Monitor Podatkowy

no. 3/2021

Shaping contract relations and verification of transfer prices according to the market price principle in the face of crisis caused by the COVID-19 pandemic

DOI: 10.32027/MOPOD.21.3.5
Marcin Czerwiński
Autor jest doktorem nauk prawnych, radcą prawnym oraz supervisorem w KPMG Tax M. Michna sp.k., biuro w Poznaniu.
Anna Wieśniak-Wiśniewska
Autorka jest młodszym managerem podatkowym w KPMG Tax M. Michna sp.k., biuro w Poznaniu.
Abstract

The pandemic influences global tax arena, including the transfer prices area. Countries are forced to search for new tax influences and to that end they are prone to use instruments within transfer prices. Within the present article, the authors show problems connected with shaping, realization and documentation made in 2020 and 2021, and propose solutions, including new guidelines from the OECD regarding the influence of the COVID-19 pandemic on transfer prices. The authors analyzed tools connected with contracts between related parties and proposed a strategy to prepare comparative analyses and use comparative revisions. They also deliberate on conditions regarding the method of determining or verifying transfer prices during the pandemic.