Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2) episode artwork

EPISODE · Jul 14, 2026 · 17 MIN

Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2)

from 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.

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Is Adoption of Generative Artificial Intelligence (GenAI) Redefining Value and Transfer Pricing? (Part 2)

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