Transfer Pricing and Business Restructurings

Type Book

Editor(s)

Anuschka Bakker

Date of publication

June 2009

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Streamlining all the way

Transfer Pricing and Business Restructurings provides readers with an understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.

Why this book?

Business restructurings are a reaction to global competitive pressures and changing market demand. In response to market forces, multinational enterprises (MNEs) may be able to retain their profit margins only by undertaking a restructuring.

By drawing together divergent views Transfer Pricing and Business Restructurings highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention and considers not only the direct tax issues in business restructuring, but also VAT and customs duties

The book also gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system. And includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.

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Sample excerpt, including table of contents

Countries/Jurisdictions covered

China, Germany, India, Switzerland, United Kingdom and United States.

Chapter 1: Introduction
Chapter 2: Business Models
Chapter 3: OECD Policy Framework
Chapter 4: EU Policy Framework
Chapter 5: Article 9 of the OECD Model Convention
Chapter 6: Permanent Establishment Issues
Chapter 7: VAT Aspects of Business Restructurings
Chapter 8: Customs Duties
Chapter 9: Tax Accounting Considerations
Chapter 10-15: Country Chapters
Chapter 16: Case Study: Restructuring a manufacturing operation
Chapter 17: Conclusions

Contributor(s)

Valerie Amerkhail, Anuschka Bakker, George Bradt, Irene J.J. Burgers, Mukesh Butani, Andrew Casley, Koen De Grave, Monica Erasmus-Koen, Massimo Fabio, Alan W. Granwell, Monique van Herksen, Nadine Hiller, Heinz-Klaus Kroppen, Patrick Mathieu, Jennifer Moore, René van der Paardt, Achim Roeder, Richard Schmidtke, Jonathan Schwarz, Caroline Silberztein, Werner Stuffer, Ynze van der Tempel, Chris Tierney, Steven Tseng, Nele Vandervelden and Markus Wyss.