are sure to get you off to a great start.

Leverage Technology and AI

As we welcome the new year, it’s the perfect time for companies to set a resolution to boost efficiency by embracing the latest technology. Transfer pricing has evolved significantly with the growing use of AI, and now is the time to take full advantage of its potential. Companies can resolve to simplify transfer pricing by automating tasks like data collection, benchmarking, and analysis, ensuring compliance with global regulations. AI can help identify comparable transactions quickly, adjust transfer prices in response to market changes, and spot potential risks of audits or non-compliance. With machine learning, companies can optimize pricing strategies, while AI-driven systems can streamline reporting, documentation, and integration with other business tools.

By leveraging AI for insights, cost savings, and dispute resolution, companies can make smarter, more compliant, and tax-efficient transfer pricing decisions in the year ahead.

Laksha Nahar, Lead Senior Manager Transfer Pricing

 

Enhance Data Transparency and Collaboration

The Organization for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) frameworks have helped spark a dramatic shift in corporate tax transparency since 2013. Back then, tax transparency was viewed as a conceptual idea, but now, it’s the norm. Tax authorities are armed with increasingly powerful machine learning and data-sharing tools allowing them to gain increasingly deep and timely access to company records.

Faced with such open environment, tax principals must ensure they’re prepared with processes to stay compliant and be able to avoid controversy wherever possible. Some of these processes are to regularly communicate with stakeholders and build trust, provide accurate and timely data to facilitate better collaboration and company decision-making.

Tax audit management is also key to enable quick and effective resolution with tax authorities. Document all collaboration efforts and maintain clean “audit defense binders,” so if you do get involved in controversy, penalties can often be mitigated by showing you had good controls in place and that the error wasn’t careless. In the transfer pricing realm, this is also known as “making significant effort.”

Susana Pujalt, Lead Senior Manager Transfer Pricing

 

Navigate the Evolving Global Tax Transfer Pricing Landscape with Confidence

Proactively aligning your business strategy with evolving transfer pricing regulations isn’t just smart—it’s essential. Proactive transfer pricing compliance is essential in today’s dynamic global business environment. By aligning your business strategy with the ever-changing regulatory landscape, you can minimize tax risks, navigate complex cross-border transactions with confidence, and unlock valuable opportunities. Take time to review the latest developments in transfer pricing, from OECD guidelines to local jurisdiction updates, and assess their potential impact on your operations. Engage with webinars, expert-led panels, or industry articles to stay informed on new compliance trends and strategies. By identifying areas of high risk and addressing them in advance, you can build a robust compliance framework that minimizes exposure while supporting your business objectives. As a bonus, this proactive approach often streamlines audits and strengthens your relationship with tax authorities.

Ivonne Pinzon, Senior Manager Transfer Pricing