Transfer Pricing (TP) risk management
MUSE STRATEGY assisted a client – a company belonging to a multinational group – during a tax audit conducted on multiple tax periods by the competent office of the Italian Revenue Agency as well as in all subsequent phases of the relationship with the tax authorities (from the attempt to reach a settlement to the activation of the mutual agreement procedure – MAP – to resolve double taxation). Furthermore, in light of the possible consequences of the dispute on tax periods subsequent to those audited, it was decided – in a proactive and collaborative approach with the Revenue Agency, to initiate the advance pricing agreement (APA).
Industry: Mechanics
The main areas of intervention can be represented as follows:
- TP tax audit
- Tax settlement procedures
- Filing of appeal to the tax court
- Application for the MAP
- Updating of TP documentation for penalty protection
- Admission to the APA (bilateral with roll-back option)