Transfer pricing (TP) audits are becoming more commonplace than ever. The breadth and depth of such audits have been increasing. The impact of COVID-19 pandemic will likely continue to drive this trend, especially as governments may seek to raise revenues via tax policy changes and associated enforcement.There is rarely one correct answer as to how to price a particular transaction in the TP area, and in fact, the Organisation for Economic Co-operation and Development (OECD) guidelines review a price within an arm’s length range. In addition, TP controversy can be further complicated by related or ancillary issues which may need...