Transfer Pricing and Business Restructurings

S. VPreface

The world is rapidly changing, and so is the business environment. To keep up with the pace, multinational enterprises (MNEs) need to continuously restructure their operations, assets, and resources. This can help them to adapt to the changing market conditions, improve operational efficiency, reduce costs, and optimize financial performance.

However, restructuring is a complex process, especially regarding transfer pricing (TP). Even after elaborate guidance provided by the OECD and the UN on the topic, the TP aspects of business restructuring remains a challenge both for MNEs and the tax administrations in determining the appropriate TP methodology, finding comparable transactions, and providing proper documentation to support the restructuring. The determination of the arm’s length principle for transactions involving these can have significant tax implications for MNEs.

This book aims to provide a comprehensive understanding of the TP aspects of business restructuring by way of case studies. It attempts to cover various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant i...