Developing a Transfer Pricing Policy Framework for the Current Economic Crisis and Beyond

The COVID-19 outbreak has brought abrupt changes to the supply chains of many multinational enterprises. The economic crisis sparked by the pandemic will potentially distort arm’s length conditions based on which transfer prices are set and regulated. This article retraces historical interactions between economic crises and transfer pricing regimes and identifies bottlenecks in applying the arm’s length principle during the crisis. It highlights the need for international organizations, taxpayers and tax administrations to develop a targeted policy response framework to deal with such challenges of the present and the future.