The globalization of business brings with it the need to consider the international dimension of taxation. The correct managing the fiscal dimension of the management of the company or group of companies is decisive for decision-making within companies, both for multinational companies operating in Italy, and for Italian companies seeking to expand abroad.

Our support consists, on the one hand, in providing the client with a clear regulatory framework in which it operates, for compliance with the rules set by the various legislations and, on the other hand, in designing an appropriate strategy to the corporate structure, to the operational and business model and, ultimately, to the objectives of the property.

We can assist you with an analysis of the international structure of your business and in the assessment of the related tax profiles, such as – for example – those relating to the ownership of the company, the structuring of transnational loans, investments and divestments.

The International Tax Service includes a special support related to direct European taxation (EU Direct Tax Group) relating, for example, to topics such as respect for fundamental freedoms, European directives, state aid, etc. and specialists in tax issues and opportunities related to incentives on Research and Development (Global R & D Incentives) provided in the various territories.

With particular reference to business groups, in terms of transfer pricing we support the customer with the following activities:

  • analysis of the application of the regulation on Transfer Pricing (including the functional and economic analysis) and in the preparation of the national documentation (Master file and Country file);
  • preparation of the benchmark analysis;
  • application of arbitration procedures under EU law and international double taxation treaties to resolve double taxation issues resulting from transfer pricing adjustments.