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good morning in our two-minute tax talk today I will consider transfer pricing and intercompany agreements and non-performance in light of covert 19 intercompany arrangements are governed by the terms of the underlying agreement in circumstances where one of the parties does not perform the question whether a defense for non-performance is available or depend on the terms of the agreement and the surrounding circumstances in our earlier talk we considered force majeure as a possible option but there may also be other options and now is a good time for companies to consider and review those underlying intercompany agreements as a first option consider whether the contract has been frustrated the doctrine of frustration will apply with the intervening act grendas performance of the agreement impossible or illegal but such performance must genuinely be impossible or illegal and in a cross-border scenario it will be considered at the place where performance was due to be rendered sweet p
