The globalization and reorganization of businesses can lead to high synergies, operating leverage, and cost savings. For these objectives to be realized, however, a cross-border migration of business functions must take place. In this article from Tax Planning International Transfer Pricing, NERA Special Consultant Dr. Alexander Voegele examines new German legislation that concentrates on the relocation of functions and imposes taxation thereon. Dr. Voegele notes that this law will not only lead to high taxes, but will also have a major impact on the structuring of future group reorganizations as well as on the valuation of intellectual property overall.