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Advance Pricing Arrangements — A Risk-Management Tool for Business Restructuring?

In recent years, business restructuring has become a hot topic for multinational corporations (MNCs) and tax administrators around the globe. To MNCs, globalisation means establishing their footprint in different parts of the world, but this is just the beginning of the process. The competitive environment MNCs face may require them to improve cost efficiency, enter new markets or exit from existing ones, or better develop, protect, and manage their intellectual property in order to maintain their ability to perform successfully on a global basis. It is this setting that forces businesses onto the path of restructuring, whether along commercial, operational, and/or legal lines.