Future-Proofing Your Transfer Pricing: Why Today's Decisions Will Face 2030's Scrutiny
Today's transfer pricing decisions will inevitably face scrutiny years down the road under evolving standards and interpretations, creating a "transfer pricing time paradox" that many organizations overlook. Historical patterns, evidenced by recent high-profile cases like Coca-Cola and BlackRock, show how seemingly robust policies can collapse when documentation and rationale aren't future-proofed. To address this, companies must build robust foundations—clearly documenting methodology, implementation processes, and decision-making rationales—to withstand future audits. Preparing now by closing documentation gaps, aligning substance with form, and establishing systematic policy reviews isn't just good practice—it's essential to prevent today's decisions from becoming tomorrow's costly challenges.
Borys Ulanenko
