Michele Ghiringhelli

I provide consultancy on transfer pricing and on the analysis of managerial, organizational and tax characteristics of the business, identifying the “value drivers” within the “value chain”, drafting the Transfer Pricing policy and respective documentation. I also provide assistance in stipulating unilateral and multilateral agreements with the Revenues Agency (APA) and in dealing with the taxation of Intellectual Property, Patent Boxes and, more generally, benefits connected to R&D activities and Intellectual Property.  

In the past, I have dealt with domestic and international taxation, extraordinary operations, tax structuring and due diligence of companies operating, in particular, in the sectors of Energy, Oil&Gas and Information Technology. 

I have studied in-depth the IAS/IFRS international accounting standards with the publication of a book regarding the impact of those standards on Italian taxation.  

I am a speaker at workshops, international and national courses on Transfer Pricing and international taxation and I regularly publish articles on matters connected to transfer pricing in Italian and international industry journals.  

My Team and I are looking for a dynamic environment that could let us take off in terms of business developing. With my tax colleagues of the other Fieldfisher offices we are working to build up an international tax practice to attract and develop cross border transactions and to provide services to multinational entities.  

I started to work in transfer pricing practice in 2 Big Four, and in Fieldfisher I contributed towards creating transfer pricing within the Italian structure and at international level. Since 2015 I developed the Italian innovation tax benefit (ITB) practice.  

Transfer Pricing is really competitive and it is dominated by the Big Four on TP side and by financial companies on ITB. Such companies are extremely competitive on commercial side using their presence related to audit needs (TP) and banks relations (ITB), but we believe they provide standard services.  

My Team and I are able to compete with them pushing on the high quality of the services rendered using economic database and involving colleagues of other tax and legal practices relationships.  

TP is a cross-sectional discipline within the business field, and it has given me in-depth knowledge of the internal dynamics of companies, as We have come into contact with senior figures of the various departments, collaborating in close contact with colleagues of different disciplines such as Legal, HR, VAT, corporate governance and tax litigation.  

The analysis of functions and risks within the corporate field has enabled my Team to develop expertise in the area of tax risk management, cooperative compliance and in the various disciplines involving the structuring of management, monitoring and control systems and the tax risk.  

We have been really active in understanding client needs and to provide opportunities for colleagues every time it has been possible. Cross selling is one of our main strategies in developing our business because, other than get new mandates, helps to strengthen the relationship with each client.