IP in an AI Era - TP Challenges for MNEs

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IP in an AI Era
Transfer Pricing Challenges for Multinationals

15 September 2026, 2:00p.m. – 3:00p.m. SG

How artificial intelligence is reshaping IP ownership, valuation and audit risk under the OECD transfer pricing framework.

Artificial intelligence is fundamentally changing how intellectual property is created, enhanced and commercialised. Traditional transfer pricing concepts such as DEMPE and Significant People Functions were built for human‑centric innovation, not machine‑driven value creation.

This webinar explores how AI‑generated IP, training data and algorithmic development are testing existing transfer pricing frameworks, and how tax authorities such as the ATO are responding. Drawing on practical experience advising multinational groups across Australia and Asia‑Pacific, TPS will outline what in‑house teams should be doing now to future‑proof their IP and transfer pricing positions.

Agenda outline (~60min)

AI and IP Value Creation – Why machine‑driven innovation strains existing TP frameworks
DEMPE, Data and Valuation Challenges – Ownership, control and pricing of AI‑generated IP
Audit Reality and Regulatory Focus – How tax authorities are using AI to test TP outcomes
Practical Takeaways for Multinationals – Designing defensible IP frameworks in the AI era
Q&A

Learning Objectives

By the end of this session participants will:

Understand how AI‑driven innovation challenges traditional IP ownership and DEMPE analysis.
Identify key transfer pricing risks arising from AI‑generated IP and data‑driven value creation.
Gain practical insights into how multinationals can maintain audit‑ready, defensible IP frameworks in the AI era.

Why You Should Attend

AI is no longer a future consideration. It is already reshaping how value is created and scrutinised by tax authorities. Multinationals that rely on legacy IP and transfer pricing models face increasing audit and Pillar Two risk.

This webinar provides a practical, non‑theoretical discussion grounded in real audit experience, helping in‑house teams understand what matters now and how to respond before issues arise.

Delivered by a director‑led, ex‑Big 4 team from a Tier 2 transfer pricing firm recognised across Australia and Asia‑Pacific, this session is designed to give you clarity, confidence and actionable insights.

About the Facilitator

Ms Adriana Calderon
Director, Asia and Malaysia - Transfer Pricing Solutions Asia
Accredited Tax Advisor (Income Tax)

Adriana is the co-founder of Transfer Pricing Solutions Asia. She has extensive international experience with Big Four and mid-tier firms advising multinational companies in the areas of corporate and international taxation across South America, the US, Australia and the Asia Pacific Region. As a Transfer Pricing practitioner, Adriana has advised companies in the Asia Pacific Region across various industries and in a wide range of projects associated with planning, compliance and dispute resolutions with tax authorities. She has also participated in specialised projects involving pricing of financial transactions, business restructures and negotiation of APAs. Most recently, she has participated in transfer pricing planning projects to implement BEPS’s Action Plan and country-by-country reporting.

Adriana also enjoys teaching and is a regular speaker and facilitator of Transfer Pricing seminars and workshops. She is a transfer pricing trainer for the Institute of Singapore Chartered Accountants and Singapore Institute of Accredited Tax Professionals. Adriana has also facilitated training sessions for CFOs, tax teams of large companies and consultancies, and tax executives at the Australian Taxation Office. In addition, Adriana is also SCTP’s representative for the TP Roundtables organised by the tax authority.

IP in an AI Era

AI‑driven innovation is exposing gaps in legacy IP and transfer pricing models. Our webinar explores how tax authorities are responding – and how multinationals can stay audit‑ready.

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