Transfer Pricing

Group of experts with extensive experience in all types of transaction and in any sector, with teams specializing in designing tax governance policies.

Thanks to our extensive knowledge and experience, we provide integrated advisory services for related-party transactions by designing transfer pricing policies, handling business restructuring, and negotiating advance pricing arrangements with the tax authorities. We also assist our clients during the mandatory TP documentation including the comparability analysis. We have large experience assisting our clients during tax audits and court proceedings, and eventually in subsequent mutual agreement and arbitration procedures to mitigate double taxation.

Our lawyers have in-depth, cutting-edge knowledge of (i) regulations and both domestic and international case law, (ii) sectoral trends, (iii) the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and (iv) the reports published by the EU Joint Transfer Pricing Forum. Our teams have access to several international databases necessary for carrying out exhaustive analysis of related-party transactions.

Tax Governance

We have teams with extensive experience in designing, implementing and following up on tax governance policies that help protect boards of directors and the companies themselves from criminal tax risks. Based on the principles of the criminal code, we have developed an operational framework that strengthens tax management and reinforces the due diligence test.

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