Today's General Counsel, Summer 2020

Page 32

SUMMER 2020  TODAY’S GENER AL COUNSEL

Compliance

Covid Brings Transfer Pricing Issues By Paul Sutton

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s multinational groups respond to the challenges and opportunities presented by the coronavirus outbreak, many of them need to update their transfer pricing policies and internal supply chains, as well as their outwardfacing business operations. General coun-

sel have a key role to play in ensuring that the legal aspects of these transitions are managed appropriately. This article provides a brief recap on the essential role of inter-company agreements in transfer pricing compliance. Transfer pricing relates to the charges

made between associated entities such as companies within a group. Tax authorities may challenge the amounts of those charges, and this may give rise to a risk of double or multiple taxation of the same profits. Legal agreements between those entities — often referred to as inter-


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