The Organisation for Economic Co-operation and Development (OECD) on December 18 issued Guidance on transfer pricing implications of the COVID-19 pandemic (the Guidance) as part of its efforts to provide policy recommendations to respond to the COVID-19 pandemic.
The 31-page document, which represents the consensus view of the 137 members of the Inclusive Framework on BEPS, is intended to provide guidance to help address challenges in applying transfer pricing rules in years impacted by the pandemic. The Guidance maintains that the arm’s-length principle (ALP) remains the applicable standard for purposes of evaluating controlled transactions in the economic environment shaped by the COVID-19 crisis.
