Adapting Transfer Pricing Strategies

Navigating the Impact of COVID-19 on Canadian Businesses

Adrianne Markell, Jim Muccilli
| 5/27/2024

Amid the COVID-19 pandemic, multinational corporations (MNCs) encountered unprecedented challenges while navigating Canada's transfer pricing landscape. The outbreak disrupted global supply chains, altered consumer behavior, significantly affected global resource allocation, sales/production strategies and how businesses distributed profits and determined arm’s length prices in intra-group transactions.

One of the most profound effects of the pandemic on transfer pricing was the disruption of traditional business models and operating structures. When widespread remote working arrangements and travel restrictions were in place, the delineation of functions, assets, and risks among related entities became increasingly complex. As a result, MNCs must reevaluate their transfer pricing policies to accurately reflect the new economic realities of their operations post-pandemic. Questions around whether these changes are permanent or temporary have remained unresolved and further complicate the assessment.

Supply chain disruptions also forced companies to reassess their transfer pricing strategies. Fluctuations in demand, production delays, and inventory shortages necessitated adjustments to pricing arrangements to ensure business continuity while maintaining compliance with regulations. Moreover, the increased use of alternative sourcing arrangements and changes in procurement patterns have implications for how transfer prices are determined within multinational groups.

The pandemic has highlighted the importance of financial resilience and risk management in transfer pricing planning. As businesses navigated economic uncertainty, the allocation of risks and corresponding returns among related entities came under heightened scrutiny by tax authorities. MNCs were forced to demonstrate that their transfer pricing policies reflected the arm's length principle and accurately captured the risks assumed by each entity within the group.

In response to these challenges, the Canada Revenue Agency (CRA) provided guidance to assist businesses in navigating the transfer pricing implications of COVID-19. This included recommendations on how to address disruptions to supply chains, changes in demand patterns, and the allocation of COVID-19-related costs within multinational groups. The CRA also emphasized the importance of thorough documentation and proactive communication with tax authorities to address transfer pricing issues that arose during the pandemic.

Looking ahead, the impact of COVID-19 on transfer pricing is likely to continue to evolve as businesses try to predict and adapt to the landscape. MNCs must remain vigilant in monitoring changes to their operating environments and reassessing their policies accordingly. By maintaining transparency, documentation, and compliance with transfer pricing regulations, businesses can successfully navigate the challenges created by the pandemic and contribute to a more resilient and equitable tax system in Canada. 


This article has been prepared for the general information of our clients. Please note that this publication should not be considered a substitute for personalized advice related to your situation.

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Adrianne Markell
Adrianne Markell
Partner, Valuations | Forensics | Litigation
Adrianne Markell Professional Corporation
Jim Muccilli
Jim Muccilli
Partner, Valuations | Forensics | Litigation
Jim Muccilli Professional Corporation