Transfer Pricing

In the current globalized economy, it is essential to establish transfer prices that are consistent with the overall policies implemented by corporations and compliant with relevant regulations. Our team assists large multinational corporations in examining and defending policies and procedures concerning transfer prices as well as in drafting the appropriate transfer pricing documentation. We support the top management of enterprises in the definition and in the management of transfer pricing policies also with reference to processes of corporate restructuring.

  • Definition of intercompany flows [in terms of strategy, management, economy and finance];
  • Drafting of group tax governance protocols [codes of conduct, residence multitest, tax compliance group policy, tax risk control framework policy, etc.];
  • Design of group transfer pricing policy according to Regulation of 29.9.2010 and Circular 58/15.12.2010);
  • Functional analysis (FAR analysis), comparability analysis and benchmarking (on 11 different platforms and databases);
  • Analysis and drafting of group contracts;
  • Tax rulings and advance pricing agreements (APA unilateral and bilateral);
  • Tax audits;
  • Pre-litigation assistance (check-upstress test, sampling);
  • Litigation in relation to transfer pricing (of any grade);
  • Criminal tax law.

Publications on Transfer Pricing