The Firm’s professionals provide assistance in the issues concerning transfer pricing policies in the context of transactions between companies within multinational groups (so-called transfer pricing).
The Firm assists companies in managing possible risks linked to the infra-group transfer pricing policies, through the following areas of activity:
- preparation of the appropriate documentation for the purposes of the penalty protection referred to in Article 1, paragraph 2-ter of Legislative Decree 18 December 1997, n. 471, in compliance with the provisions of the Provision of the Director of the Italian tax authority of September 29, 2010. The main activities performed by the professionals of the Firm for the purpose of preparing the appropriate documentation are as follows:
- identification of the relevant transactions and verification of the supporting documentation for the transfer pricing policy implemented;
- functional analysis: analysis of the activities carried out and the risks assumed by the entities involved in the transactions being analyzed;
- economic analysis, also through the identification of comparable companies, aimed at verifying the fairness of the applied intercompany prices;
- review and / or definition of the existing transfer pricing policies, including revision or preparation of the related contracts;
- analysis and reorganization of the business model implemented by the company and by the multinational group it belongs to;
- assistance in the tax audits carried out by the Tax Authorities concerning transfer pricing issues and in subsequent litigations.