The continued economic impact of corona across the globe has forced and accelerated businesses' process to review their existing commercial arrangements and operations. Enterprises have taken stock of corona's effect on their business models, financials, and supply chains.
The multi-national enterprises ( MNE ) that transfer pricing policies are a critical part of this assessment, and they need to reflect their present or future economic reality and not the past.
Also, any existing transfer pricing documentation can provide little or no protection in the fiscal authority challenge. Shortly, tax authorities will want to collect as much of the appropriate MNE tax as justifiable and according to legislation and established principles.
Multi-national enterprises must examine their concurrent documentation of transfer pricing policies, and other evidence, including contractual arrangements, to ensure transfer pricing outcomes still reflect the value-added in the supply chain. The reexamination may reduce cash amount spent on non-essential items for compliance, and other tax-related matters.
The challenge in this pandemic is to keep one's transfer pricing policies up-to-date and relevant. They should reflect the existing commercial reality and operational of one's business, be agile and responsive.
Nevertheless, there's a consensus among fiscal authorities that despite the challenges of maintaining contemporaneous documentation, it is business.