Transfer Pricing Times – Second Quarter 2020

In the “Considerations Around Intercompany Financial Transactions During the COVID-19 Crisis” article, we discuss how companies may have risks and opportunities associated with their intercompany funding arrangements. 

In “The Compensation of DEMPE Control Functions in Post-BEPS Transfer Pricing” article, we provide a possible approach for addressing situations where IP ownership and control of DEMPE functions aren’t fully aligned.

In the “What Can We Expect From Latin American Governments for Transfer Pricing in the COVID-19 Aftermath?” article, we summarize how Latin American authorities may react to extraordinary economic circumstances as it relates to transfer pricing based on administrative, regulatory and litigation outcomes from prior crises or from otherwise challenging environments.

In the “IRS Releases Transfer Pricing Documentation FAQs in Effort to Improve Quality” article, we review the main topics covered in the IRS Transfer Pricing FAQs and provide observations and implications under the current economic environment in the face of the COVID-19 pandemic.

Finally, in the “Transfer Pricing Developments in Canada” article, we provide a summary of transfer pricing developments in Canada, with a particular focus on the status of important regulatory and administrative guidance.

We hope that you will find this and future issues of Duff & Phelps' quarterly transfer pricing newsletter informative.