Transfer Pricing Considerations Resulting from COVID-19

Emerging Issues that should be proactively considered

Thomas Herr

Thomas Herr

Principal, Tax - National Leader Transfer Pricing Services, KPMG US

Prita Subramanian

Prita Subramanian

Principal, Economic & Valuation Services, KPMG US

+1 617-988-1260

Mark R. Martin

Mark R. Martin

Principal, Head of Tax Controversy & Dispute Resolution, Washington National Tax, KPMG US

+1 713-319-3976

COVID-19 significantly affected the global marketplace. As a result, transfer pricing issues emerged that should be proactively considered, including:

  • Financial transactions
  • Intercompany contracts
  • Managing disruption
  • Intangibles
  • Remote work
  • Operational transfer pricing
  • Tariffs
  • Dispute resolution and APAs

KPMG LLP's transfer pricing professionals—who are members of our Economic & Valuation Services practice—can help your company deal with transfer pricing challenges. We are supported by global transfer pricing professionals from other KPMG International firms around the world, helping us look beyond borders and understand the nuances of different national regulations.

Survey of Global Secondary Adjustment Rules
January 4, 2021 | Download PDF to read about the complexities inherent in secondary adjustment rules and details those rules in the United States and other jurisdictions globally.
State Transfer Pricing Trends and Opportunities Accelerated by COVID-19
November 16, 2020 | Download pdf to read about recent state transfer pricing trends and how they have been affected by the COVID-19 pandemic.
Current topics in asset management transfer pricing
October 30, 2020 | Download pdf to read about COVID implications to asset management transfer pricing, including: cash repatriation; cash outlay pressures; and intercompany financing.
Transfer pricing considerations resulting from COVID-19
June 8, 2020 | Download pdf to read about the transfer issues companies are addressing in today's environment.


COVID-19 Transfer Pricing Implications for Intercompany Loans

May 4, 2020 | Download PDF to read the greater care that should be taken when implementing or modifying intercompany debt funding to help ensure that the financing is respected as debt and the interest expense is deductible for tax purposes.