The ongoing pandemic is causing a global recession for 2020, and the expectations for 2021 are gloomy as well.

In this context, the question arises on how to address transfer pricing issues caused by this unexpected deterioration in the economic performance of multinational groups and the dramatic changes in financial requirements.

As a matter of principle, the OECD suggests that a MNE may suffer genuine losses caused by unfavorable economic conditions. However, at the same time, it is questionable whether, and to which extent, risks and losses are attributable to limited risk entities.

In the end, MNE will have to decide whether to apply existing transfer pricing policies on a consistent basis, or instead to renegotiate the terms and conditions of the commercial relationships.

The fact that the prevailing market conditions in 2020 are not comparable with recent years poses additional challenges in the preparation of reliable benchmarking analyses.

The webinar will address these topics, by discussing four simple cases:

- Supply of goods

- Benchmarking studies

- IP licensing

- Loans and guarantees

SPEAKERS

Marc Alms – Managing Director at Alvarez & Marsal Taxand – US

Stefano Bognandi – Partner at LED Taxand – ITALY

Carsten Quilitzsch – Partner at Flick Gocke Schaumburg– GERMANY

Dong Hun Lee – Senior C.P.A. at Yulchon – SOUTH KOREA