Transfer Pricing and Business Restructurings (eBook)

Current Developments, Relevant Issues and Possible Solutions

Michael Lang, Raffaele Petruzzi (Herausgeber)

eBook Download: EPUB

2023 | 1. Auflage
100 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1316-6 (ISBN)

Infos

Transfer pricing and business restructurings: issues and developments

In the ever-evolving global landscape, the ability of businesses to swiftly adapt is crucial for maintaining relevance and competitiveness. This imperative holds true for multinationals, which frequently engage in strategic restructuring of their operations, assets, and resources to realign with the dynamic shifts in market conditions. This dynamic approach enhances operational efficiency, cuts costs, and optimizes financial performance.

However, the intricacies of restructuring, especially in the context of transfer pricing, pose considerable challenges. Despite elaborate guidance from the OECD and UN, transfer pricing considerations in business restructuring remain complex. Determining appropriate transfer pricing methodologies, finding comparable transactions, and ensuring accurate documentation present hurdles for both multinationals and tax administrations.

This publication discusses the most important issues and recent developments related to this theme. It attempts to cover various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19.

This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, that took place in October 2022 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.

Textauszug

XIIIFigures

Introduction

Figure 1:

Conversion of full-fledged distributor to commissionaire

5

Chapter 1

Figure 1:

OECD’s six-step approach to risk allocation

34

Figure 2:

Illustration of commercial and contractual arrangements post-restructuring

49

Figure 3:

Focal points in managing fashion brands’ supply chains

54

Figure 4:

Technology opportunities across the apparel value chain

55

Chapter 2

Figure 1:

Simplified illustration of the Group’s value chain

79

Figure 2:

Illustration of the transaction flows related to the Italian and Spanish markets under the pre-restructuring scenario

81

Figure 3:

Illustration of the transaction flows related to the Italian and Spanish markets under the post-restructuring scenario

85

Chapter 3

Figure 1:

Compensation of a transfer of function in German transfer pricing regulations

115

Figure 2:

GP GMBH’s global business functional and transactional structure

124

Figure 3:

GP GMBH’s global business in the Centre-led model

127

Chapter 4

Figure 1:

Factors influencing business restructurings

134

Figure 2:

Example of a value chain approach to TP analysis of business restructurings

136

...

Produkt-Details

• Erscheint lt. Verlag: 19.9.2023
• Sprache: englisch
• Themenwelt: Recht / Steuern
• ISBN-10: 3-7094-1316-8 / 3709413168
• ISBN-13: 978-3-7094-1316-6 / 9783709413166