Business Restructuring Expenses — Tax Challenges and Opportunities

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Business Restructuring Expenses — Tax Challenges and Opportunities
Global Business Information Strategies, Inc. , Oct 2008, Pages: 7

This article examines the tax treatment of business restructuring expenses in light of the risk of non-deductibility in the country where costs are initially incurred and the associated exposure to double taxation. The article discusses the application of the arm’s length principle to business restructuring expenses, proposes an analytical framework for evaluating associated costs, and offers an illustrative case study to demonstrate some of the concepts. The article concludes with some suggestions to mitigate the risks of double taxation.


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