Global TP documentation projects.
MUSE STRATEGY assisted a multinational group in a global project aimed at preparing transfer pricing documentation for each associated enterprise, wherever located. After an initial mapping phase of the intragroup transactions involving the individual companies of the group, we proceeded – with the support of the consulting firms affiliated with the Quantera Global network – to the precise identification of the TP documentation burdens in each country of interest and the subsequent operational phase that led to the preparation of masterfile, local files and economic analyses, including a careful review of the intercompany contracts.
Industry: Food & Beverage
The main areas of intervention can be represented as follows:
- Preparation of TP documentation for penalty protection in Italy
- Identification of subsidiaries for which to prepare the local file
- Analysis of any critical international tax issues that have emerged (e.g., company residence, residence ofindividuals formally resident abroad, etc.)
- Review of the operating model in relation to the diversification of the areas of activity
- Negotiation of APA-BAPA with tax authorities
- Pillar 2 – Global Minimum Tax