Transfer Pricing and Business Restructurings

Table 1:

Changes in functions, assets, and risks pre- and post-restructuring

9

Table 1:

Summary of the OECD control over risk guidance

33

Table 2:

The overview of the responsibilities and risks of the different levels of the distributor business models

46

Table 3:

A summary of the functions/assets/risks of MyFashion France and Italy

56

Table 4:

Impact of headcount

57

Table 1:

Contractual terms and description of the distribution agreement

82

Table 2:

Functions performed, risks assumed, and assets used by the relevant related parties under the pre-restructuring scenario

83

Table 3:

Functions performed, risks assumed, and assets used by the relevant related parties under the post-restructuring scenario

86

Table 4:

Comparison of the functions performed, risks assumed, and assets used before and after the reorganization under analysis

87

Table 5:

Values considered for the purpose of the present analysis

94

Table 6:

The arm’s length range of OMs resulting from the benchmarking analysis

96

Table 7:

Revenues and the related incomes (NOPAT) that the distribution of Alfa products in the Spanish market is expected to generate over the valuation period

98

T...