OECD COVID-19 TPG paragraph 78

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Under the guidance in Chapter II of the OECD TPG, when establishing arm’s length prices using one-sided methods, particular care must be taken to avoid adopting without further analysis a particular mechanical approach (such as offsetting cost savings achieved through government assistance against the relevant cost base for the transaction; recognising government assistance as revenue; or recognising government assistance as extraordinary income) since this could lead to non-arm’s length prices in transactions among associated parties.

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