Transfer pricing

The Italian legislation provides the non-application of the administrative penalty (from 100% to 200% of the higher tax eventually assessed) in case of disputes on transfer pricing, if during the verification or inspection by the authorities, the taxpayer gives to them the necessary documentations for all those fiscal years which are still open for assessment purposes (for which the taxpayer has previously sent a specific communication to the tax authorities).


Our services include:


  • Verification of transfer pricing implemented by our clients.
  • Refinement of the TP model used identifying possible areas of improvement of the model for future years.
  • Preparation of the documentation: master file/country specific documentation.
  • Analysis of the relationship among companies of the group and identification of the cases considered particularly critical/sensitive.
  • Check up of the documentation to verify the adequacy (or any differences) compared to the standard required by current law.
  • Support to the preparation/integration of the documentation required by current law.
  • Assistance in case of tax litigation.
  • Periodical review of documentation.