fluid talk with
Graphene Economics
A 2-Part Executive Series on Transfer Pricing:
Towards Operational Clarity
fluid talk with Graphene Economics is a two-part Executive Webinar Series that gives senior tax and finance professionals a clear view of today’s transfer pricing landscape, the risk and scrutiny trends shaping oversight, and the operating model needed to respond.
Attendees will gain research-based insight, practical enablement frameworks, and a clearer understanding of how governance, data, and technology support defensible transfer pricing.
Sign up once to access both episodes.
Series Content Overview
Episode 1
The Transfer Pricing Landscape:
Towards Operational Clarity
Date: Thursday 14th May 2026
Time: 11:00am SAST / CEST
Episode 1 unpacks the forces reshaping transfer pricing oversight, using key research insights from the Graphene Economics 2025 Annual Transfer Pricing Report to frame the current landscape adressing:
- intensifying pressure across jurisdictions
- what AI changes and what it does not?
- the new audit dynamic
what this means for transfer pricing professionals?
- survey insights and 2025/26 trend signals
- internal business trends reshaping exposure
- compliance and data complexity
- repricing trends in operational transactions
- disputes, controversy, and resolution patterns
- technology and automation developments
- lessons from recent transfer pricing controversies
The episode builds a structured picture of an environment that is more coordinated, more data centric, and more operationally scrutinised than before. The session closes with a practical framework recommendation that sets the foundation for operational enablement in Episode 2.
Episode 2
The Transfer Pricing Landscape:
From Recommendation to Operational Enablement
Date: Thursday 11th June 2026
Time: 11:00am SAST / CEST
Episode 2 translates insight into implementation. It answers the executive question that naturally follows Episode 1: If operational clarity is required, what must be built?
The Operational Enablement Framework
Episode 2 introduces a structured four layer model.
- • Governance Model
Clear pricing ownership, defined approval checkpoints, structured escalation processes, and regular senior finance oversight. - • Data Flow Architecture
A mapped flow from commercial systems to ERP processing, to structured tagging layers, to centralised data hubs, culminating in reporting and documentation outputs. - • AI Enablement
Application of AI to anomaly detection, pattern recognition, variance analysis, and documentation assembly, enhancing visibility and speed while preserving professional judgment. - • Technology Infrastructure
Centralised data environments, automated transaction classification, reusable compliance architecture, and multi jurisdiction readiness.
Speakers
Michael
Hewson
Director | Founder
Graphene Economics
Michael Hewson is the Founder and Director of Graphene Economics, a specialist transfer pricing advisory firm. He has more than 20 years of transfer pricing experience across Africa and previously served as a partner at a Big Four firm where he supported transfer pricing teams across the continent. Graphene Economics was named African Transfer Pricing Firm of the Year by the International Tax Review in 2023 and South African Transfer Pricing Firm of the Year in 2021 and 2025. Michael advises large multinational enterprises and regularly presents internationally on transfer pricing policy and controversy.
April
Mckenzie
Executive Director | Tax
Graphene Economics
April McKenzie is Executive Director at Graphene Economics with 14 years of experience in tax and transfer pricing, including a decade focused exclusively on transfer pricing advisory. She has led complex multi-country documentation projects for multinational groups across industries including mining, FMCG, financial services, fintech, telecommunications, and commodity trading. Her work spans transfer pricing compliance, model design, financial modelling, data analytics, Pillar Two safe harbour analysis, and Country-by-Country reporting. April also supports multinational organisations in managing transfer pricing disputes and enquiries with revenue authorities across Africa.
Chris
Cochrane
Founder & CEO
fluid
Chris Cochrane is the Founder and CEO of fluid and a leading voice in tax automation. With more than 15 years in financial technology and SaaS innovation, he has built AI-driven platforms that help multinational organisations automate complex global tax compliance processes. Chris specialises in the intersection of tax governance, data architecture, and automation, enabling teams to move beyond fragmented spreadsheet-driven processes toward structured, auditable systems that support defensible compliance and faster response to scrutiny
Chris Cochrane is the Founder and CEO of fluid and a leading voice in tax automation. With more than 15 years in financial technology and SaaS innovation, he has built AI-driven platforms that help multinational organisations automate complex global tax compliance processes. Chris specialises in the intersection of tax governance, data architecture, and automation, enabling teams to move beyond fragmented spreadsheet-driven processes toward structured, auditable systems that support defensible compliance and fasterresponse to scrutiny.
Why Attend?
Key Take-outs from the Series
