Transfer pricing plays a central role in the field of intra-group transactions and intra-company value chain management.
Our team of experts in transfer pricing can count on many years of experience and continuous training in this field and can provide our clients with high-level professional advisory on the following issues: development and revision of transfer pricing policies, preparation of master files, country master files and country-by-country reporting as well as inter-company contracts.
We also support multinational companies in planning value chain management and analysing the necessary operations for corporate restructuring in order to optimise internal corporate processes and possible tax consequences, both at national and international level. This also includes negotiations with the Italian tax authorities of prior agreements on intra-group transfer pricing (so-called ruling).
We provide support in dealing with tax authorities: from inspections to all subsequent stages of adversarial proceedings with the Italian tax authorities, such as tax assessment settlement, appeals to tax commissioners and conciliation, and mutual agreement procedures (MAP, EU Arbitration Convention).