Commentary

A8.109 Transfer pricing and coronavirus (COVID-19)

Administration and compliance

A8.109 Transfer pricing and coronavirus (COVID-19)

A8.109 Transfer pricing and coronavirus (COVID-19)

The OECD has published new guidance for tax administrations and businesses on the application of transfer pricing rules during the coronavirus (COVID-19) pandemic. The pandemic has led to practical challenges for taxpayers and tax administrations in applying and administering transfer pricing rules which are used to calculate how much profit should be allocated among the different jurisdictions where a business operates.

A number of tax administrations have consequently published domestic guidance on some of the transfer pricing implications arising from coronavirus. The two-sided nature of transfer pricing means that only through a common agreed

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