Cross-border business restructuring operations under increased scrutiny

The OECD Centre for Tax Policy and Administration (CTPA) held its 2nd roundtable on 26 and 27 January 2005 in Paris. The purpose of the roundtable was to discuss tax implications of cross-border business restructuring operations. The roundtable was attended by senior officials, from both OECD member countries and non-OECD countries, as well as representatives from the private sector.
The discussion covered the following topics:
- Economic and commercial background of business restructuring;
- Tax aspects of the transactions undertaken as part of the restructuring;
- How to determine the income of the limited function entity;
- Permanent establishment issues raised by business restructuring operations; and
- VAT aspects of supply chain structures.
The roundtable spotlight on business restructuring operations comes at a time where such conversions are increasingly under the scrutiny of tax authorities. The next CTPA Roundtable is scheduled for January 2006.
A brief summary of the roundtable discussions has been published on the OECD website.