Transfer pricing issues on restructuring

Speed Read: With global tax authorities viewing restructuring of multinationals operations as a green light for initiating transfer pricing audits, there are a variety of areas in which taxpayers can both reduce the odds of wide-ranging, potentially costly enquiries, and mitigate the possibility of wholesale adjustments to transfer prices. Tax and fiscal authorities worldwide are routinely releasing more detailed and formulaic guidelines which allow taxpayers to anticipate contentious areas, while transfer pricing litigation in the UK and elsewhere is providing a clear insight into the practical application of transfer pricing structures and the associated legal and contractual issues critical to any reorganisation.