Anticipating business restructuring documentation requirements
October 06, 2008
John Hughes of Mayer Brown explains how taxpayers must raise the bar on transfer pricing documentation to stay inline with the new OECD discussion draft.
The OECD’s recently released discussion draft on the transfer pricing aspects of business restructurings (the draft) presents a measured analysis of the conceptual issues that arise with these transactions, which are now commonplace among multinational companies but on which the existing OECD transfer pricing guidelines provide relatively little guidance.
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