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OECD : Report on the transfer pricing aspeects of business restructurings, chapter IX of the transfer pricing guidelines



There is no legal or universally accepted definition of business restructuring. In the context of this chapter, business restructuring is defined as the cross-border redeployment by a multinational enterprise of functions, assets and/or risks. A business restructuring may involve cross-border transfers of valuable intangibles, although this is not always the case. It may also or alternatively involve the termination or substantial renegotiation of existing arrangements. Business restructurings that are within the scope of this chapter primarily consist of internal reallocation of functions, assets and risks within an MNE, although relationships with third parties (e.g. suppliers, sub-contractors, customers) may also be a reason for the restructuring and/or be affected by it.


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Detail Information

Call Number
23 OEC oec
Publisher TPA center for tax and administration : Paris.,
Collation
47 p.; 30 cm
Language
English
Classification
23 OEC oec
ISBN/ISSN
-
Edition
-
Subject(s)
-