Services
We offer our clients the following services:
Preliminary check-up
Multinational Enterprises are not always adopting properly structured and/or consistent pricing systems, and may also be unaware of some weak areas. Through a preliminary check-up, we can help you identify the strengths and weaknesses of your pricing system.
Documentation and Planning
Tax Authorities worldwide are imposing new and more severe documentation requirements on companies in relation to their transfer pricing arrangements. Failure to comply can result in significant penalties. We can help you in developing coordinated global transfer pricing documentation and defense files, as well as separate country reports. This process is coordinated centrally to ensure consistency and accuracy in the entire work project.
Economic Analysis
In many cases, the stricter documentation requirements imposed on companies imposed by Tax Authorities worldwide in relation to transfer pricing transactions make it necessary to perform an economic analysis. We have access to regional and global databases, which help us to carry out comparable searches aimed at determining the appropriate remuneration for all types of intercompany transactions, such as flow of goods, services, intangibles, loans, guarantees, and royalties.
Dispute Resolution
In the last few years, there has been an increase in transfer pricing audits, and this trend is not expected to change. We can assist you in identifying transfer pricing risks, and avoiding, managing, and resolving transfer pricing disputes and audits in a coordinated manner.
Advance Pricing Agreements
Under an Advance Pricing Agreement (APA) procedure, the Tax Authorities and the Tax Payer conclude an agreement on the transfer pricing methodology. The APAs provide taxpayers with greater certainty in managing their tax risks and potential exposure to risks. We can help you in all issues and steps to take advantage of this procedure.
Valuations
In a business-restructuring environment, when transferring assets within a group, it is important to have an economically solid valuation to support the transfer values. We can provide high quality valuation services for a number of purposes, such as cross border migration of intangibles and functional re-characterization of group entities (e.g. conversion from distributor to agent).
Patent Box Analysis
The Italian legislation provides for an optional tax benefit system in relation to the exploitation of certain intangible assets. We can perform an economic and functional evaluation to support you in determining what part of the tax benefit can be ascribed to these intangible assets.
