Stripping the functions of affiliated distributors

Journal
Musselli, A. (Andrea); Musselli, A. (Alberto)
International Transfer Pricing Journal 2008 (Volume 15), No. 6
FormatPDF
EUR
40
| USD
45 (VAT excl.)

The restructuring of multinational integrated businesses is currently one of the most controversial transfer pricing issues. This article explains proposed tax guidance, and presents the authors' opinion regarding why it is so difficult to reach an international consensus on this matter. In addition, the article addresses issues arising from the restructuring of an affiliated distributor when it is stripped of functions that it had previously performed.