The Resource Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts

Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts

Label
Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts
Title
Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts
Creator
Subject
Language
eng
Summary
This article provides a summary of the current state of affairs, including the opinion of scholars, tax authorities and the OECD regarding the tax implications of stripping out functions of local affiliates. The scope of this study is limited to (1) the implications of restructuring or relocating a producing affiliate not owing intangibles of the integrated activity and (2) the question of the eventual buy-out for the stripped affiliate as a result of disposing of its existing business. Restructuring issues are considered in the light of concepts and analysis derived from economics of contracts
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 15 (2008),
http://library.link/vocab/creatorName
  • Musselli, A
  • Musselli, A.C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • affiliated group
  • contract manufacturing
  • transfer pricing
  • reorganization
  • arm's length principle
Label
Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts
Instantiates
Publication
Label
Stripping the functions of producing affiliates of a multinational group : addressing tax implications via economics of contracts
Publication

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