https://resources.comp-press.com/tags/model-ip/ Recent content in Model IP on CompPress | Transfer Pricing Resources Hugo en-us Sat, 11 Apr 2026 00:00:00 +0000 https://resources.comp-press.com/articles/transfer-pricing-artificial-intelligence/ Sat, 11 Apr 2026 00:00:00 +0000 https://resources.comp-press.com/articles/transfer-pricing-artificial-intelligence/ <p>As of early 2026, neither the OECD nor the United States Treasury has issued transfer pricing guidance specifically directed at AI businesses. The OECD&rsquo;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.</p>