Aibidia’s Reuben Sagar and Maria Helander told The CFO that transfer pricing can no longer be treated as a back-office burden. With structured data, automation, and audit readiness, CFOs can transform it into a strategic lever for resilience, efficiency, and growth.
For years, transfer pricing has lived in the background of corporate finance, treated as a compliance obligation best left to tax specialists and external advisors. But according to Aibidia’s new 2025 State of Transfer Pricing Report and the insights of Chief Revenue Officer Reuben Sagar and VP of Product Maria Helander, that view is fast becoming outdated.
The report reveals that only 14% of firms make heavy use of structured transfer pricing data, while 92% still rely heavily on external advisors. At the same time, 31% of companies rank audit defense as their top priority.
For CFOs, that combination of underutilized data, overreliance on third parties, and mounting regulatory complexity is a risky position.
As Sagar and Helander argue, it is also a missed opportunity: transfer pricing data is not just a compliance tool, but an asset that can drive resilience, efficiency, and strategic advantage —an approach already being embraced by industry leaders like Unilever and Nokia, who are working with Aibidia to modernize their transfer pricing operations.
Helander stresses that the first step for CFOs is a mindset shift. “Too often transfer pricing is seen as something you just have to do,” she told The CFO.
“But structured data has value far beyond compliance. Centralizing and activating it creates insights that can strengthen the whole business.”
That shift requires CFOs to look past piecemeal solutions. Many organizations adopt point tools for documentation or segmentation but stop there, missing the compounding benefits of an integrated approach. A platform model, Helander argues, allows firms to start small but continuously build a structured data foundation that unlocks long-term value.
“Even if you begin with incremental projects, if the technology sits on a unified platform, every step adds to a wealth of data that can later power insights, forecasting, and decision-making,” she said.
One of the starkest changes highlighted in the report is the growing focus on audit defense. Sagar explains that the old way of handling audits, digging through records years after decisions were made, is no longer sustainable.
“Large multinationals can spend years responding to a single audit because they’re trying to reconstruct decisions from five or ten years ago. That’s incredibly difficult,” he said.
Instead, leading organizations are shifting to what he calls “always audit ready.” This means ensuring that decisions, rationales, and data are systematically captured and documented in real time on a platform. The benefits go beyond risk management.
“CFOs tell us they don’t mind paying tax. What they don’t want is unexpected tax bills,” Sagar said. “Audit readiness reduces that uncertainty and gives them greater visibility over their obligations.”
Technology is central to making that shift. Helander notes that a purpose-built platform can embed compliance into day-to-day operations, creating transparency and reliability. With the addition of AI and large language models, there is now potential to automate routine processes, enhance predictive capabilities, and support proactive transfer pricing strategy.
But AI is only as effective as the data it draws from. “Garbage in, garbage out is even more true in financial processes,” Helander cautioned. “Predictability and accuracy are critical. That means combining curated, domain-specific AI with a solid foundation of structured data.”
For CFOs, the message is clear: technology should augment people, not replace them. By automating administrative work and surfacing insights, platforms free finance teams and external advisors to focus on higher-value analysis and strategy.
The State of Transfer Pricing Report highlights that 92 percent of firms still rely on external advisors. For Aibidia, that reliance isn’t a problem in itself; it’s about what the advisors are doing.
“Too much of their time goes into manual, administrative work,” Sagar said. “Technology can take that off their plate, so advisors can focus on what really delivers value: guidance and strategy.”
Helander adds that platforms allow companies to maintain visibility and control even in hybrid models. “You can outsource operational tasks while still having full transparency and audit-ready data on the platform. That way you get the best of both worlds,” she said.
If there was ever a time for CFOs to rethink their approach, it is now. The global regulatory environment is shifting fast, with OECD’s Pillar Two, BEPS developments, and a wave of new tariffs reshaping the terrain for multinationals.
“It’s created a real wake-up call,” Sagar said. “Transfer pricing is now firmly on the CFO’s agenda. Those who proactively set prices and manage their data will navigate these shifts far better than those making retrospective adjustments.”
For Helander, the uncertainty itself strengthens the case for investment. “You can’t predict every change, whether it’s Pillar Two details or new political tariffs. But if you’ve built a structured data foundation, you’re far better positioned to respond quickly and confidently when changes come,” she said.
Looking ahead, both executives see structured data and automation as the cornerstones of transfer pricing’s future. Cost reduction, risk management, and revenue optimization are all in play, but the foundation is the same: technology that elevates transfer pricing from a reactive burden to a proactive strategic lever.
“Our customers want more from their data,” Sagar said. “They want visibility and control, not surprises. That’s the foundation of everything we’re building.”