The worldwide Covid-19 lockdown and its impact on the interpretation of OECD Transfer Pricing Guidelines

24/04/2020

Crowe TP Wednesday The worldwide Covid-19 lockdown and its impact on the interpretation of OECD Transfer Pricing Guidelines

OECD Secretary General Angel Gurría, in preparation for the G20 Virtual Summit unveiled the latest OECD estimates showing that the lockdown will directly affect sectors amounting to up to one third of GDP in the major economies. The OECD evaluated in the report dated April 14 2020 the initial impact of COVID 19 containment measures on economic activity (https://www.oecd.org//coronavirus/policyresponses/evaluating-the-initial-impact-of-covid-19-containment-measures-on-economic-activity/#figured1e120).

In the course of the Corona crisis, the focus of interest will shift to intra-group financing instruments such as loans, cash pooling, guarantees and liquidity guarantees to secure the liquidity of the group and to bridge any shortfalls. This dramatic development of the Covid-19 pandemic could of course not be reflected in the new OECD Transfer Pricing guidelines on Financial Transactions, published on 11 February 20202 .

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