Reports

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Reports

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Reports

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Reports

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Reports

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Why you should download

Why you should watch

Your guide to digital transfer pricing

12.4.2023
Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Learn how to elevate your transfer pricing processes to the next level with digitalization. In this whitepaper, you’ll:

  • Gain a better understanding of what digital transfer pricing is and how it works
  • Discover the benefits of implementing a digital transfer pricing approach, including time and cost savings, risk reduction, and enhanced visibility and control
  • Evaluate your existing transfer pricing processes
  • Find out what it takes to transition to digital transfer pricing

Meet the authors

Author
Borys Ulanenko
Advisor to Aibidia and ArmsLength AI founder

Borys Ulanenko is a Digital Transfer Pricing Expert. Borys has more than 10 years of experience in transfer pricing, with a background in industry and consulting. In addition to advising Aibidia, Borys is the founder of the educational platform StarTax Education and the AI-driven solution ArmsLength.ai.

Borys is passionate about sharing his knowledge and experience with others. He loves explaining complex transfer pricing concepts in simple words and sharing his expertise with Aibidia and the tax community. He sees his mission in demystifying transfer pricing and making this exciting area of international tax available to everyone.

Author
Sunny Bilaney
Digital Transfer Pricing Leader, Asia-Pacific region

Sunny Bilaney is a Digital Transfer Pricing Leader, in the Middle East & APAC region at Aibidia Ltd. Sunny is an International Tax and Transfer Pricing expert with 14 years of experience. Before joining Aibidia, Sunny worked mainly with PwC and KPMG.

Sunny has authored 3 books on tax and transfer pricing. He also regularly contributes articles to internationally renowned publications such as IBFD, Tax Notes, Thomson Reuters, and Taxmann.

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REPORTS

Your guide to digital transfer pricing

Get the guide to digital transfer pricing and its benefits. Download your free copy today!

Hereʼs Why You Should Get the Report

0

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.

0

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.

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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.

Insights

What youʼll learn inside the Aibidia report 2025

The rising cost of tax scrutiny
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.

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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
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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
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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
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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
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