Tax Valuation and Business RestructuringIntercompany transfers of assets and activities by multinational companies have

attracted increased scrutiny of tax authorities in recent years. Besides transfers

of intellectual property and relocations of functions, regulations are increasingly

focused on conversions of businesses that involve profit shifts between various

jurisdictions. These developments require companies to involve more analysis and

documentation when deciding to transfer assets or restructure their organizations.

Ryan provides valuation analysis and supports companies in fulfilling compliance

obligations in relation to intercompany transfers. In addition, Ryan can advise in

an initial phase of a business restructuring project by offering design and financial

modeling services. By combining valuation and transfer pricing expertise, we offer

a unique set of tools that enables companies to manage, restructure, and support

intercompany transfers from a tax perspective.

Tax Valuation Services

Ryan provides valuation services in the context of a transfer of assets or shares to

support the fair market value, the fair value, and/or the arm’s length nature of the

transfer. In this regard, our services include:

Valuation of shares

Valuation of a portfolio of group companies

Valuation of registered patents or trademarks

Valuation of goodwill or profit potential

Business Restructuring Services

Ryan also provides valuation analysis in the context of intercompany restructurings. These restructurings may be initiated for various reasons such as an international expansion, a post-merger integration or a rationalization of company assets and resources. The types of services in this context are broad and may include:

Transfer pricing design of cross-border restructurings

Transfer pricing scenario analysis and presentation of options available

Financial impact analyses in relation to exit taxes

Documentation of restructurings

Transfer Pricing

Ryan provides a comprehensive

suite of transfer pricing services

that enable multinational

businesses to proactively and

efficiently manage the changing

global legislative regulatory

requirements. We focus on our

clients’ business objectives and

leverage our technical expertise in

global transfer pricing principles to

identify the proper balance in

pricing cross-border transactions.

International Guidelines / OECD

Over the past years, the Organisation for Economic Co-operation and Development

(OECD) has become the internationally recognized platform for guidelines on transfer

pricing and business restructuring. According to the OECD, business restructuring is

broadly defined as the cross-border redeployment by a multinational enterprise of

functions, assets, and/or risks. Business restructurings can include the following:

Conversion of fully fledged distributors into limited-risk distributors

or commissionaires for a related party that may operate as a

principal

Conversion of fully fledged manufacturers into contract

manufacturers or toll manufacturers for a related party that may

operate as a principal

Rationalization and/or specialization of operations (manufacturing

sites and/or processes, research and development activities, sales,

and services)

Transfers of intangible property rights to a central entity within the

group (i.e., a so-called “intangible holding company”)

Local governments tend to implement OECD guidelines in local tax law. Although

local regulations and interpretations may vary among countries, the main OECD

principles are recognized and adopted locally.

Combining Transfer Pricing with Valuation Expertise

Ryan valuation professionals combine transfer pricing and valuation expertise. These

areas of expertise require an understanding of valuation techniques, accounting

standards, and tax and transfer pricing guidelines and regulations. Through this

unique combination of knowledge areas, we are able to advise clients on various

angles and perspectives and take into account interests from a multitude of

stakeholders. Stakeholders may include tax authorities, auditors, tax management,

internal corporate governance committees and/or other internal stakeholders.

International Team

Ryan has a global team with offices located in Europe, the United States, and Asia.

Our international presence enables us to provide local expertise for international

projects. In the current rapidly changing tax environment, we advise clients on the

latest local and international developments. Through our local teams, we understand

local habits and flavors and are aware of a tax authority’s ability and approach toward

tax valuation and business restructuring.

Award-Winning Tax Services

For additional information

1.855.RYAN.TAX

ryan.com

© 2017 Ryan, LLC. All rights reserved.

Ryan, LLC, Ryan ULC, Ryan Tax Services UK Limited, Ryan Tax Consulting Services Ireland Limited, Ryan Tax Services Hungary LLC, Ryan Netherlands B.V., Ryan Tax Services Australia Pty Limited, and Ryan Tax Services Singapore Pte. Ltd. provide clients with tax consulting, recovery, compliance, advocacy, technology and other client-related professional services. Ryan, LLC is a member firm of Ryan International, a Swiss Verein. Ryan ULC, Ryan Tax Services UK Limited, Ryan Tax Consulting Services Ireland Limited, Ryan Tax Services Hungary LLC, Ryan Netherlands B.V., Ryan Tax Services Australia Pty Limited, and Ryan Tax Services Singapore Pte. Ltd. are constituent entities of Ryan International, a Swiss Verein. Ryan International is a Swiss Verein whose member firms and constituent entities form a leading network of tax advisory and consulting firms, each of which may be licensed to use the name “Ryan” in connection with providing tax advisory and consulting services to its clients. The member firms of Ryan International and their constituent entities operate throughout North America, Europe and Asia in accordance with local regulatory requirements but are not a part of a single international partnership. The responsibility for the provision of services to a client is defined in the terms of engagement between the client and the applicable member firm or constituent entity. Neither Ryan International nor any member firm or constituent entity of Ryan International is liable or responsible for the professional services performed by any other member firm or constituent entity. Ryan International is not itself engaged in the practice of providing professional services. Rather, it is an international umbrella entity organized as a Verein under Swiss law. Not all member firms and constituent entities provide the full range of services mentioned within this brochure. “Ryan” and “Firm” refer to the global organizational network and may refer to one or more of the member firms of Ryan International, each of which is a separate legal entity.