Transfer Pricing Planning Opportunities for 2021

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Key Takeaways

The beginning of 2021 is an ideal time for companies to consider their transfer pricing planning opportunities. In DHG’s most recent webinar, Samit Shah and StarTaxed’s Borys Ulanenko cover the variety of planning options around COVID-19, financial transactions and captive insurance. The following summarizes key takeaways from their discussion:

COVID-19 Planning

There are four main areas of guidance from the Organisation for Economic Co-operation and Development (OECD) around COVID-19:

  • Comparability Analysis: With the comparability analysis there is greater flexibility around less relevant comparability search criteria.
  • Losses and Allocation of COVID-19 Specific Costs: There are a multitude of risk allocation and profits/losses distribution options that your company can utilize.
  • Government Assistance Programs: The variety of government assistant programs that have been enacted in response to the impact of COVID-19 can be a significant factor for transfer pricing considerations.
  • Advance Pricing Arrangements (APAs): These arrangements can be beneficial to creating a collaborative and transparent approach to tax solutions.
Financial Transactions and Interest Push-Down

To utilize the tax and transfer pricing advantages of interest push-down is for parent/holding companies to have their operating subsidiaries listed as co-obligators. This can push down interest and state tax benefit for the company.

Captive Insurance

Captive insurance helps companies to have greater control over their risk factors and the financial capacity to assume risks.

The tax and transfer pricing implications that would follow include substance and control over risk demonstration; underwriting outsourcing; and insurance of risks that are traditionally difficult to insure.

To learn more about transfer pricing topics, you can join a course on using the following discount code for 20 percent off – DHGWEBINAR.

For any additional questions, please reach out to

CPE Information

Recommended CPE Credit

One hour of CPE (pending approval).

Delivery Format

Group Internet Based (each attendee must be logged in and answer the poll questions in order to receive CPE credit).

Who Should Attend

Companies with intercompany transactions.

Prerequisites / Advance Preparation


Course Level


Program Content

Discussion around transfer pricing planning opportunities that companies should be considering for 2021 and practical solutions around real life examples.


This event is complimentary. Due to this program being offered free of charge, there will be no refunds issued. If you have any questions regarding administrative policies such as registration or cancellation, please contact


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