This article analyses in detail the methodologies that could be used to apply COVID-19 comparability adjustments to the comparable companies selected in transfer pricing benchmark analyses. Specifically, the article investigates linear regression analyses based on (i) costs (variable and fixed) resulting from a change in revenues; (ii) variable costs resulting from a change in revenues with the subsequent application of specific sensitivity analysis for fixed costs in view of the operating model of specific industries; and (iii) revenues and costs (variable and fixed) resulting from a change in GDP or specific industry statistics.