The gap surfaces when money moves across it.
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During diligence the buyer's team asks for three years of transfer pricing documentation. You do not have it.
1
During a funding round the US investor's counsel asks why the IP sits outside the parent. Your answer is "historical reasons." The counsel notes this.
2
During expansion into a fifth country your team discovers the three existing entities cannot cleanly send employees there without a fourth restructuring.
3
During a tax audit in one country the authority requests documentation from the other three. Your four advisors have never worked together.
The cost arrives on someone else's schedule.
It is not negotiable. It is also not small.
A typical multi-jurisdictional reorg runs $200K to $1.5M in professional fees. A preventive structural read runs a fraction of that.
· The event nobody plans for ·
The event that surfaces the gap is always the event you did not plan for.
That is why the gap survives this long.