Business Restructurings

Since the mid 1990s business restructurings involving commissionnaires, toll manufacturing and similar types of arrangements have become widespread practice in global integrated enterprises.  The January 2005 CTPA Roundtable reflected the need for work to be done in this area given the significant effects observed on countries’ revenue base and the significant risks of double taxation faced by multinational groups.   The Committee on Fiscal Affairs created a Working Group to analyse the treaty and transfer pricing aspects of restructuring.

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The OECD pursues dialogue with business on business restructuring issues

18-Jun-2007

The OECD pursues its dialogue with the business community on the transfer pricing and treaty aspects of Business Restructurings, participates in discussion panels in Washington and Stockholm, and convenes a third meeting of the Business Advisory Group.

Approval of a mandate for the Working Group on Business Restructuring

12-Feb-2007

October 2006

As a follow up to the January 2005 CTPA Roundtable, the Committee on Fiscal Affairs created a Joint Working Group of Delegates from Working Party No. 1 on the Model Tax Convention and Working Party No. 6 on the Taxation of Multinational Enterprises, in order to explore the treaty and transfer pricing aspects of business restructurings.  A detailed mandate for the Group was approved by the Committee on 20 Oct. 2006. The mandate describes the responsibilities of the Group, working methods and timetable. 

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