The attention of tax authorities on supply chain reorganisations, which impact the operations of multinational enterprises (MNEs), has noticeably increased following the issuance of the OECDs transfer pricing aspects of business restructurings (the OECD published guidance on business restructurings in draft form in 2009 and subsequently included it as final in the latest edition of the OECD Transfer Pricing Guidelines (TPG), issued in January 2022).
The OECDs guidance on business restructurings is squarely aimed at analysing the impact of such reorganisations on local taxable income, outlining bases for challenges if such restructurings are deemed not to be driven by business reasons and/or (not properly documented as being) at arms leng…
Read the full article at: https://www.internationaltaxreview.com/article/2c8v2ovmaw3jw0ijj2gow/expert-analysis/special-focus/business-restructurings-and-tp-controversy