Contact
Giampiero Guarnerio

Certified Tax Consultant (Italy), Certified Public Auditor (Italy)
Partner
Phone: +39 (02) 63 28 84-1
E-Mail

Hans Röll

Verantwortlicher Beratungsfeld Transfer Pricing
Associate Partner
Phone: +39 (04 71) 19 43 - 200
E-Mail

TP Brochure

Transfer Pricing in Italy

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Transfer Pricing documentation in Italy

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TP Global Update

08.06.2017 Country-by-Country exchange relationships

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02.06.2017 OECD discussion draft: guidance on hard-to-value intangibles

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23.05.2017 Czech Republic: Binding opinions on the determination of the tax base of permanent establishments

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18.05.2017 UN has published an updated version of the TP Manual for Developing Countries

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Considering that our clients are mostly companies belonging to multinational groups, Rödl & Partner has created a Transfer Pricing Service Line with Transfer Pricing Specialists active in more than 30 countries.

Within the Transfer Pricing Service Line we support internationally active clients on a global scale in their individual set-up, documentation and defense of cross-border transactions as well as in other transfer pricing related topics (e.g. Patent Boxes, valuation of intangibles, permanent establishment issues). A transnational coordination of transfer pricing concepts and arm’s length values is essential for incrementing the tax certainty of transfer pricing systems. Therefore we closely collaborate with colleagues from all over the world. Apart from that, we actively monitor local and international developments and take part in their elaboration.  

In this regard, the OECD/G20 initiative against ”Base Erosion and Profit Shifting” (BEPS) is currently one of the most important developments in international taxation. Of the 15 agreed Action Points, not less than five ( Action 7, 8, 9, 10 and 13) are directly concerned with transfer pricing issues, which underlines the relevance of the topic for internationally operating enterprises.

For more information about recent developments and articles drawn from practical experience please refer to our BEPS-Special as well as to our TP Global Update.

Our Services
We advise and support you with our industry expertise in the development of a transfer pricing strategy tailored to your business.

Our services include the entire spectrum of transfer pricing advice and, in such context, in particular:

Planning

  • Analysis of existing transfer pricing systems under risk considerations
  • Development of transfer pricing systems
  • Selection and application of appropriate transfer pricing methods according to national and international transfer pricing standards
  • Design and implementation of transfer pricing guidelines
  • Preparation of database and benchmark analyses
  • Support regarding special topics (e.g. Business Restructurings)
  • Support with related fiscal topics (e.g. questions regarding employee secondments or permanent establishments)

Documentation

  • Preparation of transfer pricing documentation according to local and international standards
  • Preparation of transfer pricing documentation according to BEPS Action 13
  • Review of existing documentation
  • Functional and risk analysis
  • Analysis of value chains
  • National and international coordination of documentation
  • Development of coordinated documentation processes (Roll-Outs)

Defense

  • Support during tax audits
  • Support in arbitration proceedings and mutual agreement procedures (MAP)
  • Advanced Pricing Agreements (uni-, bi- and multilateral)

Special Topics    

  • Business Restructuring
  • Permanent Establishments
  • Employee secondment
  • Cost allocation systems
  • Valuation of intangible assets
  • Patent Boxes