Transfer Pricing of Financial Transactions and the Impact of COVID-19

Abstract

Transfer pricing has been impacted before by global (economic) crises, such as the bursting of the dot com bubble in the early 2000s, which disrupted the internet and technology sector. More recently, the banking/financial crisis, starting in 2008, had severe consequences for the world economy and the liquidity of many companies. Transfer pricing arrangements, and especially financial transactions, have been and will continue to be vulnerable to extreme circumstances impacting the overall economic environment. This article focuses on the impact of the COVID-19 pandemic on the transfer pricing of financial transactions, especially intercompany loans and guarantees, from an OECD and Dutch perspective.