In a pandemic environment, longstanding transfer pricing policies can lead to suboptimal tax results. Multinationals that incur losses in some locations while earning generous profits in others could be overpaying taxes. For many companies, modifications to intercompany pricing that reduce taxes payable and utilize losses are overlooked tax savings opportunities.
A multinational company's transfer prices of goods, royalties, services and loans affect where profits are generated, or the losses incurred in each country. For companies impacted by COVID-19, an assessment of estimated taxes payable and losses by country can highlight tax savings opportunities.
Diwas KC is a professor at Emory University's Goizueta Business School, where his research focuses on healthcare delivery and pricing. He has been analyzing CMS-mandated hospital pricing data to build procedure-level benchmarks for the Georgia commercial market. Data source for article: CMS-mandated hospital machine-readable files (2026), Georgia hospitals, commercial payer rates. Facility fees only — excludes physician and anesthesia fees.
Larry Cao, CFA, is Senior Market Intelligence Analyst, AI, at American Banker, where he focuses on the adoptions of artificial intelligence across banking and financial services.
Larry has more than two decades of experience in investment research and financial services, with a particular focus on AS adoption, data-driven investment processes, and the future of finance. He previously served as a senior research leader at CFA Institute, where he led and authored research on AI, big data, fintech, investment management, and evolving skillsets in the financial industry. He is the editor of Handbook of Artificial Intelligence and Big Data Applications in Investments and author of research on AI adoption and T-shaped teams.
Larry's research and commentary have been cited by regulators and industry organizations globally, and featured in major media outlets including Bloomberg, the Financial Times, The Wall Street Journal, and Reuters. Earlier in his career, he held roles at Morningstar/Ibbotson Associates, Munder Capital Management, and McKinsey & Company.
Larry holds an MBA in finance from the University of Notre Dame.
Some of Larry's publications include:
Books and reports
Ten Structural Shifts in AI Adoption: Evidence, Frameworks, and Emerging Frontiers (2018 -2025) - Handbook of Artificial Intelligence and Big Data in Investments
- T-Shaped Teams
- AI Pioneers in Investment Management
- Multi-Asset Strategies: The Future of Investment Management
Interviews/presentations (video)
Dave Maney is the CEO of The Expert Press, which helps companies conceive, create, and nationally publish high-authority thought leadership pieces. Generative AI is changing how prospects discover and evaluate expertise, as AI increasingly builds vendor shortlists before buyers ever visit a website. In this article, Dave argues why firms must shift from producing high volumes of marketing content to creating citation-worthy, third-party validated expertise that AI can surface. He also outlines the practical changes necessary to remain visible, credible, and discoverable in an AI-first buying environment.
For many cross-border businesses, well-established policies have facilitated the pricing of intercompany goods, royalties, and services transactions over many years. However, even the most robust transfer pricing policies were not designed for pandemic-driven closures. As a result, multinational companies have a high global effective tax rate even when incurring company-wide losses. Paying unnecessary income tax bills is particularly painful for those companies already short on cash.
Tangible tax savings
An example may best illustrate the potential for savings from revisiting transfer pricing policies in the wake of the pandemic. In this situation, a wholly owned manufacturer relies on a sizeable cost-plus margin policy when selling inventory to the parent company.
For a subsidiary in a 30 percent tax rate jurisdiction, a $2 million reduction in transfer prices leads to $600,000 in tax savings by utilizing tax-inefficient parent company losses. Corrections to royalty rates and service fees have similar impacts. The result is the same: utilizing tax net operating losses in Country A while reducing Country B’s taxes. That being said, there does need to be economic substance to justify these changes.
Implementing tax savings
Utilizing tax NOLs in Country A while paying fewer income taxes in Country B is, at first glance, a straightforward concept. However, implementing corrections to transfer pricing often requires some planning. In my experience, senior management on both sides of the border needs to be involved in the decision-making process. Other issues, such as adjustments to Customs entries, are additional complications. Transfer pricing documentation is often well-advised support for changes to transfer prices.
Tax auditors may have questions about why transfer prices have changed. COVID-19 has transformed the global business environment, but preparing support to quantify the pandemic's impact on a company is advisable. Furthermore, making modifications before year-end is less complicated than afterward.
Now more than ever, multinational companies should consider modifications to transfer prices when assessing their global effective tax rate; however, changes to cross-border taxes need to be explained. While there are some complications, cash and tax savings can be well worth the effort.
