Part one discusses the implications of the new Organisation for Economic Co-operation and Development (OECD) Guidelines on Business Restructuring. This section includes specific country perspectives on business restructuring concepts from: Australia, Belgium, Canada, China, Denmark, France, Germany, Italy, Japan, the Netherlands, Spain, the United States and the United Kingdom.
The second part focuses on a few selected issues that arise in many multinational enterprise’s (MNEs) supply chains.
The last section of this publication discusses controversy, including a discussion of two new tools to help taxpayers resolve controversy -accelerated competent authority procedures (ACAP) and binding arbitration- as well as a discussion on navigating transfer pricing controversy in India. The section looks at the rapid growth of advance pricing agreements (APAs) in Asia and includes APA-statistics in Australia, China, Japan and Korea. Finally, it includes a discussion of two court cases that have significant implications for supply chain management and restructuring, namely the General Electric case in Canada and the Veritas case in the United States.