The Executive Secretariat of CIAT invites you to download and read section “3.6 Business Restructuring” of the Manual for the Control of International Tax Planning, written by the Internal Revenue Services (IRS) of the United States.

The section presents an analysis of experiences, with a focus on the United States, of types of business reorganization strategies used by multinational enterprises. These reorganize for a variety of reasons, such as expansion, aiming to reduce liability, or aligning the operating structure with the business structure, etc. Factors such as global competition, economies of scale, specialization, efficiency and cost reduction drive these reorganizations. Although tax considerations are not necessarily the main purpose for restructuring, they do influence the configuration of the new business.

This is the 34^th chapter published as part of the “Manual for the Control of International Tax Planning”, available in English and Spanish. The complete Manual has six sections and is comprised of 42 chapters. New chapters will be published soon.