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What does business restructuring mean? And what should be disclosed in regards to restructuring?


The term “restructuring” does not resonate with a particular application or single propose as it may refer to the process of local or international restructuring of financial and business relationships between related persons. This includes but is not limited to termination or s​ubstantial renegotiation of existing arrangements. Restructuring may also include business internal reallocation of functions, assets, risks within an MNE. Relationships with unrelated persons may also be a reason for the restructuring and/or be affected by it. Additionally, changing job descriptions of team members or rationalizing business processes, including reducing the number of workers or closing operational processes, can be considered as reconstruction. In case that a reconstruction process takes place, the taxpayer should click (yes) in the disclosure form and it has to be reported.​