CRA Principal, Alberto Pluviano, reviews a report published by the French Ministry of Finance that analyzes the technical issues related to transfer pricing regulation in the French system compared with other countries and proposes new measures that would tighten the French transfer pricing regulations. The report also includes comments regarding permanent establishment issues.
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...