While the current economic upheaval is unprecedented, good planning based on lessons learned from prior downturns can help. Principals Robin Hart and Anna Soubbotina from CRA’s US Transfer Pricing group discuss practical steps to take now, before year end, to avoid prolonged exposure to 2020 Transfer Pricing risks. The discussion will cover what the pandemic means for intercompany contracts, benchmark results, year-end adjustments and financial statement impacts. Looking ahead to 2021, effective prioritization of corporate transfer pricing resources will be key. We will explore ways to focus on areas of highest impact.
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...