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Performing a Comparability Analysis during an Economic Downturn

Since December 2019, countries have witnessed the widespread impact of COVID-19 on economic activity, global value chains and profitability across most industries and geographical areas.
As is the case in all periods of uncertainty, as governments try to tackle the crisis with measures that stimulate economic growth such as tax reliefs and investment incentives, tax authorities have focused to a greater extent on setting transfer pricing (TP) policies in order to verify the reason and the nature of the contraction registered in the financial statements of firms.
Hence, companies undertaking inter-company transactions should adapt their TP models to the current economic and financial conditions, in order to ensure that internal policies reflect the potential reallocation of functions, activities and risks within the multinational group.

Pubblicato su: International Tax Review (ITR) – 24 aprile 2020


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