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.
The rest of this article is available to subscribers and active trialists* only.
Subscribe today for full access to this article.
Alternatively take a free trial, giving you access for one week*.
If you are already a subscriber, please log in below to access the rest of this article.
*some articles may be excluded from free trialists.