Business restructurings and value chain transformation

Business restructurings and operating model changes often create some of the most sensitive transfer pricing issues. We support clients through value chain transformations, transfers of functions, risks or assets, IP migrations, conversions of manufacturing and distribution models and any other business changes with transfer pricing impact.

Why this matters

When a group centralises functions, changes the allocation of risks, transfers assets or modifies the remuneration of entities, tax authorities may ask whether value has moved, whether an exit charge should arise and whether the post-restructuring model is aligned with substance. A robust transfer pricing analysis should be prepared before implementation, not after the restructuring has already taken place.

How we help

• Analyse the current and future operating model: map changes to functions, risks, assets, decision-making and value creation.
• Identify transfer pricing implications: assess whether the restructuring involves a transfer of something of value, changes to profit potential or exit tax considerations.
• Support valuation and pricing: analyse transferred functions, risks or assets, including transfer packages, intangibles or customer-related value where relevant.
• Design the future remuneration model: develop pricing policies for limited risk distributors, sales agents, contract manufacturers, service centres, principals or IP owners.
• Document the commercial rationale: prepare evidence explaining the business reasons, options realistically available and expected economic impact.
• Support implementation: align intercompany agreements, pricing mechanics, accounting processes and documentation with the new model.

Typical deliverables

• Pre-restructuring TP impact assessment
• Value chain and operating model analysis
• Exit tax and transfer package analysis
• Valuation support for transferred functions, risks or assets
• Post-restructuring transfer pricing policy
• Intercompany agreement support
• Implementation roadmap
• Preparation of transfer pricing documentation or defense file

Typical triggers

• Centralisation of management, procurement, services, treasury or IP
• Conversion to toll / contract manufacturer or limited risk distributor model
• Supply chain realignment or principal company structure
• Post merger integration, carve-out or post-acquisition restructuring
• Relocation of decision-making or key people functions
• Tax authority questions following a business change