OECD COVID-19 TPG paragraph 71

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In particular, by analogy to section D.6.2 of Chapter I of the OECD TPG, the analysis of the implications of the receipt of government assistance would need to consider the following factors (not only to identify reliable market comparables when they exist, but also in cases where such comparables cannot be identified):

  • whether the receipt of government assistance provides a market advantage to the recipient;
  • the amount of any increase in revenues, decrease in costs, vis-à-vis those of reliable comparables, that are attributable to the government assistance received, and the duration of the assistance;
  • the degree to which benefits of government assistance, at arm’s length, are passed on to independent customers or suppliers (see paragraph 76); and,
  • where benefits attributable to government assistance exist and are not fully passed on to independent customers or suppliers, the manner in which independent enterprises operating under similar circumstances would allocate such benefits between them.

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