Nick Foster-Taylor looks at practical and commercial issues arising when multinationals carry out restructuring, and discusses the impact that transfer pricing has on business and operational considerations
Corporate reorganisations offer significant opportunity for proactive management of internal transfer pricing and tax structures but inevitably attract scrutiny from tax authorities. In the current economic climate many multinational companies are seeking either to rationalise or consolidate operational activity with a view to economies of scale and other cost savings: an increasingly important element to such restructuring is post-tax cash results and management of a group's consolidated effective rate of tax and as such transfer pricing often takes centre stage.
Risk profiling
Global tax authorities are increasingly undertaking detailed analysis to determine which corporate taxpayers are most likely to have transfer pricing issues and which are also most vulnerable to adjustment at audit. HMRC cites 'business reorganisation' as a...
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Nick Foster-Taylor looks at practical and commercial issues arising when multinationals carry out restructuring, and discusses the impact that transfer pricing has on business and operational considerations
Corporate reorganisations offer significant opportunity for proactive management of internal transfer pricing and tax structures but inevitably attract scrutiny from tax authorities. In the current economic climate many multinational companies are seeking either to rationalise or consolidate operational activity with a view to economies of scale and other cost savings: an increasingly important element to such restructuring is post-tax cash results and management of a group's consolidated effective rate of tax and as such transfer pricing often takes centre stage.
Risk profiling
Global tax authorities are increasingly undertaking detailed analysis to determine which corporate taxpayers are most likely to have transfer pricing issues and which are also most vulnerable to adjustment at audit. HMRC cites 'business reorganisation' as a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
