On 18 December 2020, the OECD published guidance on the transfer pricing implications of the COVID-19 pandemic. --- ABOUT This Guidance clarifies and illustrates the practical application of the arm's length principle as articulated in the OECD Transfer Pricing Guidelines to the unique fact patterns and specific challenges implied by the COVID-19 pandemic. It was developed and approved by the 137 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (Inclusive Framework). Embodied in the OECD's Committee on Fiscal Affairs (CFA), the Inclusive Framework was developed in 2013 to allow interested countries and jurisdictions to work with...