Watching last week's thriller of a World Series (or at least as much as my 9:15 PM bedtime would accommodate), I like millions of others was awed by Shohei Otani, the once-in-a-lifetime superstar of the victorious Los Angeles Dodgers. Capable of throwing 100-mph fastballs and then turning around to crush 480-ft home runs, the pitcher-slugger is Hall of Fame worthy on not one but multiple counts. Beholding such feats of dual-threat dynamism, my mind naturally drifted to transfer pricing and the lessons my profession could glean from Major League Baseball.
For decades transfer pricing was regarded as a niche profession, its practitioners highly specialized in the dark arts of setting and defending prices charges between members of multinational groups. You could call us designated hitters, brought into the game for one specific, if crucial, function. We excelled at our narrowly-defined role, and handed off to other colleagues when things strayed too far beyond our core competency.
Fast forward to 2025, and multinational enterprises and CPA firms are on the hunt for TP Otanis. International tax and trade matters are far too complex and integrated to treat any aspect of a planning project or audit as siloed, and cost pressures and technological developments mean employers are looking to do more with less when it comes to subject matter experts and consultants. Today's transfer pricing all-stars are therefore boasting literacy in technical accounting, customs, indirect tax, and management consulting. Clients are no longer satisfied with being handed a jargon-filled, context-light economic analysis. They want to know how to implement it, whether it will scale with the business, and what compliance or managerial issues may arise. In other words, they want someone who can both hit and pitch. You'll see evidence of the same happening in industry, where TP-related job postings increasingly feature hyphenated roles.
None of this is to say that modern transfer pricing practitioners must be a full-on expert in every TP-adjacent discipline, but they must be sufficiently knowledgeable to ask the right questions, cover a wide array of angles, and bring in the expert support required by each unique situation. As the Toronto Blue Jays learned the hard way, an all-around player backed by a deep bullpen is hard to beat.
Make a habit of sustained success.
