Transfer Pricing Guidance for MNEs in the Wake of COVID-19 Webcast Replay

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The economic disruption caused globally by countries’ responses to the spread of COVID-19 has generated a range of pressing transfer pricing questions to be addressed by multinational enterprises (MNEs), without dedicated guidance tailored to the unprecedented circumstances.

In this webinar, our experts examined what steps can be taken by MNEs in the absence of official guidance to meet the challenges raised.

2020-10-30T00:00:00.0000000 /insights/webcasts-and-videos/webcast-replay-transfer-pricing-guidance-mnes-covid-19 webcast {4C8AF8F6-BAEC-4E94-ACC7-7AC0F36685FC}

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Duration: 1 hour


  • What lessons can be drawn and applied from the limited guidance that has been produced (e.g., by the Australian Taxation Office)?
  • Does existing benchmarking remain valid and, if not, how does one identify relevant comparables?
  • To what extent can parallels be drawn from outcomes during the financial crisis?
  • What evidence will be needed to support changes to transfer pricing policy?
  • What are the common transfer pricing considerations regarding country-specific COVID-19 support initiatives?
  • Should head offices continue to recharge expenses related to management services to their subsidiaries?
  • What are the implications of falling profitability and interest coverage ratios for intragroup lending?
  • Is it acceptable to apportion losses to limited risk distribution, manufacturing and service entities?


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