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...
Robin Hart is a Principal within the Transfer Pricing Practice. Robin is a highly regarded transfer pricing and tax economist with 17 years of experience serving clients in the life sciences, technology, and consumer products sectors.
He has assisted taxpayers with their strategic objectives relating to the transfers and licensing of intangible property, alignment of supply chains, the establishment of high-value and shared service centers, and intercompany financing. Focused primarily on innovative Bay Area companies, Robin has executed on cross-border and domestic transactions involving cost-sharing and IP planning, post-acquisition integration, global BEPS alignment, the launch of new digital business models, and business restructurings. Projects have included feasibility and planning, U.S. and OECD Action 13 documentation, APA submissions, ASC740-10, and audit defense. His recent experience includes assessing IP strategies in light of U.S. tax reform and BEPS for high growth medical device, biotechnology and fintech companies. Prior to joining CRA, Robin was a Managing Director with Deloitte Tax in San Francisco.