OECD Guidance on the transfer pricing implications of the Covid-19 pandemic

The Covid-19 pandemic has far-reaching consequences and will have serious implications on transfer pricing for many multinational enterprises. In December 2020, the OCDE released its Guidance in order to clarify and illustrate the practical application of the arm’s length principle as articulated in the OECD Transfer Pricing Guidelines.

Four priority issues were identified and are covered in the Guidance:

  • comparability analysis;
  • losses and the allocation of Covid-19 specific costs;
  • government assistance programmes; and
  • advance pricing agreements (“APAs”).

Following a worldwide internal think tank and the organization of a webinar, Mazars transfer pricing experts would like to share their view on the OECD publication through this report.


Mazars OECD Guidance
Mazars OECD Guidance