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Our cofounders Hugo Chary and Thibaut Roques wrote an article on MNE Tax on “Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches“.
This article emphasizes the need to update transfer prices to reflect new market conditions following the COVID-19 crisis, and in particular when relying on the TNMM/CPM method: “[…]Existing comparable company searches rely on past data, not reflecting the current economic turmoil. As a result, they cannot be relied upon anymore – and shouldn’t, to avoid overpaying taxes and facing significant tax risks. One way to address this issue is to adjust existing comparable company searches to reflect new market conditions. This article discusses why some commonly used adjustments do not work and proposes how to compute robust ones.[…]”
You can find the full article here: https://mnetax.com/transfer-pricing-in-the-times-of-covid-19-dos-and-donts-for-adjusting-comparable-company-searches-38783