In today’s rapidly changing transfer pricing landscape, it is important to have an effective approach for managing opportunities, compliance and risk.
The ongoing public discussion on the tax practices of multinationals and the Organisation for Economic Cooperation and Development (“OECD”) initiative on Base Erosion and Profit Shifting (“BEPS”) have had a significant impact on traditional international Transfer Pricing rules.
It is no longer enough to address planning, compliance and risk mitigation on a fragmentary basis or at the time when issues arise.
The potential cost of not implementing and documenting Transfer Pricing policies based on the “arm’s length” (appropriate) principle may arise in taxable income adjustments, penalties and interest. In addition, the administrative procedures necessary to eliminate the resulting double taxation can be lengthy and costly in terms of human and financial resources.
The WTS R&A Transfer Pricing Team has years of experience in the definition of intra-group flows, in the pre-processing of documentation, in procedures with the competent authorities of the countries involved and in tax litigation. The integration with WTS Global’s Transfer Pricing Team, a vast global network of leading transfer pricing professionals, puts us in a unique position to advise multinationals on how to implement, optimize, monitor and defend transfer pricing policies in the global context, in a “post-BEPS” manner.
Our services cover the entire scope of transfer pricing, including the following:
- Company restructuring
- Planning and optimization
- Valuation of intangible assets
- Advance pricing arrangements
- Drafting of the BEPS Masterfile and national documentation in Italy and in the individual foreign countries
- Country-by-country reporting (“CbC”)
- Defence in transfer pricing audits
- Assistance in proceedings before the competent authorities of various States
- Domestic tax controversies
Please feel free to contact us for further information.