OECD Policy Responses to Coronavirus (COVID-19)

This series compiles data, analysis and recommendations on a range of topics to address the health, economic and societal crisis, facilitate co-ordination, and contribute to the necessary global action when confronting this enormous collective challenge. Bringing together policy responses spanning a large range of topics, from health to education and taxes, it provides guidance on the short-term measures in affected sectors and a specific focus on the vulnerable sectors of society and the economy. The content also aims to provide analysis on the longer-term consequences and impacts, steering the way towards a strong, resilient, green and inclusive recovery with co-ordinated policy responses across countries.

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Guidance on the transfer pricing implications of the COVID-19 pandemic

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.

English Also available in: French, German

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