The recent developments in the field of transfer pricing and business restructurings need to be analyzed more carefully and this research is mainly to identify transfer pricing issues arising for MNE Groups whenever they decide to restructure their functions by transferring intangible property.

Also, this paper will identify what is an intangible property, who is considered to be the owner of the intangible, when a intangible is deemed to be transferred and how to achieve the arm's length price for the controlled transaction. Moreover, this research will analyze a few issues pointed out by the OECD in the Discussion Draft regarding transfer pricing aspects of business restructurings.