OECD Guidelines for Transfer Pricing during the COVID-19 Pandemic in Thailand

notadminArticle, Insight, Tax

Taxpayers and tax administrators around the world are grappling with the unprecedented impact the COVID-19 pandemic is having on transfer pricing arrangements.

On 18 December 2020, the OECD published the much-awaited “Guidance on the transfer pricing implications of the COVID-19 pandemic”.

The Guidance represents the consensus view of the 137 members of the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) regarding the application of the arm’s length principle and the OECD Transfer Pricing Guidelines to transfer pricing issues in the context of the COVID-19 pandemic.