We offer specialized technical consulting services for multinational groups in the areas of international taxation and transfer pricing.

Our professionals, with backgrounds in economic consulting, taxation and the Internal Revenue Service, support multinational groups with customized solutions, in the following areas of international taxation:

Advance pricing agreements with tax administrations

We support multinational groups in the management of Advance agreements with Tax administrations (APA/BAPA/MAP)

  • Prior assessment of operations to be submitted to competent authorities
  • Preparation of requests for advance pricing agreement
  • Development of economic analyses and technical documentation to support the procedure
  • Managing discussion with the Internal Revenue Service and foreign competent authorities

Economic assessments and analyses

We develop ad hoc economic analyses and technical opinions in line with the OECD Guidelines, as part of compliance activities or extraordinary transactions

  • Benchmark analysis on intangible assets (brands and technology), manufacturing assets, and high value-added services
  • Development of analysis and simulation models under agreements on centralized services and cost contribution arrangements (CCA)
  • Valuations of intangible assets for intercompany sales
  • Quantification through valuation techniques (DCF) of realistically available options under restructuring operations

Analysis of financial transactions

We support our clients with technical analysis in the area of financial transactions with foreign counterparties

  • Economic analysis on financial transactions, including the definition of arm’s length interest rates for loans, cash pooling, and intercompany guarantees
  • Determination of credit risk (corporate or individual credit rating) within intercompany financing transactions
  • Risk analysis and evaluation of potential Hybrid mismatches

Transfer pricing compliance

We assist multinational groups with annual activities related to ordinary transfer pricing compliance

  • Preparation of transfer pricing documentation (Master file and Country file), in line with the OECD Guidelines and the requirements of the AdE Order 23/11/2020
  • Drafting transfer pricing policies for intercompany transactions
  • Preparation of contracts to support intercompany transactions

Why choose us?

Because our professionals’ unique skills and track record of work followed over the years enable us to benefit from the esteem of demanding clients and tax administration. Client focus, quality of services offered and speed of response are our distinguishing factors in a market where competition is often driven by hourly fees.