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.
New Instruction D-34 and translation of TP Guidelines
The financial administration is unifying procedures to determine tax bases affected by transactions between associated enterprises, both domestic and cross-border.
Transfer prices and audits of financial statements
The beginning of each calendar year traditionally entails intensive work on audits of financial statements. Among multinational corporations in particular, accounting issues are very often closely connected to an audited entity’s cooperation with…
GFD: Assessing transfer prices and determining a permanent establishment’s tax base, revisited
In November, the General Financial Directorate published new Instruction D – 32, dealing with a binding assessment of the manner in which the price agreed between related parties and the tax base of a tax non-resident relating to activities…
Transfer price checks also in personal income tax inspections
Transfer prices between related parties remain a priority of tax administrators’ inspection activities. As much as the general public believes that this only concerns corporate entities and cross-border transactions, the recent Supreme…