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OECD : Report on the transfer pricing aspeects of business restructurings, chapter IX of the transfer pricing guidelines
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There is no legal or universally accepted definition of business restructuring. In the context of this chapter, business restructuring is defined as the cross-border redeployment by a multinational enterprise of functions, assets and/or risks. A business restructuring may involve cross-border transfers of valuable intangibles, although this is not always the case. It may also or alternatively involve the termination or substantial renegotiation of existing arrangements. Business restructurings that are within the scope of this chapter primarily consist of internal reallocation of functions, assets and risks within an MNE, although relationships with third parties (e.g. suppliers, sub-contractors, customers) may also be a reason for the restructuring and/or be affected by it.
OECD - Personal Name
23 OEC oec
23 OEC oec
Book
English
TPA center for tax and administration
2010
Paris
47 p.; 30 cm
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