Transfer Pricing Challenges during and post Covid-19

About the Survey

The survey has been conducted by PwC Romania during the period April – May 2020, based on the information provided by companies that activate in a wide variety of industries.

The goal of the survey was to offer up to date information with regard to the impact of the Covid-19 pandemic on the transfer pricing practices of Romanian companies.

The data used in our research has been collected via an online survey platform, and shall be treated as confidential.

The survey entails several questions which permitted a multiple answer from the respondents, in order to provide an accurate depiction of the business reality.

In what industry does your company operate?


Other
%
Technology, Information, Communications & Entertainment
%
Fast Moving Consumer Goods (FMCG)
%
Automotive
%
Pharmaceutical
%
HoReCa
%
Online retail
%

Source: TP Survey
June 25, 2020

What is your main economic activity as part of your group?


Other
%
Multiple activities
%
Services provider
%
Retailer
%
Wholesaler
%
Manufacturer
%

Source: TP Survey
June 25, 2020
 

Most respondents activate as Service providers within their MNE groups, closely followed by Manufacturers and Wholesalers.


In terms of business model you operate locally, which is your main functional profile:


Limited functions and risk company - group decisions are implemented locally most of the time
%
It depends on the specific transaction
%
Fully fledged company - high level of local autonomy
%

Source: TP Survey
June 25, 2020

 

In terms of business model operated locally, most respondents have a limited functional profile, where group decisions are implemented locally.


For 2020, you expect Covid-19 to decrease your revenues compared with similar period of 2019 with:

Less than 25% of revenues
%
25-50% of revenues
%
More than 50% of revenues
%
Source: TP Survey
June 25, 2020

 

Around 75% of the responses indicated that the company’s revenues shall decrease with less than 25% during 2020, as compared to 2019. Furthermore, none of the respondents indicated that their business activity will be closed.


Will Covid-19 bring an issue of cash flow for the following 3 months?


No - we have sufficient liquidity
%
To a high extent yes
%
Other
%

Source: TP Survey
June 25, 2020

 

Most respondents have enough cashflow to support their activity, and will not experience any cash flow issues.


How do you intend to address a potential cash / flow financing issue for 2020:


Obtain more funds from the group
%
Obtain more funds from local third parties
%
Renegotiate payment terms without any new financing
%
We did not yet analyse such a potential issue
%

Source: TP Survey
June 25, 2020

 

60% of the answers indicated that companies will address potential liquidity and financing issues by renegotiating payment terms, without contracting new financing. Only 10% of the responses pointed towards the option of obtaining additional funds from local third parties.

Please indicate the main new type of expenses you expect to incur due to the Covid-19 situation in Romania, if any.


Workforce related
%
Raw materials
%
Logistics
%
Not applicable
%
Other (safety equipment, disinfectants)
%

Source: TP Survey
June 25, 2020

 

The main new type of expenses expected to appear due to Covid-19 is related to Workforce.


Will these specific expenses be reimbursed by the group?


The expenses will be split with the group affiliates
%
We have not discussed this aspect within the group
%
Most probably these expenses will not be reimbursed
%
These expenses will definitely lead to a loss in Romania
%

Source: TP Survey
June 25, 2020

 

Any specific expenses will most likely not be reimbursed (i.e. 36%), while there is also a chance of splitting the expenses between the affiliates (i.e. 20%).


Which is the time span in which you expect such expenses will be incurred?


Already incurred
%
In the next 3 months
%
Until the end of 2020
%
In the long term
%

Source: TP Survey
June 25, 2020

 

These expenses have most likely been incurred already, or are expected to be incurred during the following 3 months.


Do you have IT tools in place to accurately record and measure the financial effects of Covid-19 on related party transactions for 2020?


Yes, my company is properly prepared
%
No, my current resources do not allow such complex monitoring
%
Unsure, we still need to analyse the impact
%

Source: TP Survey
June 25, 2020

 

Most respondents have the necessary IT tools in place to record and measure the financial effects of Covid-19 on related party transactions. The other respondents are either unsure of the impact, or do not have the necessary resources.


What type of transfer pricing challenges do you expect during 2020, in the context of Covid-19?


Decrease of profit margin level
%
Significant operational loss
%
Significant decrease in demand from affiliated clients
%
Business model changes are not reflected in the intercompany contractual agreements
%
Disruption in the access to raw materials and other materials from affiliated suppliers
%
Significant increase in management fee charges
%
Disruption in access to intercompany financing
%
Other
%

Source: TP Survey
June 25, 2020

 

The respondents expect a decrease of profit margin level, as well as operational loss and decrease in demand. 


To answer the above challenges, I will undertake the following actions during the following 3 months:


Any such actions will be taken most probably towards the end of 2020
%
No action will be taken for the coming 3 months as we have other urgent priorities in the current context
%
Revisit the intra-group pricing with each related party
%
Revisit transfer pricing contractual clauses with related parties
%
Increase in local functions and responsabilities to manage economic difficulties
%
Other
%
Complete restructuring of the activities undertaken with related parties
%
No action will be taken as our economic activity will be closed/ significantly reduced
%

Source: TP Survey
June 25, 2020

 

Companies will most likely take corrective actions towards the end of 2020. 


If you have an Advance Pricing Agreement in place in Romania, do you expect an impact on the negotiated terms with the tax authorities due to Covid-19:

I do not have such an agreement in place
%
No
%
Yes
%
Source: TP Survey
June 25, 2020

 

Most respondents do not have an APA in place. However, 12% of respondents mentioned that they don’t expect a renegotiation of the terms, while 8% expect to take such action due to the impact of Covid-19.


If you have workforce stranded in certain abroad locations under Covid-19 lockdown, do you expect a permanent establishment issue to appear?

I do not have such workforce
%
No
%
Source: TP Survey
June 25, 2020

 

Most respondents do not face the issue of workforce stranded abroad during the lockdown (i.e. 76%), while 24% do face such issue, but do not expect a permanent establishment to appear in those locations.


Contact us

Ionuț Simion

Ionuț Simion

Partner, Tax Services, PwC Romania

Daniela Dinu

Daniela Dinu

Director, Tax Services, PwC Romania

Georgiana Gheorghe

Georgiana Gheorghe

Senior Manager, Tax Services, PwC Romania

Livia Teodoru

Livia Teodoru

Director, Tax Services, PwC Romania

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