Читать книгу Global Tax Governance. Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs + ADR) Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas онлайн

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Considering the above, it is crucial that enterprises limit any changes to their tax strategies to what is strictly required to comply with the current restrictions. In any case, each and every enterprise should assess the tax treatment of employees and activities on a case by case basis, to ensure that all relevant facts and circumstances are duly considered.

Transfer Pricing policies must ensure compliance with the arm’s length principle, even under the present exceptional circumstances. The multinationals’ main challenge though is to evidence through their transfer pricing documentation that registration of losses or low profits is due to the COVID-19 crisis, e.g. not due to transfer pricing manipulations. With this in mind, enterprises must:

• Produce appropriate documentation in support of the economic results registered and reflecting the current conditions through the use of proper comparable data;

• Perform appropriate transfer pricing adjustments to justify the re-distribution of functions, activities and risks among the various entities of the group, taking into account the impact of the crisis to the supply chain.