There's always going to be opportunities for transfer pricing planning as long as countries have different tax rates. For example under the new rules it's still possible to use planning involving intellectual property such as brands or royalties, as long as there is real commercial substance attached to that planning.
The risks involved in doing tax planning under these rules are that if it's not done properly the tax authorities can challenge you. They can charge you additional tax going back to earlier years, they can charge you interest and penalties, and of course there is reputational risk.
If the tax authority thinks that a company has done something wrong, that information may be made public and that causes a boardroom issue as well as a tax department issue. Businesses need to think about tax planning in the new environment; the rules have changed, tax planning is still possible but they need to think about commercial value.
Businesses can't do tax planning in isolation; it has to be actually wedded to real commercial operations. As long as that principle is adhered to then most companies should still be able to undertake tax planning.
Download a copy of the transfer pricing help sheet.