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Transfer Pricing

Transfer Pricing management in compliance with the “arms’s length” principles is achieving a growing importance in the present business scenario, that, due to the advance of globalisation processes, implies a corresponding increase of intragroup commercial transactions.

PwC TLS Avvocati e Commercialisti has formed a multi-disciplinary, dedicated and specialist team with more than 20 years of experience in the sector to deal effectively with the issues arising from Transfer pricing. The team is composed of highly qualified professionals with expertise in their different areas of practice (tax, legal, functional analysis, financial analysis, etc.) and also availing itself of a vast network in over 80 countries.


Our services

The Transfer pricing team can help clients providing a vast range of services.

Italian Transfer pricing documentation

Assistance in preparing a set of Transfer pricing documents in compliance with the specifications in the Director of the Revenue Agency’s Order of 29 September 2010.

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Global Coordinated Documentation

Assistance in preparing a set of Transfer pricing documents for the whole Group on the basis of a coordinated global approach which also satisfies local requirements while preserving efficiency under a costs management perspective.

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Business model analysis and Transfer pricing policy

Support in scrutinising the coherence of your business model with your intercompany pricing system to identify and mitigate the potential risks associated with your transfer pricing policy, taking an approach based on current international developments.

Assistance in working out, formalising and implementing Transfer pricing policies.

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Financial Transfer pricing

Assistance in analysing the transfer pricing of financial transactions.

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Advance Pricing Agreement (international rulings)

Assistance and support during the procedures for the negotiation of unilateral and multilateral Advance Pricing Agreements (APAs) with tax authorities.

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Litigation management

Advice and assistance during inspections, agreed settlement procedures and tax disputes in connection with transfer pricing, including representing you before the competent judicial and administrative bodies.

Assistance during Mutual Agreement Procedures to settle international transfer pricing disputes.

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Corporate restructuring - Value Chain Transformation

Advice and assistance in corporate restructuring operations for an efficient value chain management process.

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Contact us

Alessandro Caridi

Tax Partner, PwC TLS

Tel: +39 02 91605016

Gianni Colucci

Tax Partner, PwC TLS

Tel: +39 02 91605509

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