There are a range of issues that could arise for transfer pricing purposes, due to the impact of coronavirus (COVID-19). Intra-group contracts The starting point for a transfer pricing analysis will be the terms and conditions of a legal contract, and therefore clauses in intra-group contracts relating to termination or force majeure could be important in considering whether, and if so how, the coronavirus epidemic will impact arrangements between group entities. Third party contracts in similar circumstances may provide an arm’s length example of how intra-group arrangements may also be renegotiated in this current environment, whether that means changes to payment term durations, the related party fee itself or the need for compensation payments. Allocation of losses Given the broader financial impact that coronavirus has had and will continue to have, one of the key transfer pricing questions will be how this affects profit (or loss) allocation among group entities. The crisis will clearly result in a significant reduction