Welcome to this issue of Moore Global’s Transfer Pricing Brief. This is Issue No 4 of 2020, the year that will forever be remembered for the devastating worldwide coronavirus (COVID-19) pandemic.
This issue brings a special focus on Europe, North and East Africa and the Middle East, but we begin with two articles of general importance on issues arising from the economic impact of COVID-19.
Sven Helm, Global Transfer Pricing Collaboration Group leader, discusses how it may be possible to adjust for the effects of COVID-19 on the results of low-risk routine entities.
Natalie Bissoli of Bureau Plattner in Milan looks at how best to allocate intra-group losses arising from the pandemic. We then welcome introductions from member firms in Kenya, Morocco and Lebanon to the transfer-pricing situation in their countries.
Joy Bhatt of Moore JVB in Nairobi shows how transfer-pricing rules in Kenya have developed since their inception in 2006.
Kouds Bernossi of Moore Bernossi in Tangier surveys Morocco’s transfer-pricing rules from their first introduction in 2009, while
Hala Sakha of Moore Tabbal in Beirut explains how the Lebanese tax authorities apply transfer-pricing principles in the absence of explicit transfer-pricing rules and regulations.
We conclude with a survey of transfer-pricing rules, this year’s relevant jurisprudence and the impact of COVID-19 in France from
Nikolaj Milbradt of COFFRA in Paris.
We hope that you find much of interest in this Issue and wish all readers the compliments of the season and best wishes for what one hopes will be a New Year in which we see a gradual retreat of the coronavirus.