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Transfer pricing in the context of pandemic – OECD Guidance


by Dominika Tyczka-Szyda

8 January 2021


The OECD published Guidance on the transfer pricing implications of the pandemic in December 2020.


It is intended to assist taxpayers reporting controlled transactions in financial periods that have been adversely affected by the pandemic. It is also to support tax administration representatives in assessing taxpayers' implementation of their transfer pricing policies.


As indicated in the report: “Guidance on the transfer pricing implications of the COVID-19 pandemic represents the consensus view of the 137 members of the Inclusive Framework on BEPS regarding the application of the arm's length principle to transactions carried out by associated enterprises. The document mainly refers to the existing OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration.”


The Guidance covers four priority issues:

  • comparability analysis;
  • losses and the allocation of COVID-19 specific costs;
  • government assistance programmes;
  • advance pricing agreements.


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Dominika Tyczka-Szyda

Tax adviser (Poland)


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