Read the Top 5 Transfer Pricing Tax Journal Articles of 2025

This compilation highlights five transfer pricing articles of the year, offering insights into the challenges and opportunities that tax professionals and multinational enterprises face as we approach 2026. These pieces, authored by industry experts, provide a comprehensive overview of the current state and future trends in global transfer pricing

Transfer Pricing Landscape Shifts Amid IRS Changes and Tariffs. The US transfer pricing landscape has been volatile in 2025 and promises to remain at the forefront of multinationals’ tax strategies heading into 2026. Steven C. Wrappe, Glen Marku, and Hayley M. Yarem of Grant Thornton wrote this in December. Read More.

How Can GenAI Improve My Transfer Pricing Process? Some of the challenges and opportunities that firms should consider when deciding whether to use GenAI in the transfer pricing process is analyzed. Amanda Carey and Brittany Hardin Tanguay of KPMG US wrote this in March. Read More.

Are Advanced Pricing Agreements Ushering in a New Dawn in Africa? The transfer pricing audit process in Nigeria and South Africa is discussed. Barbara Mbaebie and Christian Wiesener of KPMG Nigeria and South Africa, respectively, wrote this in September. Read More.

Amount B Entity Segmentation Presents Opportunities and Traps. Differing approaches to financial segmentation between taxpayers and governments may cause wildly different Amount B returns, or a different conclusion on being in-scope at all, so documentation of reasonable allocation standards is key to avoiding government rebuttals. Andrew O’Brien-Penney, Alejandro Zavala-Rosas, Imke Gerdes, and Shane Koball of Baker McKenzie wrote this in September. Read More.

Safe Harbors: Is the Arm’s Length Principle Losing Its Grip? While the full arm’s length principle is reserved for complex, high-stakes cases, safe harbors can be deployed for routine fact patterns. Jelena Mihić Munjić of Kreston MDM Serbia wrote this in November. Read More.

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law, Bloomberg Tax, and Bloomberg Government, or its owners.

Write for Us: Author Guidelines