Transfer Pricing | Fieldfisher
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Transfer Pricing

Transfer pricing is becoming an increasingly important strategic issue for multinationals in a globalised economy and is a critical aspect to which the tax authorities of developed countries are dedicating particular attention.

Why choose our Transfer Pricing lawyers?

Fieldfisher Italy has developed a highly-specialised, dedicated team capable of providing the client with effective support in preparing documentation on the existing transfer pricing system and in structuring new intercompany pricing policies.  This is vital when in correctly determining the prices applied to commercial and financial operations between associated or controlled companies resident in different countries.

We developed a methodology that starts with a detailed analysis of the situation and the management, organisational and tax characteristics of the client’s business, in order to identify the value drivers of the company’s value chain. The next step is to prepare the transfer pricing policy and the relative documentation, based on OECD directives and the laws of the countries involved.

For companies expanding to international markets, we start by identifying the forecast value drivers followed by the structuring of a transfer pricing policy that complies with domestic and international policies and the drafting of the relative documentation.

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We can support clients in all areas of Transfer Pricing including:

  • Identifying relevant transactions
  • We can provide functional analysis of the breakdown of activities, responsibilities and risks between Group companies
  • We also provide economic analysis, search for ‘comparables’ and verification of the suitability of prices applied
  • We can verify  documents supporting the transfer price assessment 
  • We prepare the ‘Master Files’ and ‘Country Files' in accordance with the laws in force
  • We prepare and develop the transfer pricing policy and preparation of the relative documentation 
  • We can review existing transfer pricing policies
  • We analyse and support the reorganisation of the business model - if needed
  • We help clients prepareunilateral and multilateral agreements APA.

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