The EY 2026 International Tax and Transfer Pricing Survey reveals that transfer pricing functions are failing to keep pace with AI adoption, regulatory pressure, and supply-chain complexity [1]. With 67% of teams still relying on spreadsheets [1] and data quality ranked as the top AI-readiness blocker by 38% of respondents [1], the gap between ambition and execution is wide. Channel partners, already investing heavily in AI consulting [2] and AI software [2], are positioned to capture significant advisory and implementation revenue by bridging this divide.
What is Covered in this Article
- Transfer pricing's three-front pressure crisis: policy change, supply-chain disruption, and regulatory scrutiny [1][1]
- The AI perception gap between tax leaders and transfer pricing practitioners [1][1]
- Data quality and accessibility as the leading AI-readiness blocker [1]
- Channel ecosystem growth trajectory and partner AI readiness [3][3]
- Strategic opportunity for partners combining data management, agentic tooling, and compliance automation [2][4]
The News: EY released its 2026 International Tax and Transfer Pricing Survey on November 4, 2026, drawing on responses from 1,000 transfer pricing leaders and stakeholders across 29 jurisdictions [1][1]. The findings paint a function under siege: 85% of respondents expect keeping pace with policy change to be difficult [1], and 97% report significant supply-chain transformation [1]. AI adoption lags badly, with tax leaders more than twice as likely as transfer pricing leaders to report AI deployment at scale (25% vs. 11%) [1], while 67% of teams still rely on spreadsheets or manual processes [1]. EY Global Transfer Pricing Leader Tracee Fultz noted that the opportunity goes beyond using AI to do the same work faster, emphasizing the need to improve inputs and connect evidence across the business.
Transfer Pricing's AI Gap Is a Channel Opportunity
Analyst Take: EY's survey is less a progress report than a pressure gauge [1]. Transfer pricing functions face simultaneous stress from regulatory complexity, supply-chain volatility, and an AI adoption curve they are clearly not climbing fast enough. The data exposes a market in need of outside expertise, and the channel ecosystem is well-timed to provide it [2][3].
A Three-Front Pressure Crisis Demanding Technology Solutions
Transfer pricing teams are not dealing with a single disruption; they are managing three at once. Policy volatility is the most immediate: 85% of respondents expect keeping pace with regulatory change to be difficult over the coming years [1]. Supply-chain transformation compounds the challenge, with 97% of leaders reporting significant disruption that creates new transfer pricing complexity [1]. Regulatory scrutiny adds a third layer, with 50% citing double taxation under Pillar One or Pillar Two as a high risk [1] and 58% ranking dispute avoidance as their top policy priority [1]. Together, these pressures create a clear demand signal for technology-enabled solutions. Manual processes cannot absorb this volume of change. The question is not whether these teams need modernization, but who delivers it.
The AI Perception Gap Reveals an Execution Problem
The most striking finding in EY's survey is not that AI adoption is low; it is that leadership and practitioners disagree on how low. Tax leaders report AI deployment at scale at a rate of 25%, more than double the 11% reported by transfer pricing leaders [1]. Transfer pricing leaders are twice as likely to report no AI use at all (19% vs. 9%) [1]. This divergence suggests that executive optimism is not translating into operational reality. The underlying reasons are structural: 73% of respondents say obtaining transfer pricing data is difficult or very difficult [1], and 67% still rely on spreadsheets or manual processes [1]. Meanwhile, 50% identify AI as a significant driver of change over the next three years [1], but only 17% currently use agents or machine learning to a large extent [1]. The gap between aspiration and execution is where channel partners can intervene most effectively.
Data Quality Is the Bottleneck, and the Channel's Entry Point
EY's survey identifies data quality and accessibility as the leading AI-readiness risk, ranked first by 38% of respondents [1]. This is not a coincidence for channel partners. AI consulting is the top growth-driving service category among channel partners in 2H 2026, cited by 86.7% of respondents [2], and AI software including copilots is the leading technology growth category at 78.3% [2]. Partners are not just selling into this gap; they are already operating inside it. More than half of channel partners report using AI agents internally [4], giving them hands-on experience with the agentic tooling that transfer pricing functions are only beginning to explore [1]. The alignment between where enterprise tax functions are stuck and where channel partners are investing is unusually precise.
Channel Market Growth Amplifies the Opportunity
The timing of EY's findings coincides with a channel market in accelerating expansion. Futurum Group's base-case forecast projects the Channel Ecosystems market reaching $41.8 billion by 2029 at a 36% CAGR [3], with year-over-year growth from $21.0 billion in 2025 to $25.7 billion in 2026 [3] driven substantially by AI software and consulting services. Partner confidence is high: 52% of channel partners describe themselves as leading edge in their ability to succeed in an AI-transformed market [2]. AI software growth expectations have remained consistently strong across both halves of 2026 [4]. However, partners should note that vendor-partner friction is a real risk, as major software and hardware vendors are expanding direct-service offerings in AI consulting and systems integration [5]. For channel partners targeting enterprise tax and compliance, domain-specific expertise in transfer pricing workflows is a meaningful differentiator against that competitive pressure.
The Channel Play: From Data Chaos to AI-Ready Infrastructure
EY's findings define the problem precisely enough to map a solution. Transfer pricing functions need three things: cleaner data pipelines, workflow automation that replaces spreadsheet dependency, and compliance tooling that can absorb regulatory change without manual rework. Channel partners who combine data management services with agentic AI tooling and compliance automation are positioned to address all three. The organizational challenge is equally important: only 37% of transfer pricing teams describe themselves as highly engaged or fully embedded with operational teams [1], and 60% rank stakeholder alignment as a top operational challenge [1]. Partners who can deliver both technical integration and change management advisory will capture the most durable revenue. The market is not waiting for a perfect solution; it is waiting for a credible one.
What to Watch
- Partner specialization: whether channel partners develop transfer pricing-specific AI offerings or continue selling horizontal AI consulting into this vertical [2]
- AI adoption rate: how quickly the 42% of transfer pricing teams focused on smaller AI use cases [1] progress to agent-based workflows through Q2 2027
- Data infrastructure investment: which enterprise tax functions prioritize data quality remediation as the prerequisite for AI deployment [1] heading into Q1 2027
- Vendor-partner friction: whether major software vendors expand direct-service offerings in tax and compliance AI, narrowing the channel opportunity [5]
- Regulatory catalyst: how Pillar One and Pillar Two enforcement timelines accelerate demand for automated compliance tooling among the 50% of respondents citing double taxation as a high risk [1]
Sources
1. EY survey finds business change is outpacing transfer …, EY, November 2026
2. 2H 2026 Ecosystems, Channels & Marketplaces Global Enterprise Decision Maker Survey Report, Futurum Research, August 2026
3. 2H 2025 Hyperscaler Marketplace Market Sizing & Five-Year Forecast, Futurum Research, December 2025
4. 1H 2026 Ecosystems, Channels & Marketplaces Global Enterprise Decision Maker Survey Report, Futurum Research, March 2026
5. Partners Weary on SaaS as Infrastructure Surges Again, Futurum Research, September 2026
Disclosure: Futurum is a research and advisory firm that engages or has engaged in research, analysis, and advisory services with many technology companies, including those mentioned in this article. The author does not hold any equity positions with any company mentioned in this article.
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