On 10 March 2021, the Greek Public Revenue Authority (AADE) published Circular Ε. 2054 of 10 March 2021, providing general guidance of how to deal with the adverse effects of the COVID-19 pandemic on transfer pricing issues. The guidance is helpful both for taxpayers in reporting the financial periods affected by the pandemic and for tax administrations in evaluating the implementation of taxpayers’ transfer pricing policies. The Circular specified that the instructions are based on the guidance on the transfer pricing implications of the COVID-19 pandemic issued by the OECD in December 2020. Four priority issues were identified and are covered in the guidance:
(i) comparability analysis;
(ii) losses and the allocation of COVID-19 specific costs;
(iii) government assistance programmes; and
(iv) advance pricing agreements (“APAs”).
