Interpreneur insight: Managing transfer pricing risk
September 10, 2026
Managing transfer pricing risk is no longer simply a compliance exercise. For international businesses, it is increasingly connected to value creation, profit allocation, governance and risk management — and deserves attention at the highest levels of an organisation.
For the Interpreneur Report, we spoke to 1,100 mid-market business leaders across 11 countries and asked them 11 key questions about their experience of going global. We covered challenges, opportunities and expectations for the future, and the results offer real insight into mapping the route to interpreneurial success.
In this latest Interpreneur podcast episode, Kreston Global expert Jose Padilla, Tax and Legal Partner at Kreston BSG, is joined by Yessica Valor, Regional Senior Tax Manager, North and Central America, Tetra Pak, and Martin Bonner, Chair of the Kreston Global Transfer Pricing Group and Partner and Tax Advisor, AREA Bollenberger.
Across six short episodes, the panel explores how the transfer pricing environment is changing as businesses and tax authorities gain access to more data, technology transforms tax administration and international tax, customs and regulatory requirements become increasingly interconnected.
From the strategic importance of transfer pricing and the impact of AI to APAs, MAPs, regional differences and proactive risk management, the series offers practical perspectives on how multinational businesses can combine global governance with the local expertise needed to operate effectively across different jurisdictions.
Watch and listen
Episode one: Introducing the experts
Meet the panel behind the series and hear about the international experience they bring to the discussion.
Yessica shares insights from more than 20 years working across different industries and advisory roles and her current responsibilities across North and Central America. Martin discusses a career spanning more than 15 years in transfer pricing, including both industry and advisory roles, and his work as Chair of the Kreston Global Transfer Pricing Group.
Episode two: The growing relevance of transfer pricing
Why should transfer pricing be considered a strategic business issue rather than simply a tax compliance requirement?
Yessica, Jose and Martin explore how transfer pricing has become increasingly connected to value creation, profit allocation and risk management. Greater transparency between jurisdictions, automated information exchange and developments in international taxation mean multinational businesses need greater consistency in how their transfer pricing positions are developed and communicated.
The discussion considers why transfer pricing is moving out of the tax back office and becoming an issue that senior leadership should understand.
Episode three: Global trends in transfer pricing
Technology, tariffs and greater transparency are reshaping the transfer pricing landscape — but they are also changing how different areas of tax interact.
In this episode, the panel explores the increasing connection between transfer pricing, customs and other tax disciplines. As customs authorities make greater use of transfer pricing documentation and tax authorities gain greater visibility of multinational transactions, businesses need to consider how decisions and arguments made in one area could affect another.
The speakers also discuss the growing role of AI and automated tools, and why businesses need accurate, consistent information if they are to keep pace with increasingly sophisticated tax authorities.
Episode four: Managing transfer pricing risk proactively
When tax authorities have access to more information than ever before, how can multinational businesses stay ahead of potential transfer pricing disputes?
The panel discusses proactive approaches to risk management, including Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs) and bilateral mechanisms that can help businesses create greater certainty around their international operations.
They also examine how tax audits are changing. Rather than beginning by trying to understand a business, authorities can increasingly use digital information to identify discrepancies before an audit begins. For businesses, that places greater emphasis on data quality, technology, analytics and cross-functional collaboration.
Episode five: Balancing global strategy with local expertise
Can a multinational business apply one transfer pricing approach everywhere?
Jessica and Martin discuss the different levels of regulatory maturity, implementation and tax authority scrutiny across Europe, Latin America, the US and individual jurisdictions such as Brazil.
While global policies, monitoring and governance provide essential consistency, the panel argues that successful implementation requires local knowledge. Involving local specialists can help businesses understand how international principles are interpreted in individual jurisdictions and identify potential controversy before it develops into costly disputes.
The result is a model that combines global alignment with informed local implementation.
Episode six: Advice from the experts
What should international tax and transfer pricing leaders prioritise as the environment continues to evolve?
In the final episode, Jessica and Martin bring together the central themes of the series. Their advice is to combine local expertise, regional knowledge and global governance while strengthening communication, organisational learning and proactive risk management.
Transparency and access to real-time data are also increasingly important. Rather than waiting for an audit to reconstruct the rationale behind a transfer pricing position, businesses should develop and document that position as decisions are made.
The message is clear: effective transfer pricing requires global consistency without losing sight of local realities. By bringing together the right expertise, governance and data, businesses can put themselves in a stronger position to anticipate risk, respond to scrutiny and support international growth.
