A comparability analysis that is solely based on financial information from the global financial crisis 2008/2009 would raise significant concerns (despite the obvious superficial similarities between that crisis and the current pandemic), given the unique and unprecedented nature of the COVID-19 pandemic and its effect on economic conditions, as well as the variability of the impact by business sector of the 2008/2009 crisis. In all cases, a comparability analysis should be performed by reference to the specific delineation of the controlled transaction, including its actual economic circumstances.
OECD COVID-19 TPG paragraph 25
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: COVID-19, Data from other crises, Financial crisis
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