Finally, the COVID-19 pandemic has created conditions in which associated parties may consider whether they have the option to apply force majeure clauses, revoke or otherwise revise their intercompany agreements. This may impact the allocation of losses and COVID-19 specific costs between associated parties, and therefore also requires specific consideration in the current economic environment.
OECD COVID-19 TPG paragraph 37
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Asymmetrical splits of profits and losses, COVID-19, COVID-19 specific costs, Force majeure, Losses, Renegotiation of the existing contractual arrangements
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