There is no legal or universal definition of business restructuring. Nevertheless The OECD Transfer Pricing Guidelines provide that business restructuring may be defined as the cross-border redeployment by an MNE (multinational enterprise) of functions, assets, and/or risks. Considering that a business restructuring may involve cross-border transfers of valuable intangibles, the focus is on internal reallocation …
Continue reading “Company restructuring in international tax planning.”