Activities - Transfer Pricing

Transfer Pricing

Transfer pricing concerns the definition of intra-group transactions that take place between a domestic entity and a related one located in a foreign country: contractual clauses, pricing of goods and services (including financial transactions), related supporting documentation, advance agreements with the Italian and foreign tax administrations.

Main activities

  • Revision of the transfer pricing policies applied
  • Definition and implementation of new TP policies
  • Benchmarking analyses (goods, services, financial transactions, IP licensing), including through specific data bases
  • Preparation of transfer pricing documentation (Masterfile, Country File, Country by Country Reporting)
  • Drafting of agreements supporting infra-group transactions
  • Negotiation of Advance Pricing Agreements with the Italian and foreign Tax authorities
  • Assistance during tax inspections, tax settlement procedures, tax litigation and appeals before the competent tax courts
  • Activation of international proceedings in order to solve double taxation cases (i.e., Mutual Agreement Procedures – MAPs; EU Arbitration Convention)

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