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There is now extensive, although still fragmented and not fully perfectly aligned (if not outright contradictory), guidance on COVID-19 related Transfer Pricing (TP) issues coming from a number of sources.

Based on what we see from the OECD and various tax authorities, it is fair to expect that the focus will be on the following key issues:

How much attention is devoted to those areas is affected by the government spending in the context of the COVID-19 crisis, which leads some to expect increased scrutiny of TP in general and treatment of the interaction between TP and pandemic related subsidies and costs in particular.

OECD perspective

The OECD Transfer Pricing Guidelines contain limited direct guidance with respect to the issues arising from the COVID-19 crisis. Given the lack of clear guidance, it is expected that the OECD will issue some additional commentary to cover the key COVID-19 related TP issues, including the issue of whether managed margin / limited risk entities should be protected from losses incurred as a result of COVID-19, or how the financial consequences of the crisis should be shared between group companies.