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The COVID-19 pandemic caused many businesses to suffer a decline in revenues and profits, even resulting in losses. MNEs’ responses to deal with this crisis touched the aspect of Transfer Pricing. MNEs are forced to make adjustments, prepare loss justifications, and face challenges to do comparability analysis. In order to tackle these issues, on 18 December 2020, the OECD released a report containing guidance on the transfer pricing implications of the COVID-19 pandemic.
Thus, what should be prepared in order to make a defendable 2020 transfer pricing documentation?
Darussalam
Managing Partner DDTC
Lenida Ayumi
Tax Researcher, DDTC Fiscal Research