Companies Get OECD Help Fixing Cross-Border Virus Tax Issues - Bloomberg Tax

John Warner, shareholder in the firm's Tax section, is quoted in the Bloomberg Tax article, "Companies Get OECD Help Fixing Cross-Border Virus Tax Issues."

"Generally, the guidance is conceptually very useful," said John Warner, a shareholder at Buchanan Ingersoll & Rooney PC in Washington. "It gets into a lot of detail that could help taxpayers and tax administrations set up or frame COVID-19 related transfer pricing issues."

"The guidance contains some helpful language on the possibility that 'limited risk' distributors may suffer at least short-term losses at arm's length," Warner said. "So, the key for taxpayers seeking to claim such losses for those controlled distributors will be to find data for comparable uncontrolled limited risk distributors to support those results."