CRA Principal, Paul Wilmshurst, provides a brief introduction to two key transfer pricing documents released by the OECD on July 30, including a “Revised Discussion Draft on Transfer Pricing Aspects of Intangibles” and a “White Paper on Transfer Pricing Documentation.”
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...