Transfer pricing international advice and planning

We design and assist in transfer pricing policy planning, advise on restructuring and internationalisation processes.

In the current context of the global economy, most companies have internationalised, becoming multinational groups of varying sizes. Traditional business models have given way to the digital economy and e-commerce, opening up opportunities for companies but also generating new problems in the tax field and, in particular, in Transfer Pricing.

The Covid-19 is also bringing about a change in business models and in the perspective of companies’ economic activity, moving away from an exclusively global vision to one that also includes the strengthening of a more local or regional scope of action.

In addition to the above, the international community, through the OECD and the G20, has evolved the regulatory paradigm by introducing new principles of action in international taxation that go beyond the traditional arm’s length Transfer Pricing.

In all these cases, it is essential to establish a correct Transfer Pricing policy, aligned with the business strategy, and to generate value in the company (“Value Chain analysis”), both to achieve an efficient management of the supply chain of goods and services, and to avoid the generation of future tax controversies with the tax administrations.

Our services include the following:

  • Design and modelling: We advise multinational companies and groups on the design and modelling of the most appropriate Transfer Pricing policy for their business strategy and operations, both at national and international level.
  • Internationalisation and changes in the busines model: Advice on the internationalisation and restructuring processes of multinational groups’ internal operations, both in the establishment of the new related operations and in the justification and validation of these business processes, for the purposes of the regulations in this area.