In this Tax Notes article, Robin Hart discusses how to reevaluate transfer prices based on market conditions caused by COVID-19 and mitigate complexities associated with year-end processes. Robin also examines how (re)structuring intercompany transactions with high upfront payments can be effective in deploying cash within a multinational group.
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...