OECD issues transfer pricing guidance relating to COVID-19 pandemic

On December 18, 2020, the OECD published detailed guidance on the transfer pricing implications of the COVID-19 pandemic.

The guidance discusses the practical application of the arm’s length principle in the following four priority issues identified in consultation with Business at the OECD: comparability analysis; losses and the allocation of COVID-19 specific costs; government assistance programmes; and advance pricing agreements (APAs).

The guidance represents the consensus view of the 137 members of the Inclusive Framework on BEPS regarding the application of the arm’s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the COVID-19 pandemic.
​
See Guidance