Transfer Pricing & Operational Modeling.

• Identification and analysis of the operational model
• Definition of the intercompany flows
• Design and review of TP policies
• Preparation and update of intercompany agreements supporting different types of transactions (goods, services, IPs, CCA, CSA, finance, secondment of personnel)
• Revision of the value chain and business restructuring projects

• Economic analyses and benchmarking exercises concerning products, support services, tangible assets, intangibles (IPs), services of strategic nature, financial services, secondment of personnel
• Preparation of master file, local file and Country by Country Reporting (CbCR)
• Analysis and implementation of Pillar 2 provisions

• Analysis and coordination of TP provisions involving different foreign countries
• Tax residence issues of foreign subsidiaries
• Permanent Establishment
• Controlled Foreign Companies (CFC)
• Black-list costs
• Application of double tax treaties
• EU Directives
• VAT
• Custom duties
• Analysis of the tax position of the managers relocated abroad (expatriates) 

Assistance in the negotiation of APAs with the Tax Administrations concerning: 

• Transfer Pricing
• Existence of a permanent establishment
• Attribution of profit to the permanent establishmen
• Application of EU directives

• Support during inspections of the tax administration
• Preparation of appeals before the competent tax courts
• Negotiations of settlement agreements and conciliation deeds

Activation of procedures (between the tax administrations involved) aimed at settling double taxation issues