Companies Sharing of AI Agents Risks More Tax Fights

Mayer Brown partner Anthony Pastore was quoted in a Bloomberg Law article examining the transfer pricing and tax challenges that can arise when multinational companies share AI agents across affiliates. The article explores how the growing use of AI agents is creating uncertainty around whether such arrangements should be treated as services or intellectual property transactions, with significant implications for profit allocation and tax liabilities. Anthony noted that existing Treasury Department regulations governing cloud computing and digital content transactions may provide a useful framework for characterizing AI-related transactions until more AI-specific guidance emerges.