Taxation of international relations and transfer pricing

The Firm provides tax advice on all issues relating to international relations, providing assistance to taxpayers

• on the analysis and solution of double taxation cases;
• on the criteria for identifying tax residence, natural and legal persons and entities;
• on the interpretation of the rules of the international conventions against double taxation;
• on the establishment of out of court and arbitration procedures (Mutual Agreement Procedures);

The firm also offers its assistance in the application and correct interpretation of OECD interventions with regard to the treatment of multinational companies and in the monitoring of issues relating to the so-called "harmful tax competition".

The Firm develops methodologies and quantitative analyses in the field of transfer prices, also in agreement or with the collaboration of expert economists, assisting its international clients in determining the normal value of the goods and services transferred within the group, taking care of contract management and the preparation of the supporting tax documentation.

The Firm offers assistance in international ruling procedures , Advance pricing agreement (APA) and Mutual Agreement Procedures (MAP).