Cum vor arăta prețurile de transfer după COVID-19?
What will transfer pricing look like after COVID-19?

Summary/Abstract: The COVID-19 crisis is likely to have significant implications for many companies’ transfer pricing policies. Disruption, changes to commercial flows, new ways of doing business and potentially lower profits will all affect what companies’ 2020 transfer pricing files will look like. This presents challenges from a compliance perspective, especially as tax authorities throughout the world are now particularly keen to protect revenue. Therefore, companies should consider whether they need to adjust their transfer prices. If changes have occurred to profitability and some subsidiaries are now making losses, they should prepare careful documentation to demonstrate this. Determining economic losses may require sophisticated economic modeling and income-based analysis. Care should be paid to benchmark studies, as these are one year behind and may not accurately reflect the arm’s length nature of transactions in 2020. Some long term analysis will be needed, to consider how transfer pricing positions might evolve over the next few years.

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