Companies got long-awaited help Friday for ensuring that their pandemic-era cross-border arrangements don’t run afoul of the tax authorities.
The Organization for Economic Cooperation and Development’s guidance addresses four issues companies are currently struggling with: comparability analysis; losses and the allocation of Covid-19-specific costs; government assistance programs; and advance pricing agreements.
Companies have been asking for answers by year-end on key transfer pricing questions posed by this year’s pandemic, to help them avoid double taxation and disputes with tax authorities. Transfer pricing is how companies value their intercompany transactions.
The guidance reflects the consensus view of the 137 jurisdictions that ...