Business restructurings of multinational groups very often include a transfer pricing aspect, either (i) because an existing transfer pricing policy needs to be re-examined and possibly modified further to the restructuring, and/or (ii) because it must be determined whether the restructuring in itself is implemented in accordance with the arms-length principle.
Since the arms-length principle does not apply differently to post-restructuring transactions as opposed to transactions that were structured as such from the beginning, the second aspect of business restructurings described above is generally the more complex to deal with.
Since their update in 2010, the Organization for Economic Cooperation and Development Transfer Pricing Guid…
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