The impact of the economic crisis on transfer pricing

The impact of the economic crisis on transfer pricing will cover the following subjects:

• How does the 2022 crisis impact the profitability of limited risk affiliated entities?
• Can comparability studies take into consideration the effects of the crisis?
• What are the consequences of the 2022 crisis on the intragroup financing?
• How should multinational entities (MNEs) manage the consequences of the crisis during tax audits?

Mazars’ position is taken in light of the OECD Transfer Pricing Guidelines published in January 2022, and the OECD Guidance on the transfer pricing implications of the Covid-19 pandemic published on 18 December 2020, which provides comments on the application of the arm’s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the crisis (hereinafter “OECD Guidance”).