Transfer Pricing and Business Restructurings

Streamlining all the way

Transfer pricing and business restructuring
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.


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


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.

Transfer Pricing and Business Restructurings
Abbreviations and Common References
Chapter 1 – Introduction
Chapter 2 – Business Models
Chapter 3 – OECD Policy Framework
Chapter 4 – EU Policy Framework
Chapter 5 – Art. 9 of the OECD Model Convention
Chapter 6 – Permanent Establishment Issues
Chapter 7 – VAT Aspects of Business Restructuring
Chapter 8 – Customs Duties
Chapter 9 – Tax Accounting Considerations
Chapter 10 – China
Chapter 11 – Germany
Chapter 12 – India
Chapter 13 – Switzerland
Chapter 14 – United Kingdom
Chapter 15 – United States
Chapter 16 – Case Study
Chapter 17 – Conclusion

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