Our Offices
The Team constantly monitors the evolution of the Transfer pricing practice by analysing the changes in the legislation and the national and international jurisprudence with the aim to identify the interpretative trends which may constitute fiscally risky situation on one side or an opportunity for our Clients on the other.
The Transfer pricing and its «methodologies» have reached a fundamental relevance for all those attractive and incentivizing regimes specifically conceived to attract particular economic activities or assets like, for example, the Patent Box regime. In this field as well the Team analyses and deepens its knowledge on the constant legislative production and its official interpretation by the local Authorities in order to be able to follow the Clients during all the necessary administrative steps.
The Transfer Pricing Focus Team is the perfect match for Clients, mainly represented by MNEs, requesting high level advisory services on (i) the design and revision of the group transfer pricing policy in an efficient manner and responding to the best international practices together with the necessary documentation (ii) the negotiation of Advance Price Agreements with local Tax Authorities (iii) filing of Patent Box rulings and negotiations (iv) litigations arising from tax audits claiming the breach of the arm’s length principle in intragroup transactions.
