The department has developed a market leading transfer pricing practice “TP” (with relevant mandates acquired in the course of the last year with FORTUNE 500 clients on very technical issues such as Mutual Agreement Procedures and unilateral or bilateral APAs ), in strategic partnerships with the most established TP economists; such practice, where the Firm had developed an important track record, ranges from the assistance in the design and structuring of the group TP policy as well as in the representation of clients in case of TP audits and litigations.
Clients include multinationals in different industries and sectors; the TP assistance related to the drafting of the documentation, the entering of APAs with the Italian tax authorities (or in some cases also bilateral APAs, with the USA especially, but also other EU States), as well as TP disputes and litigation where the firm operates truly as a team with litigators and TP experts involved on each file. Examples include assistances in the audit and dispute resolution for financial institutions, leading companies in Digital and tech business, forest industry and renewable products, motorbike sector, as well as NASDAQ multinationals with respect to their PE issues in Italy.
As regards transfer pricing, Raul-Angelo Papotti has been advisor to the Italian Authorities and Institutions for some draft decrees, implementing TP adjustments and procedures, and edited a book titled “Tax Dispute Resolution: A Commentary on the EU Council Directive 2017/1852”, published by Kluwer, reporting the relevant domestic implementing measures of the EU Directive with commentary, relevant case law, and details of mutual agreement procedures (MAPs) and arbitration outcomes.
Hager&Partners was founded in 1995 and today has offices in Bolzano, Milan and Rome. The Firm is composed of approximately 110 staff members, of
which 70 professionals and is member of NEXIA International network. Hager&Partners counts on a fully-dedicated transfer pricing & tax value chain
department: team members positively couple strong knowledge and widespread experience on transfer pricing, business economics, international taxation, internationalization of enterprises, business organization.
The department advises on: design of TP policies
preparation of TP documentation
benchmarking analyses (including any type of financial transactions)
IP box regimes and intangible assets optimization; global expansion services
LED Taxand is an Italian tax law firm with more than 20 tax advisors (lawyers and chartered accountants) and headquarters in Milan. In cooperation with Taxand (www.taxand.com), the world’s largest independent tax organisation with over 550 tax partners and 2.500 tax advisors in 50 Countries, the firm offers customized tax assistance, providing consultancy relating to direct and indirect taxes, fiscal and corporate aspects and opinions.
LED Taxand operates in areas of general fiscal planning and structuring, tax compliance, real estate tax, indirect tax, international taxation, M&A, tax litigation and transfer pricing.