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Christine Schwarzl Authors Bloomberg Article on Post-COVID-19 Transfer Pricing Issues and Risks 

On 4 May 2022, Bloomberg Tax published an article written by Christine Schwarzl (Regional Transfer Pricing Director) on post-COVID-19 transfer pricing (“TP”) issues and how to manage the risks.

The recent global pandemic has profoundly impacted business models and global supply chains, resulting in significant changes to working patterns. Christine discussed the potential TP risks in her article and what taxpayers might do to manage these challenges in the years ahead. 

Christine reviewed three of the main factors that have influenced TP since the COVID-19 pandemic began more than two years ago: 

  • Global supply chain disruption and restructuring, including the pivot to digital commerce, has altered group entity profiles and remuneration.
  • The shift to the work-from-anywhere model has led to decentralized value creation and profit attribution, and other substantial issues.
  • Increased transparency through global reporting has resulted in an increased risk of disputes and the possibility of a voluntary compliance response. 

Christine also explained the risks and the steps taxpayers could take to manage them. We invite you to read the full article here