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Navigating The New Frontier: How GenAI Is Shaping Transfer Pricing Analysis
Navigating The New Frontier: How GenAI Is Shaping Transfer Pricing Analysis

Forbes

time17-07-2025

  • Business
  • Forbes

Navigating The New Frontier: How GenAI Is Shaping Transfer Pricing Analysis

Chidambaram Bhat, Co-Founder and CTO at Integral Technologies. It's funny how some of life's most profound revelations happen over a steaming cup of coffee. A couple of months back, I was catching up with an old colleague from my days at Citadel. We were reminiscing about the seemingly insurmountable challenges we faced in the financial sector, especially when dealing with the complexities of transfer pricing. It was then that it struck me: GenAI wasn't just a tool for software development and operational efficiency (my bread and butter, if you will) but a burgeoning force quietly revolutionizing transfer pricing qualitative analysis. You could say it was an 'aha' moment—one that spurred me to explore this confluence of technology and finance further. The Rise Of GenAI In Transfer Pricing In the last few years, GenAI has evolved from an intriguing novelty into a robust tool that automates the more nuanced, qualitative aspects of transfer pricing analysis like benchmarking and documentation. Coming from a technology background, I can appreciate the parallels between building AI-driven platforms and tackling transfer pricing complexities. When we constructed Integral Technologies' core offerings, we leaned heavily on GenAI to automate document analysis and generation. The results were striking: Not only did we manage to streamline operations, but we also achieved a degree of consistency and transparency that was previously unheard of. However, in the financial sector, there is still a palpable tension between the promise of automation and the fear of overreliance on machines. While GenAI can churn out standardized insights, it's crucial to blend these with human expertise from those who have their finger on the pulse of ever-changing global tax regulations. We learned this the hard way when our initial AI-generated reports, though accurate, lacked the nuanced understanding that only a seasoned tax expert could provide. Sometimes, the data tells a story that needs a human narrator. Embrace GenAI for its strengths in efficiency and standardization—but never at the expense of human judgment. Balance is key. The Technical Deep Dives: A Closer Look At GenAI Models GenAI models work their magic through advanced algorithms and deep learning techniques. During our initial experiments at Integral, I saw firsthand how NLP algorithms can dissect and understand complex text, which is fundamental for transfer pricing documentation. A particular project I recall involved integrating transformer models into our document analysis tools. The initial setup was complex, akin to setting up a multitenant cloud architecture, but the payoff was enormous. It highlighted the potential for GenAI to handle tasks that traditionally required significant manual input. However, there's a flipside. The complexity of these models often leads to integration challenges. They don't always mesh seamlessly with existing ERP systems, an issue we've faced numerous times. Our clients occasionally struggled with fragmented data landscapes, which in turn impacted the holistic view of their transfer pricing strategies. Invest in seamless systems integration to leverage GenAI's full potential, and overcome data silos through comprehensive, unified platforms. Future Predictions And Navigating Challenges Looking ahead, the integration of GenAI into transfer pricing will likely result in a hybrid analytical model. AI will increasingly handle routine tasks, freeing human experts to concentrate on strategy. This echoes a lesson I learned while setting up our DevOps environment at Citadel: Automate what you can to focus human resources on innovation and creativity. However, this evolution demands a workforce adept in both financial acumen and AI literacy—a tall order but certainly achievable. Just like AI-driven product features we've implemented for transfer pricing automation, there's a significant learning curve, but there's also an immense opportunity for those willing to adapt. Moreover, as AI refines pricing strategies with precision, regulatory bodies are bound to increase scrutiny, potentially leading to more rigorous compliance standards. We've preemptively worked on setting policy-based access control and audit trails, embedding compliance into our DNA. Prepare for increased regulatory demands by building rigorous compliance frameworks into your AI systems. Conclusion: A Balanced Path Forward GenAI is significantly impacting transfer pricing qualitative analysis, paving the way for greater transparency and operational efficiency. However, it's essential to tread carefully to embrace GenAI's strengths while maintaining the invaluable human touch. Reflecting on my journey from software engineer to CTO, the key takeaway is this: Technology, no matter how advanced, is only as effective as the people who wield it. As we navigate this new frontier, let's strive to balance a blend of machine precision and human insight to truly revolutionize transfer pricing strategies for a digital age. Over our next coffee, perhaps we can delve into how these changes are reshaping other domains. There's always more to explore when technology and industry meet. Forbes Technology Council is an invitation-only community for world-class CIOs, CTOs and technology executives. Do I qualify?

Oman: Taxation is not a statutory requirement, but a strategic Imperative
Oman: Taxation is not a statutory requirement, but a strategic Imperative

