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The Bloomberg BNA International Tax Blog is a forum for practitioners and Bloomberg BNA editors to share ideas, raise issues, and network with colleagues. The ideas presented here are those of individuals, and Bloomberg BNA bears no responsibility for the appropriateness or accuracy of the communications between group members.

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Wednesday, May 18, 2011

When Restructuring Gives Rise to Compensation for Loss of Functions

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Trying to determine when restructuring of a multinational gives rise to compensation for the loss of functions?

A new Special Report by BNA Tax Management Transfer Pricing Report examines contractual provisions in third-party automotive and industrial supply agreements to illustrate when the restructuring of a multinational entity indicates compensation to the nation losing the function.

The report is written by KPMG practitioners Hareesh Dhawale, Ph.D., in Los Angeles, and Anjit Bajwa, Ph.D., in Seattle.

To read the Special Report for free, register for a free 15-day subscription to the Transfer Pricing Report at http://www.bnatax.com/Transfer-Pricing-Report-p7899/.

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