期刊名称：Journal of the Australasian Tax Teachers Association
印刷版ISSN：1832-911X
电子版ISSN：1832-911X
出版年度：2013
卷号：8
期号：1
出版社：Australasian Tax Teachers Association
摘要：Business restructuring by multinationals has become increasingly prevalent as businesses seek to improve their profits through the location of business activities in countries with cheaper distribution, production, administration, or tax costs. This restructuring activity has been subject to increasing scrutiny from the OECD and tax authorities due to its potential impact on domestic tax bases. In particular, when profit- making activities are shifted from one jurisdiction to another, this can significantly alter the tax paid by multinational subsidiaries. Dominating the debate surrounding the tax issues are the transfer pricing implications of these reorganisations. This paper discusses the motivation behind international business restructures, including a review of some recent high profile examples, and considers why transfer pricing issues arise. Responses by the Australian and New Zealand tax authorities are examined, together with the OECD's report on the transfer pricing aspects of business restructuring and recent initiatives aimed at the issue of global profit shifting .
