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Business Restructuring

Chris Lenon Head of Tax at Rio Tinto explores why business restructuring has become such a contentious issue in international tax and discusses the recent OECD discussion draft
The tax consequences of business restructuring have become a major issue over recent years. A significant body of work has developed in the OECD involving government representatives an advisory group from business and a consultation process which has led to the issue of a discussion draft for public comment published on 19 September 2008 entitled 'Transfer pricing aspects of business restructurings'. The OECD has invited interested parties to send comments before 19 February 2009.
What is a business restructuring?
The OECD discussion draft describes a business restructuring...

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