This case study has been presented at the D-A-CH Tax Congress 2023 which occurs every two years in Vienna, bringing together experts and advisors from the German-speaking world to discuss current topics within the cross-border context of these countries from the perspective of tax law practice, tax administration, case law and tax policy. This article summarizes and analyzes the discussions about the transfer pricing implications of distributors that in a crisis scenario do not generate routine profits anymore, including primary and secondary adjustments along with comparability adjustments. Based on that, solution approaches from Germany, Austria, Switzerland and Liechtenstein are described.
