During the COVID-19 pandemic, governments’ overriding concern has been public health and controlling the spread of the virus while at the same time trying to help enterprises manage the impact of the decline of business activity and workers facing a decline in employment opportunities and income.
OECD COVID-19 TPG paragraph 61
Category: TPG2020 Guidance on the transfer pricing implications of the COVID-19 | Tag: COVID-19, Government assistance, Government interventions
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- OECD COVID-19 TPG paragraph 64The availability, substance, duration and take-up of these programmes potentially have transfer pricing implications, whether the government assistance is provided to a member of an MNE group directly or made available to independent parties within the market where an MNE group operates (thus...
- OECD COVID-19 TPG paragraph 86Finally, when applying a one-sided method such as the resale price method, the cost plus method, or the TNMM, the accounting treatment of the government assistance in both the tested party and any comparable may need to be specifically identified, especially when the...
- OECD COVID-19 TPG paragraph 60Government assistance is a monetary or non-monetary programme where a government or other public authority provides a direct or indirect economic benefit to eligible taxpayers such as grants, subsidies, forgivable loans, tax deductions, or investment allowances. For example, a government may directly subsidise...
- OECD COVID-19 TPG paragraph 62Job retention programmes have been used in many jurisdictions to preserve jobs in enterprises experiencing a temporary reduction in business activity.34 Examples of these programmes include short- term work programmes that directly subsidise hours not worked35 and wage subsidy programmes that subsidise hours...
- OECD COVID-19 TPG paragraph 76The economic circumstances of the market in which the party receiving government assistance operates could also influence the pricing of the accurately delineated controlled transaction. Subject to the specific facts and circumstances, aspects such as the level of competition, the elasticity of the...
- OECD COVID-19 TPG paragraph 92Most APAs include critical assumptions about the operational and economic conditions that will affect the transactions covered by the APA. The COVID-19 pandemic and the response of governments have dramatically affected the economic and market conditions and are likely to qualify as a...
- OECD COVID-19 TPG paragraph 1The impact of coronavirus (“COVID-19”) has been profound. The rapid spread of the virus has strained local medical infrastructures, led to restrictions on travel and social contact, and created unprecedented disruptions to the global economy....
- OECD COVID-19 TPG paragraph 109Where taxpayers and tax administrations are negotiating APAs that are intended to cover FY2020, all parties are encouraged to adopt a flexible and collaborative approach to determine how to take into account the current economic conditions, and the various options discussed above in...
- EU Report on Improving the Functioning of the Arbitration Convention (2015)In April 2015 the Forum agreed on a Report on Improving the Functioning of the Arbitration Convention including a revised Code of Conduct for the effective implementation of the Arbitration Convention. The report and the revised Code of Conduct are the result of...
- OECD publishes Guidance on Pricing of Minerals6 November 2023 OECD published a transfer pricing framework on determining the price of minerals. The framework provide guidance for developing countries to accurately delineate the transaction and price mineral sales on an arm’s length basis. Specifically, it identifies the primary economic factors that...