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: 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.
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…
Effect of COVID-19 on transfer pricing of intra-group loans
The current pandemic puts pressure on firms to keep positive cash flows and cash balances. Multinational groups are thus facing the issue of financing their companies. In the most affected industries, access to bank loans has worsened, leading to an…
COVID-19 and intra-group services – a transfer pricing perspective
Implementing emergency plans, trying to keep a positive cash flow, or monitoring the quick succession of legislative changes adopted in connection with the coronavirus pandemic – these have become corporate management’s daily bread. Remuneration…
COVID-19 and transfer pricing
While liberation packages may mitigate the immediate effects of the COVID 19 pandemic on businesses’ financial performance, sooner or later, enterprises that are part of multinational chains (MNEs) will have to deal with the crisis’ consequences for…
Watch out for tax inspections! Companies drawing investment incentives surprised by transfer pricing issues
Apart from loss-making companies, tax administrators now systematically target transfer pricing in profit-making companies that draw investment incentives.