Business restructurings are a reaction to global competitive pressures and changing market demand. In response to market forces, multinational enterprises (MNEs) may be able to retain their profit margins only by undertaking a restructuring.

By drawing together divergent views Transfer Pricing and Business Restructurings highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention and considers not only the direct tax issues in business restructuring, but also VAT and customs duties.


The book also gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system. And includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.


Transfer Pricing and Business Restructurings provides readers with an understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.