The Virus in the ALP, Issues from the Transfer Pricing Guidance on Risk and Capital in the light of the covid-19 pandemic

Abstract

In this article, the authors consider various policy, technical and practical implications of the transfer pricing guidance on risk and capital in the light of the COVID-19 pandemic, with special reference to the OECD Transfer Pricing Guidelines and the arm’s length principle.

Author/s

Richard S. Collier and Ian Dykes