Companies want and need to take action to deal with the uncertainty caused by COVID-19, or to take measures to enable their operations to weather possible outbreaks or similar events in the future. Those actions have transfer pricing implications, and if companies have an Advance Pricing Arrangement (APA), or are pursuing an APA, the uncertainty created by COVID-19 heightens the need for careful scrutiny of a company’s transfer pricing policy.

This article, part of Baker McKenzie and Bloomberg Tax's Special Report, provides insight into current considerations, pertinent experience from similar economic events in the past, and critical assumptions regarding APAs.

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