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ARTICLE · 30 DECEMBER 2020

OECD Releases Helpful New Guidance On Transfer Pricing During The Pandemic

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On 18 December 2020, the OECD published its much-anticipated "Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic".

LuxembourgTax

On 18 December 2020, the OECD published its much-anticipated "Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic".

It is clear that government restrictions and trading difficulties have created an environment in which existing transfer pricing policies will not always be appropriate. The OECD has done well to reach rapid consensus among its members on four key transfer pricing topics, namely: comparability analysis, losses and the allocation of COVID-19-specific costs, government assistance programmes and advance pricing agreements (APAs). It is hoped that taxpayers and tax administrations will be able to apply this guidance and circumvent the increase in disputes that would otherwise emerge.

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