OECD takes action on Covid-19 and transfer pricing

The challenges of COVID-19 emergency on the international tax compliance of the Multinational Groups are addressed by the recent publication “Guidance on the transfer pricing implications of the COVID-19 pandemic” released by OECD on December 18,2020.

In the revised economic scenario, cooperation and flexibility between taxpayers and Tax Authorities are envisaged to properly delineate the intercompany transactions. In that regard, the OECD Guidance identifies four main priorities:

1. The consequences on the comparability analysis;
2. The treatment of losses and allocation of COVID-19 specific costs;
3. The implications of government assistance programmes and actions;
4. The effects on APA procedures.

The attached newsletter presents the recent indications to navigate through the current uncertainties.

Should you require any further information or clarification on any aspect of this newsletter please contact cmslegaltax@cms-aacs.com