Italy



World TP Reviews

Transfer pricing
Andersen

Andersen’s transfer pricing team provides specialist expertise in a multitude of areas, including restructuring, cross-border issues, transactions, compliance and hard-to-value intangibles (HTVI’s). Partner and transfer pricing specialist Stefano Rossi is a key individual within the practice. 

The team recently advised on a complex transfer pricing matter relating to the application of patent box tax incentives. It also recently advised Italian client FCA Bank in relation to advanced pricing agreements.  

Manager Antonio della Corte joined the firm in February 2020, while senior manager Elisabeth Barini joined in May 2020.

Baker McKenzie

Baker McKenzie’s transfer pricing team currently consists of six dedicated professionals, specialising in area such as benchmarking, transactions, international tax, restructuring, litigation, MAP’s, APA’s and audit. Partner Michele Santocchini is a key individual within the transfer pricing practice. 

Transfer pricing director Marco Orlandi joined the firm from Ludovici Piccone & Partners in January 2021. 

Baker McKenzie

Baker McKenzie’s transfer pricing team currently consists of 6 dedicated professionals, specialising in area such as benchmarking, transactions, international tax, restructuring, litigation, MAP’s, APA’s and audit. Partner Michele Santocchini is a key individual within the transfer pricing practice. 

Transfer pricing director Marco Orlandi joined the firm from Ludovici Piccone & Partners in January 2021. 

Bird & Bird

Bird & Bird boast a long experience oprofessional expertise in international tax and transfer pricing matters, including TP planning, compliance, audit, litigation, APA’s, documentation and patent box. Senior Counsel Giuliana Polacco is a key individual within the transfer pricing practice. 

The team recently provided litigation assistance to a pharmaceutical company in relation to patent box and R&D tax incentives. It also assisted publishing software company EidosMedia in adopting a new set of transfer pricing policies. 

Chiomenti

The tax department at Chiomenti has developed a market leading transfer pricing practice, providing high profile clients with services including MAP’s, APAs, TP policy, restructuring, audit, litigation, documentation and dispute resolution. Partner Raul-Angelo Papotti is a key individual within the transfer pricing practice. 

DLA Piper

The team at DLA Piper provides assistance on the full range of transfer pricing services, including documentation, compliance, transactions, due diligence, TP planning, supply chain reorganisation, restructuring, APA’s, audit, litigation and financing. Partner and transfer pricing specialist Federico Pacelli is a key individual within the practice.  

The team recently advised on several complex transfer pricing matters, including advising telecommunications company Telecom Italia on TP policy and intercompany transactions. It also advised one client regarding a bilateral APA procedure including the Italian and US tax authorities. This matter involved the transfer pricing policy applicable to a large distribution transaction. 

EY

The transfer pricing team of EY Italy consists of approximately 60 dedicated professionals, specialising in areas such as documentation, TP policy, audit, cross-border transactions, litigation and controversy, MAP’s and APAs. Senior partner and transfer pricing specialist Davide Bergami is a key individual within the practice. 

The transfer pricing team recently advised on a set of connected unilateral APA procedures for a client in the industrial technology and automotive sectors. It also advised on a global transfer pricing documentation project for a major client operating in the energy industry.  

Associate partner Livio Zallo departed the firm for GPBL in April 2021, while senior manager Luca Tortorella left for the same firm in March 2021. 

Hager & Partners

The transfer pricing department of Hager & Partner provides specialist expertise in a range of areas, including benchmarking, documentation, controversy, TP policy, cross-border transactions, restructuring, audit, APAs and MAPs. Partner and head of transfer pricing Gian Luca Nieddu is a key individual within the practice. 

Over the research period, the firm provided one client with litigation in relation to a transfer pricing documentation dispute. It also advised one client in an international tax controversy matter regarding undisclosed permanent establishment and business restructuring. 

Transfer pricing specialist Serena Cresta departed the firm in May 2020. 

Maisto e Associati

The transfer pricing team at Maisto e Associati provide specialist expertise in a number of practice areas, including documentation, TP policy, litigation, MAP’s, APA’s, arbitration, tax optimisation and patent box. It advises client from a range of industry sectors such as fashion, pharmaceuticals, banking, media, digital and consumer goods. Partners Marco Valdonio and Aurelio Massimiano are key individuals within the transfer pricing practice. 

The team recently advised on several complex and high-profile transfer pricing matters. All clients remain confidential. 

Studio Associato – Consulenza legale & tributaria (KPMG)

KPMG Studio Associato’s TP practice is a multidisciplinary team of professionals, including economists, tax experts and lawyers who can carry out advanced economic, tax and financial analyses. The team contains experience advisors in a range of areas, including documentation, audit, dispute resolution, APA’s, MAP’s, litigation and patent box. Partner and head of transfer pricing Gianni De Robertis is a key individual within the practice. 

The team recently provided one client with a comprehensive economic transfer pricing analysis in relation to the impacts of the COVID-19 pandemic. It also provided litigation for one client in a dispute related to the recharging of R&D royalties. 

Studio Tributario e Societario Deloitte | STS Deloitte

Deloitte has the largest TP practice in Italy, with over 80 dedicated transfer pricing professionals. Partner and head of transfer pricing Aldo Castoldi is a key individual within the practice. The team provides specialised services in the areas of controversy and disputes, cross-border transactions, documentation, DAC6 analysis, MAP’s, APA’s, patent box and TP analytics. 

The team recently provided transfer pricing advisory for one client in the automotive sector in relation to a tax reimbursement deriving from the conclusion of a mutual agreement procedure. It also provided transfer pricing and business evaluation consultancy for American medical device company Medtronic. 

Tremonti Romagnoli Piccardi e Associati

The transfer pricing practice of Tremonti Romagnoli Piccardi e Associati provides the full scope of TP services to both Italian and international clients, including documentation, patent box, APA’s, MAP’s, TP policy and litigation disputes. Partner and transfer pricing specialist Simone Zucchetti is a key individual within the practice. 

The transfer pricing team advised on several complex matters during the research period, including assisting consumer credit company Agos Ducato in negotiating and signing a patent box agreement with the Italian tax authorities. This deal was the first of its kind within the Italian consumer credit sector. 

Valente Associati GEB Partners / Crowe Valente

The TP team at Valente Associati GEB Partners Crowe Valente is well-known in the market for their integrated, innovative and business-oriented approach. It provides standard services such as TP policy, litigation, MAPs, APAs and documentation, but also provides services beyond traditional offerings such as pricing optimization, sales and marketing strategies. Transfer pricing specialists Pietro Schipani and Federico Vincenti are key individuals within the practice. 

Case studies show the practice recently provided litigation for one client in a transfer pricing dispute regarding advanced pricing agreements and mutual agreement procedures between Italy and Spain. It also provided one client with global transfer pricing documentation and restructuring services.