On 18 December 2020 the OECD released “Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic”. The guidance focuses on how the arm’s-length principle and the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“TP Guidelines”) apply to issues that may arise from or be exacerbated by the Covid-19 pandemic. The guidance focuses on four priority issues:
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