International - Transfer Pricing Documentation for Business Restructurings
- P. Boone; M. Haupt
- International Transfer Pricing Journal, 2013 (Volume 20), No 3
- 3 May 2013
This article deals with the challenge of documenting business restructurings for transfer pricing purposes. It links the discussion to the ongoing debate of risk management for transfer pricing, and suggests how MNEs can build a business case for change and sufficiently evidence the operational transformation by following an efficient, contemporaneous documentation approach.