The year 2025 has been a challenging year for many MNEs, considering amongst others, the volatile U.S. (customs) politics, the ongoing Ukrainian war, political tension in many regions of the world, rapidly changing business conditions due to accelerating technical progress such as AI or new competition entering settled markets, etc.
From a tax and transfer pricing perspective, tax authorities have increased their efforts and capabilities to assess intra-group transactions. The review of the appropriateness of the transfer prices applied is increasingly supported by enhanced investigation techniques, such as artificial intelligence (AI) and information gathered from Country-by- Country-Reportings (CbCRs) and other reporting obligations.
The current situation requires not only courage and vision for MNEs to adapt business models to be able to face the challenges arising and to possibly utilise the opportunities, but also the ability to navigate through an increasingly complex tax, transfer pricing as well as customs landscape. This navigation entails the proactive management and robust documentation of transfer pricing models and their changes.
One proactive management measure can be the year-end transfer pricing adjustment, which – if not used correctly – can lead to tax and customs risks (or unused opportunities). In highly challenging and volatile landscapes as in the year just ended, proactive operational transfer pricing management is more crucial than ever. Looking forward to 2026 and the foreseeable future, an increasing level of automation with respect to compliance tasks and focus on creating efficient and sustainable transfer pricing models including proactive operational transfer pricing and customs duty management will become even more important to address the current or arising challenges and mitigate future risks with respect to tax audits.
We at Tax Partner are eager and committed to support you with your specific tax, transfer pricing and customs challenges – and wish you a successful year 2026.