Industry Insights on CompPress | Transfer Pricing Resources

Transfer Pricing in the Consumer Goods Sector: A Sector Deep Dive

Sun, 12 Apr 2026 00:00:00 +0000

The consumer goods sector covers companies that produce and sell goods to end consumers, including consumer packaged goods (CPG), apparel and footwear, consumer durables, beauty and personal care, and food and beverage. This article addresses transfer pricing issues that are common across these sub-segments. Consumer electronics (which sits closer to technology hardware), tobacco and alcohol (which raise distinct excise tax considerations), and luxury goods (which have a more concentrated brand-IP profile) raise additional issues that are not addressed in detail here.

Transfer Pricing in Artificial Intelligence: A Sector Deep Dive

Sat, 11 Apr 2026 00:00:00 +0000

As of early 2026, neither the OECD nor the United States Treasury has issued transfer pricing guidance specifically directed at AI businesses. The OECD’s planned 2026 revision of the Transfer Pricing Guidelines may eventually address some of the issues discussed below, but the current authoritative position is that AI businesses are subject to the same general framework as any other multinational group. The analysis that follows applies the existing framework to AI fact patterns and is explicit where the application is settled, where it is contested, and where it is genuinely unsettled.

Transfer Pricing in the Technology Sector: A Sector Deep Dive

Fri, 10 Apr 2026 00:00:00 +0000

The technology sector is the umbrella category that encompasses software, Software-as-a-Service (SaaS), digital platforms, and emerging artificial intelligence businesses. This article focuses on the software sub-segment, where SaaS has become the dominant business model, and treats artificial intelligence as an emerging set of issues at the end.

For most groups in the software sub-segment, transfer pricing analysis differs from the standard playbook in three respects: most of the value lives in intangibles rather than in routine functions, value creation is typically distributed across multiple jurisdictions, and stock-based compensation is large enough relative to operating costs that its tax treatment matters in ways it does not in other sectors.