Comparability Analysis under COVID-19 Circumstances in Light of the OECD Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic

This article depicts potential future scenarios that MNEs may have to face in the near future in light of the recent Guidance on the transfer pricing implications of the COVID-19 pandemic issued by the OECD. To this end, such scenarios are developed through a practical example that shows how year-end transfer pricing adjustments may be influenced by the pandemic according to the recommendation provided by the above-mentioned guidance.