by Ajit Jain
The OECDs new transfer pricing approach to business restructuring, as described in Chapter IX of 2017 OECD transfer pricing guidelines, has changed radically from prior versions.
These new transfer pricing guidelines, released on July 10, echo important changes made in 2015 OECD/G20 base erosion and profit shifting (BEPS) project regarding how to analyze a transaction for purposes of transfer pricing.
The following is a closer look at the new OECD transfer pricing guidelines on business restructuring, highlighting areas of the greatest importance to practitioners.
Delineation of transactions in pre- and post-structuring
The 2017 guidelines provide that the analysis of a business restructuring from a transfer pricing perspective s…
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