The global effects of COVID-19 are well underway to changing the game. This is true for business models as well as value and supply chains and, thus, also for transfer pricing systems. Accordingly, multinational enterprises (MNEs) are required to analyze and possibly adjust their transfer pricing policy in order to fit the needs of the “new normal". As crisis management usually lacks blueprints, managers of MNEs are strongly recommended to timely and comprehensively document the economic rationale behind the measures taken. This might be crucial in order to demonstrate the ex ante perspective and effectively mitigate “use of hindsight".
