Exploring Transfer Pricing

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In Part 2 of this two-part series, host Brittany Hardin Tanguay and Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) practice, continue their conversation fielding questions from transfer pricing professionals at the TP Minds West Coast event in Palo Alto.


This episode digs into the practical realities of GenAI's impact on transfer pricing, covering three key areas:


- The evolving value of data (and why a single data point is nearly worthless until it's aggregated, cleansed, and put to work)

- How GenAI adoption is - and isn't - reshaping comparability analysis and benchmarking under TNMM and CPM, and

- Where tax authorities are most likely to challenge intercompany arrangements tied to AI-driven value creation.

The rise of GenAI is not just an innovation in technology, it's a gamechanger for global business strategies. In this episode, industry specialist Lonnie Brist, Senior Managing Director at KPMG LLP Washington National Tax (WNT) and our host, Brittany Hardin Tanguay, comment on the pressing issues posed by tax professionals in the field raised at the TP Minds West Coast event in Palo Alto.


We explore the implications of GenAI on transfer pricing:

- Does GenAI-generated content constitute new intellectual property?

- How does automation shift the allocation of intercompany costs?

- What steps can companies take to stay proactive amid the rapid adoption of this technology?




From understanding the evolving role of data to tackling comparability challenges, this discussion explores the dynamic intersection of GenAI and transfer pricing in Part 1 of this two-part episode.

ICAP - the OECD's International Compliance Assurance Program - offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way?


This episode presents a unique opportunity to hear directly from both perspectives: Doug O'Donnell, former IRS Acting Commissioner and Deputy Commissioner, who was instrumental in shaping ICAP for tax administrations, and Erik Skarstad, who has navigated the program during his time as a Transfer Pricing leader for Fortune 100 companies. Their firsthand experiences reveal the practical realities, challenges and benefits of participating in ICAP.


Join our host Brittany Hardin Tanguay as she speaks with Doug O'Donnell (Senior Managing Director, Washington National Tax, Tax Controversy and Dispute Resolution) and Erik Skarstad (Managing Director, Tax, Transfer Pricing) to unpack ICAP's origins, objectives, and real-world impact. Together, they share insights from both sides of the table, government and taxpayer, on building trust, navigating challenges, and finding value in multinational cooperation.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses.


This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next.


Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.

As we round out 2025, we reflect on the pivotal developments that have reshaped the transfer pricing landscape this year. Our annual year end 'Taxing Times' episode charts the evolving terrain, from changes arising from the One Big Beautiful Bill Act (OB3) such as FDII/FDDEI to the future of QDMTTs, upcoming OECD projects and tariffs-examining how these changes are influencing strategies and compliance for multinational businesses.


This episode highlights how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management. Wrap-up this year with key takeaways and forward-looking perspectives as we set sail toward 2026 with practical insights and a compass for what's next.


Our host Brittany Hardin Tanguay (Senior Manager, Tax, WNT - Transfer Pricing), is joined by Jessie Coleman (Principal - Washington National Tax, Transfer Pricing) and Doug Labadie (Managing Director, Tax - Transfer Pricing). Together, they chart how businesses are navigating new regulations and shifting economic realities.