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...
Anna Soubbotina is a Principal within the Transfer Pricing Practice.
Ms. Soubbotina guides companies through the lifecycle of their controlled transactions, from international expansion to business and regulatory change, ongoing risk management and compliance, through to effective controversy resolution. She has advised Fortune 500 public and private companies on transactions involving the transfer and use of intangible, tangible and financial assets, as well as services, effectively balancing local regulatory requirements across over 200 tax jurisdictions.
In addition to advising companies on cross-border transactions, Ms. Soubbotina has developed tailored transfer pricing programs for companies in the life sciences, energy, technology and media industries, solutions for early-stage and private companies, and efficient Global Documentation processes for companies with multiple affiliates or transactions. She designs and implements solutions to complex business problems, frequently teaming with cross-functional company and external stakeholders, including law firms and tax accounting firms.
Prior to joining CRA, Ms. Soubbotina was with the Global Transfer Pricing practice of Deloitte Tax LLP for 13 years, leading project teams to execute transfer pricing and international tax projects, such as cost allocation, cost-sharing, uncertain tax position review, loan and guarantee pricing, intangible property valuation and restructuring, global documentation and planning. She also spent two years with Deloitte’s national office in Washington, DC developing best practices and technical advice for emerging areas in transfer pricing.
Ms. Soubbotina frequently presents on transfer pricing issues at industry conferences and has published articles in International Tax Review.