Multinational groups should review transfer pricing policies

Maricla Pennesi, Partner and Head of Tax area, and Stefano Rossi, Partner, delve deeper into the impact of the health emergency on transfer pricing policies in an article published by Il Sole 24 Ore.

Following the inconveniences caused by the global spread of the Covid-19 virus, multinationals groups were forced to edit supply contracts appealing to the MAC, and evaluating alternatives to implement contractual obligations.

To deal with the emergency, companies are gradually changing the contents of intercompany contracts, especially as regards the structure of functions, risks, and assets to support the definition of new financial and commercial conditions.

In the article, the professionals also evaluate the potential critical issues during the tax audit and in the context of the advance pricing agreements signed or being defined.

The guidelines released by the Organization for Economic Cooperation and Development (OECD) on transfer pricing (chapter IX) could be considered as a point of reference in the application of the principle of free competition, recognizing the impact of the large scale of the global pandemic on transfer pricing policies.