At the 2005 IFA Congress in Buenos Aires, Seminar E, entitled "Moving away from source taxation: reorganizing supply chains", focused on business restructuring issues, such as changes in functions and in the way business operations are conducted (also referred to as "supply chain reorganizations"). In the context of multinational enterprises, these changes lead to changes in the risk profile of the entities within the group and consequently in the profitability of operations in countries in which activities take place. The changes may result in overall changes in the group's profitability or a shift in the jurisdiction where profits arise - away from the place where activities are undertaken to the place where risks are assumed or functions are moved. This article summarizes the discussions at Seminar E.