How can multinational companies mitigate the impact of Covid-19 on their Transfer Pricing reviews?

The Covid-19 pandemic will have serious implications on transfer pricing for many multinational companies (MNEs) in the upcoming years.

In December 2020, the OECD released its Guidance that clarifies and illustrates the practical application of the arm’s length principle as articulated in their Transfer Pricing Guidelines.

Four priority issues were identified and covered in the Guidance:

  • Comparability analysis
  • Losses and the allocation of Covid-19 specific costs
  • Government assistance programmes
  • Advance Pricing Agreements (“APAs”)   

 Zarejestruj się

On the agenda:

  • How does OECD Guidelines address the impact of COVID-19 on Transfer Pricing?
  • Key take-aways for 2020
  • What should MNEs need to consider for the end of 2021?
  • What should MNEs do to prepare for the following years?


  • Frédéric Barat, Partner at Mazars France
  • Elisabeth Tchumburidze, Manager at Mazars Germany
  • Karen Lau, Director at Mazars China