Transfer pricing documentation requirements have globally become increasingly universal, and certain transfer pricing positions are also widespread. As the economy continues to suffer from the COVID-19 pandemic, it begs the question as to why some transfer pricing positions have not been reassessed. A globally accepted axiom includes a low-risk distributor (LRD) or low-risk service provider (LRSP), and it states these both can never lose money. The current COVID-19 crisis and its resulting economic downturn warrant a review of this view.

Learn more from our international practice advisors at Moore Doeren Mayhew, as they further explore the LRD and LRSP issues which need to be considered and performed in a recent article, which can be read here.