ARTICLE · 06 OCTOBER 2026
Transfer Pricing Implications Of Business Restructuring
Changes in business models and supply chains have become increasingly common as multinational groups respond to cost pressures, digitalization, geopolitical developments, market expansion, and the need for greater supply-chain resilience. While these changes are usually driven by commercial considerations, they can significantly affect a group’s transfer pricing position.
Changes in business models and supply chains have become increasingly common as multinational groups respond to cost pressures, digitalization, geopolitical developments, market expansion, and the need for greater supply-chain resilience. While these changes are usually driven by commercial considerations, they can significantly affect a group’s transfer pricing position.
A restructuring may change the functions performed, assets used, and risks assumed by group entities. As a result, an existing transfer pricing policy may no longer reflect the way the business actually operates. Transfer pricing should therefore be considered as part of the restructuring process, rather than addressed only after the new model has been implemented.
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