Andersen with FCA Bank for an Advance Pricing Agreement

Advance Pricing Agreement concerning the infra-group financial transactions centralized at the Treasury of the Parent Company

An Andersen team led by the partners Maricla Pennesi, Tax Coordinator for Italy and Europe, Stefano Rossi, TP Coordinator for Italy and Europe, and Giovanni Gallucci, international tax expert, assisted FCA Bank in the negotiations with the Italian Revenue Agency – Direzione Centrale Grandi Contribuenti – Ufficio Accordi Preventivi, aimed at signing an Advance Pricing Agreement (APA).

Andersen, in constant collaboration with the internal Treasury and Tax functions of FCA Bank, provided support for the Advance Pricing Agreement, concerning the infra-group financial transactions centralized at the Treasury of the Parent Company: the cash management system and hedging on interest rate derivatives.

The agreements, which have the purpose of providing preventive certainty regarding the criteria and methods adopted for determining transfer prices, comply with the standards laid down by the OECD and the European Union. They are tax policy instruments that refer to the calculation criteria for determining the normal value of intercompany transactions in line with the recent guidelines on financial transactions published by the OECD last February.

The operation aims to achieve, in a context of transparency and collaboration, information symmetry between the company and the tax authorities. On the part of FCA Bank, there will be an ongoing dialogue to share the transfer pricing methodology applicable to intercompany transactions over the five-year period 2020-2024.