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Global supply chains across all industry sectors are facing an unprecedented challenge due to the COVID-19 pandemic. Increased pressure on supply chain linkages is nothing new to multinational enterprises (MNEs), due to national tax and trade protectionism measures, evolving international tax policies, and technological disruption, but the current global pandemic is materially different. COVID-19 is unlike typical supply chain disruptions in that it has rapidly moved across the globe and forced companies to respond almost immediately to address the near-term sustainability of their existing supply chains. This development is putting a massive strain on MNEs’ operations and creates a profound level of future risk and exposure from a business, tax, and legal perspective.

This article, part of Baker McKenzie and Bloomberg Tax’s Special Report, addresses transfer pricing and the state of play for supply chains before and in response to the pandemic, and identifies implications post-pandemic.

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Armando Cabrera-Nolasco is a partner in Baker McKenzie's Tax Practice Group in Guadalajara. He has 10 years of experience in transfer pricing issues. Mr Cabrera-Nolasco currently coordinates the transfer pricing services for financial and services industries, and the financial valuation practice.

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Tamara Levin is a partner in Baker McKenzie’s San Francisco/Palo Alto Tax Practice Group. She regularly advises companies, mostly in technology-based industries, on transfer pricing and tax planning matters, including structuring and implementing international operations, cross-border transactions, and post acquisition integrations. Tamara speaks at internal workshops and seminars, as well as external events sponsored by Bloomberg BNA and the Tax Executives Institute.

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Jon Cowley is a member of Baker McKenzie's Hong Kong office. Jon's practice focuses on Asia-Pacific customs and trade matters, including controversy and audit support, duty and indirect tax planning, supply chain structuring and trade compliance advice. Jon returned to Baker McKenzie after spending five years as Assistant General Counsel for Customs and International Trade at a major consumer product company, where he advised the business on trade and customs issues globally. He previously was a member of Baker McKenzie’s International Trade Controversies and Planning practice in Hong Kong, where he assisted multinational companies with China customs, export control, encryption, indirect tax and cross-border regulatory matters. Earlier in his career, Jon was a trade advisor with consulting firms in Silicon Valley and Chicago.

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Jukka Karjalainen is a partner in the London Tax Department of Baker McKenzie, and co-leads the UK Transfer Pricing practice. He has over 20 years of experience in dealing with transfer pricing and international corporate tax issues from both a private practice and an industry perspective.

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Gene Tien works with US and foreign multinationals on transfer pricing (TP) and other economic valuation issues, with a primary focus on the planning and dispute resolution of intangible property (IP) transactions and other value-added TP flows. Dr. Tien also works on economic development issues on a pro bono basis — including international fiscal devolution, water rights, and domestic social justice research. He regularly presents and writes about developments in international TP policy.

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Shane Koball is a director of economics in Baker McKenzie's New York office. He has extensive experience advising multinational corporations from the industrial products, life sciences, automotive, retail and consumer products, and media and advertising industries on transfer pricing planning, compliance and dispute resolution, as well as supply chain planning and restructuring. Prior to joining the Firm, Mr. Koball was a senior manager in the international tax services practice of well-known audit firm.

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Vladimir Zivkovic is a senior economist in Baker McKenzie Amsterdam’s Transfer Pricing team. He has more than nine years of experience in transfer pricing and value chain analysis. Vladimir started his career in Canada and relocated to the Netherlands in 2011.