COVID-19 Transfer Pricing Guidance

Duration: 1 hour 15 minutes

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Learning Objectives

IP Valuation

• Identifying the issues and opportunities around changing IP valuations resulting from the economic impact of COVID-19
• Potential impacts on carrying values associated with acquired intangibles and goodwill
• Best practices for IP valuations so that they withstand scrutiny of financial statement auditors and tax authorities including discussion of the issues around forecasts, discount rates, multiples and other common valuation benchmarks

Benchmarking

• Limitations of relying on one-sided pricing methods in crisis environments
• Decision criteria for changing transfer pricing policies now vs. staying the course
• Practical considerations for setting or revising targets, and implementing policies
• Comparability factors that may become more sensitive due to COVID-19
• Implications of internal contracts and historic divisions of risk within a multinational group

Tax Administration

• Awareness of the OECD’s guidance to tax administrations
• Comprehension of the impact of COVID-19 on APAs, MAP discussions, litigation, audits and documentation deadlines
• Familiarity of available resources to find latest tax policy and tax administration developments
• Understanding of tax administrations’ relaxation of enforcement of permanent establishment rules during the COVID-19 travel restrictions

Presenters

• Simon Webber, Managing Director, U.S. Transfer Pricing Services, Duff & Phelps
• Fabian Alfonso, Managing Director, Latin American Transfer Pricing Services, Duff & Phelps
• Ted Keen, Managing Director, EMEA Transfer Pricing Services, Duff & Phelps
• Matt Billings, Managing Director, Canada Transfer Pricing Services, Duff & Phelps
• David Ptashne, Director, U.S. Transfer Pricing Services, Duff & Phelps