Zawya

time25-06-2025

  • Business
  • Zawya

Oman: Taxation is not a statutory requirement, but a strategic Imperative

The International tax seminar hosted by Crowe Oman, a leading Audit & Advisory firm in the Sultanate shed light on the application of transfer pricing provisions, Base erosion and profit shifting concepts and the Global minimum tax provisions. The event held at the Hormuz Grand Hotel brought together leading tax professionals, banking executives, business leaders, finance managers and enthusiasts for an insightful discussion on the evolving global tax landscape. Welcoming the participants Dr Davis Kallukaran, Managing Partner, at Crowe Oman, highlighted the growing challenges, tax establishments are facing across borders, emphasizing that 'Taxation is no longer just a statutory requirement, but a strategic imperative.' Dr. Davis reiterated the critical role taxation plays in shaping global business decisions, underscoring why understanding its nuances is essential for all stakeholders. He extended a warm welcome to the keynote speakers – Dr. Robert E. B. Peake and Mr. Matthew Moriarty, who later shared their valuable insights on the implications of international taxation. The seminar featured a series of insightful sessions, aimed at enlightening businesses in Oman with the required knowledge to navigate global tax systems effectively. Dr. Robert Peake opened the discussion by shedding light on the theme of Global Expansion, bringing clarity to the key tax considerations that Omani businesses must navigate when stepping onto the international stage. He emphasized the strategic importance of tax treaties, explaining how they can shape cross-border operations and reduce tax risks. He also highlighted their real-world implications on business structures and profitability, and offered practical insights on how companies can stay compliant across diverse tax jurisdictions. Mr. Matthew Moriarty followed with an engaging session on the critical relevance of BEPS (Base Erosion and Profit Shifting) action points. He explained how multinational companies use tax planning strategies to exploit gaps and mismatches in tax rules across jurisdictions, making BEPS a global concern. He also delved into OECD methodologies and the Transfer Pricing Arm's Length Principle and related regulatory frameworks, keeping the audience actively engaged with practical examples and discussions. He outlined the objectives and recent developments under Pillar One, and shed light on the far-reaching impact of Pillar Two's Global Minimum Tax. He concluded his session by examining how the rapid growth of the digital economy is transforming business dynamics in Oman, offering thought-provoking perspectives on the future of tax in a digitalized world. The seminar concluded with an engaging Q&A session, sparking insightful dialogue on tax strategies. Mr. Antony Kallukaran, Partner – Tax Advisory Services, delivered the vote of thanks, expressing gratitude to the distinguished speakers and participants for making the International Tax Seminar a meaningful success. © Muscat Media Group Provided by SyndiGate Media Inc. (

Taxation is not a statutory requirement, but a strategic Imperative
Taxation is not a statutory requirement, but a strategic Imperative

Times of Oman

time24-06-2025

  • Business
  • Times of Oman

Taxation is not a statutory requirement, but a strategic Imperative

The International tax seminar hosted by Crowe Oman, a leading Audit & Advisory firm in the Sultanate shed light on the application of transfer pricing provisions, Base erosion and profit shifting concepts and the Global minimum tax provisions. The event held at the Hormuz Grand Hotel brought together leading tax professionals, banking executives, business leaders, finance managers and enthusiasts for an insightful discussion on the evolving global tax landscape. Welcoming the participants Dr Davis Kallukaran, Managing Partner, at Crowe Oman, highlighted the growing challenges, tax establishments are facing across borders, emphasizing that 'Taxation is no longer just a statutory requirement, but a strategic imperative.' Dr. Davis reiterated the critical role taxation plays in shaping global business decisions, underscoring why understanding its nuances is essential for all stakeholders. He extended a warm welcome to the keynote speakers – Dr. Robert E. B. Peake and Mr. Matthew Moriarty, who later shared their valuable insights on the implications of international taxation. The seminar featured a series of insightful sessions, aimed at enlightening businesses in Oman with the required knowledge to navigate global tax systems effectively. Dr. Robert Peake opened the discussion by shedding light on the theme of Global Expansion, bringing clarity to the key tax considerations that Omani businesses must navigate when stepping onto the international stage. He emphasized the strategic importance of tax treaties, explaining how they can shape cross-border operations and reduce tax risks. He also highlighted their real-world implications on business structures and profitability, and offered practical insights on how companies can stay compliant across diverse tax jurisdictions. Mr. Matthew Moriarty followed with an engaging session on the critical relevance of BEPS (Base Erosion and Profit Shifting) action points. He explained how multinational companies use tax planning strategies to exploit gaps and mismatches in tax rules across jurisdictions, making BEPS a global concern. He also delved into OECD methodologies and the Transfer Pricing Arm's Length Principle and related regulatory frameworks, keeping the audience actively engaged with practical examples and discussions. He outlined the objectives and recent developments under Pillar One, and shed light on the far-reaching impact of Pillar Two's Global Minimum Tax. He concluded his session by examining how the rapid growth of the digital economy is transforming business dynamics in Oman, offering thought-provoking perspectives on the future of tax in a digitalized world. The seminar concluded with an engaging Q&A session, sparking insightful dialogue on tax strategies. Mr. Antony Kallukaran, Partner – Tax Advisory Services, delivered the vote of thanks, expressing gratitude to the distinguished speakers and participants for making the International Tax Seminar a meaningful success.

Tax Forum discusses development in tax system
Tax Forum discusses development in tax system

Times of Oman

time06-05-2025

  • Business
  • Times of Oman

Tax Forum discusses development in tax system

Muscat: The second edition of the Tax Forum 2025, organized by the Tax Authority in Muscat today, discussed ways to introduce comprehensive developments in the tax system, in transfer pricing and in the implementation of value-added tax (VAT) in the Sultanate of Oman. The forum saw the presentation of working papers on the most significant structural updates within the Tax Authority. The updates included the consolidation of operational efficiency and improvements to electronic services aimed to facilitate taxpayers' compliance. The presentation also showcased new strategic initiatives launched by the Authority and aspects of enhancing cooperation with international tax organizations and sharing expertise and best practices in the field. Specialized experts gave detailed accounts of outstanding tax developments at the regional level and the potential impacts of such developments.

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