Tax alert


Business restructurings

Restructuring activities in the group according to §23a of the Minister of Finance of June 17, 2013 in terms of  transfer pricing and Chapter IX of the OECD Guidelines is understood as cross-border redeployment by a multinational enterpise of:

  • assets,
  • risks,
  • function.

In a situation where related entities move between them assets or change functions (eg. from a distributor to a contract/tool manufacturer) to the appropriateness of such transaction in the context of market prices should be made:

-       valuation of assets,

-       fix of exit payment.

Valuation of assets should be based on the valuation of the property expert, while the amount of the exit payment, should be refer to the value of royalties in the industry recognizing the value of the market being the product of royalties (ie. between the lower and upper quartiles) and a period of 3-5 years.

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