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…
International rules for taxation of digital economy progress next stage
In mid-October, the OECD released for public comments its revised rules for the taxation of the digital economy. The final version of the rules including draft legislation is planned to be issued in mid-2021. The rules are still based on a two…
July G20 summit and digital economy taxation
The July G20 summit in Saudi Arabia, a meeting of finance ministers and central banks governors of the world’s major developed and emerging economies, brought a certain shift in their effort to set global rules for the taxation of the digital…
Postponement of digital economy taxation in both CR and other world countries
Despite assurances made in early March that the COVID-19 pandemic will not slow down negotiations on new international taxation rules applicable to the digital economy, the OECD has now made it clear that it is no longer certain that agreement will…
Czech Republic deposits MLI with OECD depositary
On 13 May 2020, the Czech Republic deposited its instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in Paris. So far, the MLI has been signed by 94…
Impact of governmental measures on the application of double taxation treaties
In response to the extraordinary governmental measures adopted in the context of the COVID-19 pandemic (e.g. restriction of travel, quarantine), the OECD has released a recommendation to address certain tax implications of a temporary change of the…