30092014_LOGO_HECKELCONSULTING1.jpg
30092014_LOGO_HECKELCONSULTING1.jpg
TPCENTER - Logo plain
TPCENTER - Logo plain
  • Chapter II. - Losses and Allocation of COVID-19 Specific Costs
  1. Introductions
  2. Can entities operating under limited risk arrangements incur losses?
  3. Under what circumstances may arrangements be modified to address the consequences of COVID-19?
  4. How should operational or exceptional costs arising from COVID-19 be allocated between related parties?
  5. How should exceptional costs arising from COVID-19 be taken into account in a comparability analysis?
  6. How many force majeure affect the allocation of losses derived from the COVID-19 pandemic?
  • Chapter I. - Comparability Analysis
  1. Introduction
  2. What source of contemporaneous information may be used to support the performance of a comparability anaylsis applicable for FY 2020?
  3. Can budgeted financial information be used to support the setting of arm's length prices?
  4. Under what circumstances are timing issues not pronounced?
  5. What practical approaches may be available to address information deficiencies?
  6. Can data from other crises be used to support price setting?
  7. How might the period of data used to evaluate arm's length pricing be established to support a comparability analysis?
  8. Would price adjustment mechanisms be apporpriate?
  9. What actions may be taken to evaluate the set of comparable companies or transaction used?
  10. Can loss making comparables be used?
  • Chapter III. - Government Assistance Programmes
  1. Introduction
  2. Is the receipt of government assistance an economically relevant characteristic?
  3. Is guidance on other local market features relevant when anaysing the transfer pricing implication of government assistance?
  4. Does the receipt of government assistance affect the price of controlled transactions?
  5. Does the receipt of government assistance modify the allocation of risk in a controlled transactions?
  6. Does the receipt of government assitance affect the comparability analysis?
  • Chapter IV. - Advance Pricing Agreements
  1. Introduction
  2. What impact does COVID-19 have on existing APAs?
  3. What impact does COVID-19 have on APAs under negotiation?

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