With only over 13% of the total world population fully vaccinated against the Covid-19 virus, the world economy is struggling to recover from the impact of the pandemic. As businesses grapple with employee retention, government restrictions, and other safety compliance issues, multinational entities have additional considerations concerning their cross-border transactions and taxes.

While ensuring the arm's length standard is the mantra of transfer pricing, finding real-world data to support an arm's length valuation for its related party transactions that are regional, functionally comparable, and at a similar stage in the pandemic might be challenging.