OECD finally releases guidance on transfer pricing implications of Covid-19

The OECD released guidance about the transfer pricing implications of the COVID-19 pandemic on December 18th 2020.

This guidance represents the consensus view of the 137 members of the Inclusive Framework on BEPS regarding the application of the arm’s length principle and the OECD Transfer Pricing guidelines to transfer pricing issues that may arise as a result of the COVID-19 pandemic.

It provides comments and illustrations of, the practical application of the arm’s length principle in four issues :

  1. comparability analysis;
  2. losses and the allocation of COVID-19 specific costs; 
  3. government  assistance  programs;  and 
  4. advance pricing agreements.


This OECD guidance is consistent with Mazars’ webinars, recommendations and publications released since April 2020. Mazars will comment the OECD guidance in the coming weeks through new articles and new webinars which will provide further clarity on these issues. We invite you to follow us. In the interim, do not hesitate to contact us should you have immediate questions.