Tuesday, 22 December 2020

Guidance on the transfer pricing implications of the COVID-19 pandemic

The OECD has released guidance on transfer pricing implications of the COVID-19 pandemic. This guidance represents the consensus view of the 137 members of the OECD/G20 Inclusive Framework on BEPS regarding the application of the arm’s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the COVID-19 pandemic.

The guidance covers the following priority issues:

  1. Comparability analysis

  2. Losses and the allocation of COVID-19 specific costs

  3. Government assistance programmes

  4. Advance pricing agreements (“APAs”)

The report provides a helpful guidance for both tax administrations and taxpayers.

The OECD Report is available here.