Why choose our Transfer Pricing lawyers?
- Identifying relevant intercompany transactions and review of the existing transfer pricing policies.
- Identifying Key Entrepreneurial Risk Taking (KERT) function along the value chain (Functions, Risks, and Assets analysis) as well as key value drivers/asset.
- Planning efficient and arm’s length/BEPS compliant transfer pricing policies.
- Providing an economic analysis, searching for ‘comparable’ with a specialised international database, and verifying the suitability of prices applied.
- Preparing and developing transfer pricing documentation (‘Master Files’ and ‘Country Files') in accordance with the laws in force.
- Preparing intercompany agreements and cost share agreements.
- Analysing and supporting the reorganisation of business models and business restructuring.
- Evaluating the impact of new/proposed transfer pricing regulations, CFC rules, Permanent Establishment and withholding tax rules, VAT and customs duties on implementing structures.
- Preparing unilateral and multilateral Advanced Pricing Agreement (APA) and participating in negotiations with tax authorities.
- Supporting in Country by Country reporting obligations.
- Helping with tax transfer pricing audits and assistance in managing relationships with tax authorities.
- Preparing and discussing Mutual Agreement Procedure (MAP) and arbitration.
- Identifying and evaluating intangible assets (brand, software, patent, know-how and others hard to value intangibles).
- Providing due diligence for M&A transactions.
How?
Fieldfisher Italy's expert Transfer Pricing team works with multinational corporations to develop tailored transfer pricing strategies that mitigate risks, optimise tax outcomes, and support sustainable business growth.
Transfer pricing is a cross-sectional discipline provides in-depth insights into the internal dynamics of organisations; therefore, our expert team collaborates with colleagues from different areas of an organisation such as legal, HR, VAT, corporate governance and litigation, and creates internal and cross-border opportunities for civil, regulatory, anti-trust, IP, financial, and tax departments.
Why
Transfer pricing is an extremely competitive area however Fieldfisher Italy can compete with the bigger players in the market and has developed a highly specialised, dedicated team capable of providing our clients with effective and tailored support in all transfer pricing matters such as:
- Designing, planning and structuring transfer pricing policies compliant with the arm’s length criteria/BEPS recommendations (on goods, services, royalty, and financial transactions).
- Preparing agreement and proper documentation, including benchmark analyses.
- Supporting in case of transfer pricing audit and in managing relationships with Tax authorities, including MAP and APA procedures.
Our team has developed a methodology that starts with a detailed analysis of the situation, and the management, organisational and tax characteristics of our client’s business to identify the value drivers of the company’s value chain. We then expertly prepare the transfer pricing policy and the relative documentation, based on OECD directives and the laws of the countries involved.
We specialise in the consumer goods and apparel, luxury, financial services, healthcare equipment, pharmaceutical, banking and insurance, and software and service industries.
