Why governance, evidence and operational credibility are now at the centre of risk
Executive Insight
Transfer pricing audits are entering a new phase.
Tax authorities are no longer focused only on whether a policy looks correct on paper. They are testing whether transfer pricing outcomes reflect how the business actually operates, where decisions are made, who controls risk, and whether those positions can be supported with credible evidence.
Our latest article explores the issues now under greatest scrutiny, including:
- governance and internal consistency;
- support for services, allocations, and intercompany charges; and
- mismatches between documentation and operational reality.
This shift means that even technically sound positions may be challenged if businesses cannot demonstrate alignment between policy, conduct, and financial outcomes.
Read the full article to see what tax authorities are really testing in 2026 and what multinational groups should do now to reduce risk.
How We Can Help
The organisations that stay ahead are those that invest early in governance, align tax policy with business conduct, and use technology to create consistency across their transfer pricing framework.
At TPI Lab, we help organisations move from reactive compliance to proactive transfer pricing control.
TPIL Genetics™ enables:
- alignment between policy, execution and documentation;
- improve consistency across jurisdictions; and
- reduce the burden of manual transfer pricing processes.
