Are Tax-Efficient Structures Still Efficient?

Business restructuring is not a new issue. Throughout the world businesses are being transformed to drive down costs and respond to the global marketplace. There is no doubt that this is a real response to real pressures. Encouraged by the prospect of added tax-efficiency many multinationals have changed or are reviewing their business models in response to these trends. However the transfer pricing issues that this can raise and the subsequent response by tax authorities to changing business models should be considered in some depth.

As with any significant commercial transaction restructuring will unearth a large number of tax issues. Equally given that most businesses rightly view tax as...