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Guidance On The Transfer Pricing Implications Of The Covid 19 Pandemic
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Book Synopsis Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic by :
Download or read book Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic written by and published by . This book was released on 2020 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In response to the COVID-19 crisis, a number of tax administrations have already published domestic guidance on some of the transfer pricing implications of COVID-19. While this is an important first step in setting taxpayer expectations, facilitating co-operative compliance and delivering greater tax certainty, the two-sided nature of transfer pricing means that it is only by agreeing a common approach that tax administrations can enhance tax certainty. This Guidance clarifies and illustrates the practical application of the arm's length principle as articulated in the OECD Transfer Pricing Guidelines to the unique fact patterns and specific challenges implied by the COVID-19 pandemic. Four priority issues were identified and are covered in the Guidance: (i) comparability analysis; (ii) losses and the allocation of COVID-19 specific costs; (iii) government assistance programmes; and (iv) advance pricing agreements (APAs). This Guidance was developed and approved by the 137 members of the OECD/G20 Inclusive Framework on BEPS. While it is recognised that some Inclusive Framework members may also follow the United Nations Practical Manual on Transfer Pricing for Developing Countries (2017), this Guidance should be helpful in such circumstances where the UN Manual follows a similar analytical framework and allows for similar conclusions as the OECD Transfer Pricing Guidelines.
Book Synopsis Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic by : Organisation for Economic Co-operation and Development
Download or read book Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic written by Organisation for Economic Co-operation and Development and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Comparability Analysis Under COVID-19 Circumstances in Light of the OECD Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic by : M. Orlandi
Download or read book Comparability Analysis Under COVID-19 Circumstances in Light of the OECD Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic written by M. Orlandi and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article depicts potential future scenarios that MNEs may have to face in the near future in light of the recent Guidance on the transfer pricing implications of the COVID-19 pandemic issued by the OECD. To this end, such scenarios are developed through a practical example that shows how year-end transfer pricing adjustments may be influenced by the pandemic according to the recommendation provided by the above-mentioned guidance.
Book Synopsis 2020 Documenting Transfer Pricing Under Pandemic Circumstances by : Brigitte Baumgartner
Download or read book 2020 Documenting Transfer Pricing Under Pandemic Circumstances written by Brigitte Baumgartner and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The author addresses the COVID-19 transfer pricing challenges, covering the steps for analysing transfer pricing implementation, documentation processes and adjustments in 2020. The article is based on the OECD Guidance on the transfer pricing implications of the COVID-19 pandemic and the OECD Transfer Pricing Guidelines 2017.
Book Synopsis Transfer Pricing Aspects to Consider During COVID-19 by : A. Dushime
Download or read book Transfer Pricing Aspects to Consider During COVID-19 written by A. Dushime and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors discuss adjustments that companies might make in light of the coronavirus pandemic, as well as their related transfer pricing implications.
Book Synopsis Determining Arm's Length Prices in a COVID-19 World : ATO Issues Three Sets of Guidance by : M. Butler
Download or read book Determining Arm's Length Prices in a COVID-19 World : ATO Issues Three Sets of Guidance written by M. Butler and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines three publications issued in June and July 2020 by the Australian Taxation Office (ATO) that provide the ATO's views on the implications of the COVID-19 pandemic for transfer pricing arrangements.
Book Synopsis Transfer Pricing Practice During COVID-19 by :
Download or read book Transfer Pricing Practice During COVID-19 written by and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Questions: The Spring/Summer 2020 issue is being put together as the world is experiencing an event with an unusual effect on countries' economies - the COVID-19 pandemic. This issue explores whether and how countries are reacting to the transfer pricing tax effects of a turbulent economic environment. 1. Per the OECD, the impact of the COVID-19 pandemic on economic activity would far outweigh anything experienced during the global financial crisis in 2008-09. What similarities and differences do you see between the 2008 crisis and the current pandemic so far on the practice of transfer pricing in your jurisdiction? 2. Business performance as a result of the COVID-19 pandemic: a. What do you see as the impact of the COVID-19 pandemic on low-risk entities (which typically bear limited risks, and record limited profit margin when the principal entity incurs a loss) in your jurisdiction? Do you see your jurisdiction accepting that such entities can lose money during this unusual economic downturn? b. Are there MNEs in your country who are experiencing or likely to experience increased or expanded business opportunities despite the current pandemic? What strategies should these entities be mindful of with regard to their transfer pricing models? c. How are MNEs in your jurisdiction addressing comparability issues, or how would you advise them to address comparability issues? How should they treat loss-making comparables, to ensure that any adjustments factor in the current global epidemic and adequately reflect economic reality? d. How likely are the tax authorities in your jurisdiction to consider "economic circumstances" as a relevant comparability factor? 3. How do you see the pandemic affecting APAs? What adjustments are MNEs making - or what adjustments should they make - to ensure that they will be considered to be in compliance with their agreements? Are companies looking to amend (or should they look to amend) their APAs, or are they just documenting changes in anticipation of possible future amendments? 4. Do you think there is a "silver lining" or bright spot about this economic situation that MNEs should be mindful of? What are possible opportunities that otherwise would not be sustainable in the absence of an economic crisis? Reset possibilities? Location-specific advantage?
