Category: Business Restructuring
In the context of transfer pricing, business restructuring is defined as the cross-border redeployment by a multinational enterprise of functions, assets and/or risks. A business restructuring may involve cross-border transfers of valuable intangibles. It may also or alternatively involve the termination or substantial renegotiation of existing arrangements. Business restructurings can also consist of the rationalisation, specialisation or de-specialisation of operations including the downsizing or closing of operations.
- Conversion of full-fledged distributors into limited-risk distributors or commissionnaires for a foreign associated enterprise that may operate as a principal,
- Conversion of full-fledged manufacturers into contract-manufacturers or toll-manufacturers for a foreign associated enterprise that may operate as a principal,
- Transfers of intangible property rights to a central entity (e.g. a so-called “IP company”) within the group.