Transfer Pricing
The importance of arm’s-length transfer pricing for multinational enterprises (MNE) has boomed in recent years on account of the upswing in trans-border dealings. The greater importance now attributed to this issue by national fiscal authorities is justified by the fact that MNE, leveraging on intra-group transfer prices between related parties located in different countries, could transfer taxable income from one country to another.
VVA Expert Opinion has recently gained unique expertise in this field, having adopted, sole Italian business consulting firm, an integrated approach between our business and economic competencies and fiscal know-how provided by external tax law firms we have teamed up with on a permanent basis. The added value for clients stems from combining specific expertise in the two areas of competence.
The approach has proved successful in a large number of projects conducted for Italian MNE (with subsidiaries abroad) as well as for overseas ones (with subsidiaries in Italy), so tackling the issue from every different perspective.
VVA Expert Opinion carries out the economic studies that form the methodological base for tax opinions. Distinctive features of VVA Expert Opinion’s profile include:
- deep knowledge of OECD guidelines, contemplated methods (CUP, RPM, Cost Plus, TNMM, Profit Split) and respective areas of application;
- ability to analyze, understand and interpret markets, competitive scenarios, supply chains and organizational/corporate environments;
- statistical and accounting skills;
- expertise gained in numerous industries;
- ownership and usage of the best databases available.
Some of the needs we address:
Pre-emptive economic studies which:
- comply with national and international regulations
- ensure the most effective defense in case of investigation
- provide for the best costs/benefits ratio for product transfers
Economic studies to support ongoing disputes which:
- ensure a preventive understanding of the objections raised
- contribute to the best defense strategy for the specific (corporate) context and the applicable Italian and international rules
- present the defensive arguments that best fit the level of jurisdiction
