Transfer pricing: otherwise related persons and arm’s length price

The Supreme Administrative Court (SAC) has recently closed several cases dealing with the assessment of otherwise related persons - a concept from the area of transfer prices between group companies.

Germany: New transfer pricing guidelines

Transfer pricing is a hot issue at a time when all finance ministries are searching for funds to cover their exorbitant budget deficits. The German Ministry of Finance has issued new…

Transfer pricing remains under tax administrators’ scrutiny

The financial administration has published information about its tax inspections focusing on transfer prices between related parties. In 2020, tax administrators carried out 249 inspections, assessing additional corporate income tax of CZK 1.4…

Transfer pricing - comparability analysis in times of COVID-19

The unprecedented changes in the economic environment following the outbreak of COVID-19 have created unique challenges for setting prices in intra-group transactions. The correct setting or verification of transfer prices for the past year while…

OECD on loss situation due to COVID

Lower levels of demand. Disruptions to supply chains. Increases in exceptional, nonrecurring operational costs. These are the key factors which have led to a loss situation faced by many companies of multinational groups during the COVID-19 pandemic…

OECD guidance on the transfer pricing implications of the COVID-19 pandemic

The unique economic conditions arising from COVID-19 and government responses to it have resulted in challenges for the application of the arm’s length principle. To enhance tax certainty in the face of such challenges, the Organisation for Economic…

Landmark case-law: softer penalties for transfer prices incorrectly set by companies receiving investment incentives

The Supreme Administrative Court (SAC) has issued a ground-breaking judgment for companies drawing investment incentives under older schemes. The court confirmed that the failure to meet the condition not to increase the tax base for calculating tax…

COVID-19 and transfer pricing policy – comparability analysis

With the economic downturn brought about by the COVID-19 pandemic, companies face the challenge of determining whether they should modify their transfer pricing policies. The decision…