Book Synopsis The Virus in the ALP. by : R.S. Collier
Download or read book The Virus in the ALP. written by R.S. Collier and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors consider various policy, technical and practical implications of the transfer pricing guidance on risk and capital in the light of the COVID-19 pandemic, with special reference to the OECD Transfer Pricing Guidelines and the arm's length principle.
Book Synopsis The Impact of the COVID-19 Pandemic on Advance Pricing Agreements by : B. Gibert
Download or read book The Impact of the COVID-19 Pandemic on Advance Pricing Agreements written by B. Gibert and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).
Book Synopsis Transfer Pricing Developments Around the World 2022 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2022 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.
Book Synopsis COVID-19 Disruption : International Tax and Transfer Pricing Issues by : K.J. Tan Majure
Download or read book COVID-19 Disruption : International Tax and Transfer Pricing Issues written by K.J. Tan Majure and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article focuses on some of the significant international tax and transfer pricing issues arising from companies' disruption activities. First, the authors discuss the tax implications of cash flow planning, with a primary focus on the interaction of certain provisions in the newly-enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136,and the TCJA. Further, they discuss common international tax and transfer pricing issues related to R&D, supply chain, and remote workforce responses to the COVID-19 pandemic.
Book Synopsis Transfer Pricing of Financial Transactions and the Impact of COVID-19 by : M. Bonekamp
Download or read book Transfer Pricing of Financial Transactions and the Impact of COVID-19 written by M. Bonekamp and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing has been impacted before by global (economic) crises, such as the bursting of the dot com bubble in the early 2000s, which disrupted the internet and technology sector. More recently, the banking/financial crisis, starting in 2008, had severe consequences for the world economy and the liquidity of many companies. Transfer pricing arrangements, and especially financial transactions, have been and will continue to be vulnerable to extreme circumstances impacting the overall economic environment. This article focuses on the impact of the COVID-19 pandemic on the transfer pricing of financial transactions, especially intercompany loans and guarantees, from an OECD and Dutch perspective.
Book Synopsis Transfer Pricing Guidelines in 2020, Transfer Pricing Impact on Loans and Financial Transactions, Transfer Pricing Impact on Distribution Arrangements by : Malik Hill
Download or read book Transfer Pricing Guidelines in 2020, Transfer Pricing Impact on Loans and Financial Transactions, Transfer Pricing Impact on Distribution Arrangements written by Malik Hill and published by . This book was released on 2021-02-14 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt: As we all know COVID 19 pandemic has triggered the most severe recession in 2020 and is causing enormous damage to the world economy. Obviously, the economic downturn will have an impact on group Transfer Pricing analysis and documentation especially given that Transfer Pricing is definitely a hot topic across the world and a big issue and challenge that needs to be dealt with in multinational groups, as the author exposes in detail throughout this monograph.
Book Synopsis COVID-19 Economic Crisis : Impact on Transfer Pricing by : S. Agrawal
Download or read book COVID-19 Economic Crisis : Impact on Transfer Pricing written by S. Agrawal and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: COVID-19 has resulted in major economic disruption and a drop in economic activity unprecedented in recent history. Cross-border dealings and international transactions will likely be impacted, as corporate enterprises explore different ways of keeping their operations running while remaining within the limits of government-prescribed restrictions. It is prudent for corporate enterprises to analyse any impact on their business due to the COVID-pandemic and revisit any inter-company policy now rather than later. This can be supported by maintaining contemporaneous and robust documentation which will be available with the enterprises at this juncture.
Book Synopsis Transfer Pricing and Loss Allocation for the COVID-19 Era by : B. Misle
Download or read book Transfer Pricing and Loss Allocation for the COVID-19 Era written by B. Misle and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors consider COVID-19's effect on transfer pricing and how the OECD's guidelines apply to loss allocation in an unforeseen crisis.
Book Synopsis The Impact of COVID-19 on Transfer Pricing : Issues Arising During the Economic Downturn and Possible Solutions by : M. Cataldi
Download or read book The Impact of COVID-19 on Transfer Pricing : Issues Arising During the Economic Downturn and Possible Solutions written by M. Cataldi and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyses whether limited-risk entities may bear under arm's length conditions a portion of the negative financial consequences deriving from the current COVID-19 disruption. Furthermore, the article offers an overview of the impacts of the COVID-19 emergency on the benchmark analyses for 2020, on transfer pricing documentation and on unilateral and bilateral advance pricing agreement (APA) procedures.
Book Synopsis Managing Transfer Pricing in the COVID-19 Economic Downturn by : H. Higinbotham
Download or read book Managing Transfer Pricing in the COVID-19 Economic Downturn written by H. Higinbotham and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors examine how businesses can use their intercompany transfer pricing systems to better manage losses resulting from the coronavirus pandemic.
