Transfer Pricing & Operational Modeling.

Strategic solutions for the management of intercompany flows


Operational modeling & TP policies.

  • Identification and analysis of the operational model
  • Definition of the intercompany flows
  • Design and review of TP policies
  • Preparation and update of intercompany agreements supporting different types of transactions (goods, services, IPs, CCA, CSA, finance, secondment of personnel)
  • Revision of the value chain and business restructuring projects

Benchmark analyses and documentation.

  • Economic analyses and benchmarking exercises concerning products, support services, tangible assets, intangibles (IPs), services of strategic nature, financial services, secondment of personnel
  • Preparation of master file, local file and Country by Country Reporting (CbCR)
  • Analysis and implementation of Pillar 2 provisions

Analysis of international taxation aspects.

  • Analysis and coordination of TP provisions involving different foreign countries
  • Tax residence issues of foreign subsidiaries
  • Permanent Establishment
  • Controlled Foreign Companies (CFC)
  • Black-list costs
  • Application of double tax treaties
  • EU Directives
  • VAT
  • Custom duties
  • Analysis of the tax position of the managers relocated abroad (expatriates) 

Advance Pricing Agreements (APA) concerning international taxation topics.

Assistance in the negotiation of APAs with the Tax Administrations concerning: 

  • Transfer Pricing
  • Existence of a permanent establishment
  • Attribution of profit to the permanent establishmen
  • Application of EU directives

Assistance during tax inspections and in the subsequent litigation phases.

  • Support during inspections of the tax administration
  • Preparation of appeals before the competent tax courts
  • Negotiations of settlement agreements and conciliation deeds

Mutual Agreement Procedures (MAP).

Activation of procedures (between the tax administrations involved) aimed at settling double taxation issues

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