Episode 123: Data-driven decisions: AI elevates transfer pricing strategy

Kristina Novak, a Principal in PwC’s Washington National Tax Services Transfer Pricing practice, and John Cianfrone, a Director in PwC’s Washington National Tax Services Transfer Pricing practice, are joined by Erin March, a Principal in PwC's US Transfer Pricing practice, and Nikole Flax, a Principal in PwC’s Washington National Tax Services practice and former Commissioner of the IRS Large Business and International Division. The discussion focuses on how artificial intelligence is reshaping transfer pricing, from how companies create value to how tax authorities enforce compliance. AI is also driving a broader shift in the tax function, from a more periodic, manual process to a more continuous, data-driven operating model, with transfer pricing at the center of that transformation. The conversation explores data infrastructure and governance, evolving documentation, and how taxpayers and tax authorities are converging toward real-time, technology-enabled approaches to risk management and audit readiness.