Businesses have always thrived through expansion, synergy and efficiency. Size does matter, but small and lean operations can prove to be very profitable. To deal with this apparent paradox, large multinationals need to be agile in the structuring of their operations.
In the late 1980s and early 1990s, several tax regimes were implemented to help enterprises manage their tax liability (tax consolidation regimes) or their restructuring: the so-called EU Merger Directive implemented a tax deferral regime on mergers, divisions, transfer of assets and exchange of shares in order to remove fiscal obstacles for cross-border reorganizations. Such regime has proved helpful for enterprises to acquire, dispose of or restructure their internationa…
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