There are also business restructurings whereby more intangibles or risks are allocated to operational entities (e.g. to manufacturers or distributors). Business restructurings can also consist of the rationalisation, specialisation or de-specialisation of operations (manufacturing sites and/or processes, research and development activities, sales, services), including the downsizing or closing of operations. The arm’s length principle and guidance in this chapter apply in the same way to all types of transactions comprising a business restructuring, irrespective of whether they lead to a more centralised or less centralised business model.
TPG2017 Chapter IX paragraph 9.3
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Business restructuring, De-specialisation of operations, Downsizing of operations, Termination of operations
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