Post-BEPS, post-pandemic corporate reorganization, whether it is driven by controversy risk mitigation or commercial necessity, often involves restructuring of intangibles and the associated R&D activities. The restructuring options and potential solutions have to be evaluated based on transfer pricing considerations in the OECD Transfer Pricing Guidelines and the interpretations that countries have adopted in respect of these guidelines. At the same time, we see an increase in tax audits and litigation related to transfer pricing and intangibles. Often these cases relate to royalty rates, cost sharing or intangibles being transferred within the group. Where are the stress points that often give rise to disputes? What are some of the strategies that multinational groups could consider in order to manage potential disputes? What is the anticipated impact of the OECD two-pillar solutions on the structuring of intangibles and R&D activities?