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Pris: 695 SEK exkl. moms  |  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.
Table of contents
- Preface
- List of Editors/Authors
- Figures
- Tables
- Abhishek Padwalkar Introduction to Business Restructuring
- Natalie Reypens/Svitlana Buriak Chapter 1: Delineating and Recognizing Business Restructuring
- Gianni De Robertis/Rocco Talia Chapter 2: Remunerating the Restructuring Itself
- Roman Dawid/Danilo Zehner Chapter 3: Remunerating the Post-Restructuring
- Thomas Ebertz/Oleh Shkolnyi/Sayee Prasanna Chapter 4: Other Relevant Issues
- Series on International Tax Law | | |
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