Strategizing International Tax Best Practices – by Keith Brockman

TP 2020 & COVID 19

As COVID 19 ravages the world, the world of transfer pricing will also feel extraordinary consequences.  The attached articles from Rödl & Partner highlight transfer pricing considerations in China, which can apply in most other countries, and a COVID 19 tax summary of each EU Member State’s relevant developments, updated daily.

Highlights of China’s TP considerations:

  • Subsidiary losses: should they be borne by the Principal?
  • Intra-group financing, including thin capitalization, loss compensation (although contract adjustments require relevant approvals prior to taking effect), and guarantee fees
  • Adjustment of transfer pricing methods

It should be noted that current year comparables will include many loss making companies due to COVID 19, thus advance thinking may be necessary prior to year-end.

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