Transfer pricing implications of restructuring

Corporate restructuring within multinationals—such as transferring assets, centralizing functions, or converting distributors to Limited Risk Distributors (LRDs)—can have a significant transfer pricing impact. This session will give you insight into the tax considerations and how to document them correctly.

Content

When companies restructure within groups, such as transferring functions, assets, or risks, there’s a lot to think about when it comes to transfer pricing. In this training course, you will learn how to substantiate these transactions for tax purposes, how to determine any exit compensation, and which risks shift before and after the reorganization. We will take a closer look at the OECD guidelines, including the expectations regarding documentation, so that you can avoid future discussions or double taxation.

Target group

This training is intended for tax and TP specialists, financial managers, and legal professionals involved in intra-group reorganizations and their transfer pricing implications It is also relevant for policymakers who make strategic decisions that impact value creation within the group.

Duration

A physical session typically lasts 1.5 to 2 hours and is organized at the client’s premises. An online session lasts 1.5 hours.

Timing

We offer our training courses online or as customized in-company training courses tailored to the specific needs of companies. If you are interested, please contact us via the “MORE INFORMATION” button above. We will be happy to consult with you to schedule a session that fully meets your needs.

Programme

  • OECD guidelines on restructuring: Explanation of the OECD framework, including the importance of options realistically available (ORA analysis) for all parties involved

  • Exit charges and compensation mechanisms: How do you determine whether an exit charge applies and how do you calculate arm’s length compensation for transferred functions, assets, or risks?

  • Risk allocation before and after the reorganization: Analysis of how the allocation of risks within the group changes after a restructuring and the impact this has on transfer prices.

  • Risk allocation before and after the reorganization: Analysis of how the allocation of risks within the group changes after a restructuring and the impact this has on transfer prices. Focus on economic motives, risk analysis, ORA considerations, and valuation of transferred elements.

  • Summary and Q&A: Overview of the most important insights and opportunity for questions from practice.