Transfer Pricing: tax optimization and compliance for multinationals

Transfer Pricing is a key element of tax management for multinational corporations, directly influencing pricing in intercompany transactions to ensure that such transactions take place at market values and comply with the tax regulations of the various countries involved.

Compliance with OECD principles and local regulations is essential to reduce the risk of tax claims and to ensure compliance.

By properly implementing TP policies, we:

  • minimize double taxation
  • optimize tax management
  • improve tax compliance with tax authorities

Establishing a robust Transfer Pricing framework, companies can operate in an international environment with greater security and transparency, reducing the risk of tax disputes.

Why choose Andersen for Transfer Pricing?

We support multinational companies in implementing compliant, efficient TP policies, minimizing the risk of tax adjustments or penalties. Due to our experience and in-depth knowledge of international regulations, we offer customized solutions for every business reality.

In addition to ensuring compliance, we help companies structure Transfer Pricing policies that improve the operational efficiency and clarity of business functions.

Our services include:

  • Defining and implementing TP strategies to guarantee regulatory compliance and tax efficiency, consistent with the functions performed and risks assumed.
  • Conducting benchmark analysis for transfer pricing, in line with the arm’s length principle.
  • Providing TP documentation complying with OECD guidelines, reducing the risk of claims.
  • Managing APA and MAP procedures to reduce tax uncertainty and prevent double taxation.
  • Providing assistance in audits and litigation, representation and strategic support in dealings with tax authorities.
  • Optimizing tax for intellectual property management by properly allocating revenues and costs across jurisdictions.
  • Providing professional development and training for corporate staff so that they can independently handle key Transfer Pricing issues.

 

Planning and implementing TP Policy

We provide consulting on the valuation of intercompany transactions, analyzing:

  • The allocation of taxable revenues and costs in individual jurisdictions in line with the functions and risks assumed.
  • Strategies to better manage double taxation issues and reduce the risk of penalties.
  • Price structures that comply with local and international regulations.
  • TP solutions for the digital economy and new global business models.

 

Assistance in audits and litigation

Our team assists companies in tax audits and TP litigation proceedings, providing strategic support and representation before tax authorities in Italy and abroad. With our experience, we can handle interactions with tax administrations and support clients in preparing defense briefs and gathering documentary evidence to support their tax position.

 

Documentation and Compliance

 We prepare TP documentation to ensure transparency and compliance, drawing up:

  • Master File and Local File according to OECD Guidelines and in compliance with local regulations, ensuring proper reporting of intercompany transactions.
  • Country-by-Country Reporting (CbCR), in accordance with OECD and BEPS guidelines.
  • Benchmark analysis to demonstrate the appropriateness of the TP policies adopted.
  • Preparation of documentary evidence to support tax positions in case of audit.
  • Periodic monitoring of Transfer Pricing strategies to ensure continuous alignment with international best practices.

An effective transfer pricing strategy reduces tax risks and ensures that transactions between affiliates are conducted in accordance with the arm’s length principle. Our consulting helps companies structure their transactions efficiently and in compliance with international regulations, while ensuring proactive management of emerging tax risks.

Synergies with other service departments

To ensure an integrated approach to international tax management, we work closely with other specialized teams, including:

  • International Tax: to support companies in international tax planning, with targeted strategies for optimizing the tax burden and managing double taxation risks.
  • VAT (VAT, Indirect Taxes & Customs): to ensure efficient management of indirect taxes and compliance with European and international VAT regulations.
  • Global Mobility: to support the taxation of internationally mobile employees, managing any impacts on business functions.
  • M&A (Mergers & Acquisitions): to provide strategic consulting on M&A transactions, with a focus on tax risk analysis in TP.
  • Corporate Legal: to deal with international contracts and manage legal aspects linked to intercompany transactions.
  • Corporate Finance & Valuation: to integrate international tax and transfer pricing strategies with financial analysis and business valuation.
  • Risk Management and Compliance: to ensure continuous monitoring of tax risks and develop mitigation strategies.

Through this multidisciplinary collaboration, we are able to offer integrated, customized solutions, contributing to more efficient, strategic tax management for multinational companies.

Relying on our team means benefiting from a comprehensive and innovative approach capable of adapting to ever-changing global tax regulations.