AI in Transfer Pricing

Is there a role for AI in transfer pricing? We believe the simple answer to this question is – yes – but with a few qualifiers. In this conversation, we dive into what is AI, Generative AI and how next-word prediction can and may be used in a transfer pricing context. While we are generally optimistic, we also discuss the pitfalls of AI, including hallucinations, and why outsourcing judgment in evaluating comparables could be a slippery slope. We do not believe AIs have agency (yet) and advocate for human oversight in deploying and leveraging AI-based automation tools.