Transfer pricing benchmarking is often presented as a technical database exercise. In reality, it is a chain of judgement calls — and those judgement calls increasingly determine whether a benchmark is persuasive in practice.

That matters even more now because AI is changing both sides of the equation. It can help teams execute benchmarking work more efficiently and consistently, but it also makes it easier for reviewers, tax authorities, and counterparties to scrutinise benchmarks, test assumptions, and spot weaknesses in the process.

In this webinar, we will walk through a typical transfer pricing benchmarking process from end to end: from defining the tested party and selecting a PLI, to setting the search strategy, reviewing comparables, handling loss-makers, and building a defensible range.

We will also highlight the points in the process that are most often challenged in audits and disputes, and map those issues against recent tax authority guidance and broader controversy trends.

Along the way, we will show how these decisions can be executed in a modern workflow inside ArmsLength AI. The goal is to show what a stronger, more consistent, and more defensible benchmarking process looks like in practice — especially in an environment where benchmarking analyses are becoming easier to test and challenge.