The longer-term effects of the Covid-19 pandemic continue to make themselves known in the TP world, as companies consider how to make appropriate adjustments, and how to make comparability analysis work in this landscape. The pandemic also accelerated the adoption of technology and sales of intangibles, with inevitable consequence for TP teams. Meanwhile, tax disputes continue with activity in some courts picking up after a lull during the height of the pandemic. The 22nd edition of Transfer Pricing guide also outlines the OECD's two-pillar global tax solution, Italian case law on intercompany loans, the deductibility of management fees in real estate funds, the consideration for intra-group TP transactions, the death of Libor in Indonesia, country-by-country reporting and Google's TP strategy.
