- Chapter II. - Losses and Allocation of COVID-19 Specific Costs
- Introductions
- Can entities operating under limited risk arrangements incur losses?
- Under what circumstances may arrangements be modified to address the consequences of COVID-19?
- How should operational or exceptional costs arising from COVID-19 be allocated between related parties?
- How should exceptional costs arising from COVID-19 be taken into account in a comparability analysis?
- How many force majeure affect the allocation of losses derived from the COVID-19 pandemic?
- Chapter I. - Comparability Analysis
- Introduction
- What source of contemporaneous information may be used to support the performance of a comparability anaylsis applicable for FY 2020?
- Can budgeted financial information be used to support the setting of arm's length prices?
- Under what circumstances are timing issues not pronounced?
- What practical approaches may be available to address information deficiencies?
- Can data from other crises be used to support price setting?
- How might the period of data used to evaluate arm's length pricing be established to support a comparability analysis?
- Would price adjustment mechanisms be apporpriate?
- What actions may be taken to evaluate the set of comparable companies or transaction used?
- Can loss making comparables be used?
- Chapter III. - Government Assistance Programmes
- Introduction
- Is the receipt of government assistance an economically relevant characteristic?
- Is guidance on other local market features relevant when anaysing the transfer pricing implication of government assistance?
- Does the receipt of government assistance affect the price of controlled transactions?
- Does the receipt of government assistance modify the allocation of risk in a controlled transactions?
- Does the receipt of government assitance affect the comparability analysis?