Magic circle firm Allen & Overy assists numerous national and foreign financial institutions and funds with transfer pricing matters related to their capital markets practices. Both partner Francesco Guelfi and counsel Michele Milanese are experienced in advising financial sector clients on a variety of transfer pricing matters.
Baker McKenzie has a strong transfer pricing practice in Italy, with a focus on M&A transactions, including economic supply and value chain analysis, inter-company transactions, intellectual property analysis and review, and the definition and application of transfer pricing policy. It includes partners Mario D'Avossa and Massimo Giaconia.
The firm is currently assisting pharmaceutical company Zambon with a detailed analysis of its supply and value chain to ascertain the necessary adaptations needed for the client’s centralisation of its R&D activities. It also advised CNH Industrial on the analysis of its value chain focused on intercompany financing between GNH and subsidiary Iveco.
Bonelli Erede Pappalardo Studio Legale is widely recognised as a leading full service law firm in Italy. Its transfer pricing department includes partners Marco Adda and Stefano Simontacchi. Simontacchi is president and member of the board of the firm and is also the director of the Leiden Transfer Pricing Research Center. The firm assists numerous MNEs on all aspects of transfer pricing.
The team is currently conducting analysis for a food and beverage company on its current business model in the Italian market in order to analyse the effects of potential alternative structures for the business to alleviate pressure on its Italian subsidiaries. The firm is also advising a multinational technology company on the new Italian Web Tax, including assisting in the negotiations of an APA on a new transfer pricing policy designed with consideration to the new regulations.
Chiomenti is one of the largest Italian full service law firms, which has developed a significant transfer pricing service. It has a strategic partnership with a number of prominent transfer pricing economists, as well as having numerous professionals competent in advising on transfer pricing matters. The firm frequently represents APAs and MAPs to the authorities, as well as drafting and structuring group transfer pricing policy, especially in obtaining ruling from the authorities in connections to the transfer pricing adjustments made in group reorganisations and transactions. The firm has also developed its practice of transfer pricing litigation and now assists clients during audits and provides representation in disputes.
The team is currently advising Bank of America Merrill Lynch on the restructuring of its Italian operations in anticipation of the consolidation of its three Italian branches into a new centralised Italian hub. Special consideration was given to the opportunity to leverage the new Italian withholding tax exemption on cross-border lending through the transfer of Merrill Lynch's lending business into the new hub.
DLA Piper Studio Legale Tributario has a strong Italian tax team, with expertise in transfer pricing litigation as well as a strong transfer pricing advisory service. The team includes partners Christian Montinari and Federico Pacelli, both of whom are well known for their expertise within transfer pricing. The firm, through its own TP department and its international TP partners, is able to provide a range of transfer pricing services to its multinational clients.
The team recently assisted the Lavazza Group on a revision of the clients entire transfer pricing policy, including advising on the policy in more than 90 jurisdictions where Lavazza operates. The firm also advised VF International in the negotiation of a multilateral APA with the Italian, French Belgian and American authorities, following transfer pricing questions related to the restructuring of VF's business model.
LED Taxand offers a range of transfer pricing solutions to its clients, using both specialists within the firm and the transfer pricing professionals in the wider Taxand network. Partner Stefano Bognandi is the leading transfer pricing expert in the firm. He has more than 20 years of experience dealing with TP, including expertise in business valuations, reorganisations, documentation and engagement with the tax authorities in disputes and discussions.
The firm regularly advises Fortune 500 and listed companies with MAPs/APAs proceedings with the Italian and foreign authorities, as well as assisting on the selection, definition and implementation of a new transfer pricing policy, including providing the economic analysis.
Maisto e Associati is one of the leading Italian law firms operating within transfer pricing. Its transfer pricing department includes founding partner Guglielmo Maisto, as well as partners Aurelio Massimiano and Marco Valdonio, all of whom assist in international tax as well as transfer pricing. Gabriella Cappelleri is another key member of the department who, prior to joining the firm, acted as head of the APA office for the Italian revenue office. Capperelli was also the Italian delegate to the OECD’s Working Party 6 and acted in the implementation of BEPS in Italy.
Owing to the professionals within the department, the firm regularly advises in discussions with authorities regarding APAs. This included advising fashion company Valentino on its successful APA proceedings with the Italian authorities.
PwC is one of the largest firms in Italy, with a significant transfer pricing practice. It uses its Italian specialists alongside the global PwC network to provide a service offering counsel on all transfer pricing matters. It include partners Dario Sencar and Alessandro Caridi. The partners, along with their team, are responsible for conducting value chain and business model analysis, as well as advising on policy adaptation, design and implementation and representing clients in MAP/APA procedures.
The team recently completed a transfer policy review for manufacturer, De Nora. It included analysis of the intellectual property transfer pricing system, resulting in the implementation of a revised policy in order to ensure compliance with the BEPS principles.
KPMG offers a highly sophisticated transfer pricing practice in Italy, with a transfer pricing department including economists, lawyers and tax experts. The firm handles all aspects of transfer pricing analysis of the economic, fiscal and taxation policies of the client, as well as assisting on transfer pricing policy documentation and implementation, including reorganisations and restructurings. It also assists on disputes regarding transfer pricing. Gianni De Robertis is in charge of the Italian TP practice, as well as leading the KPMG TP practice in the EMEA region.
The firm assists a number of MNEs with transfer pricing issues, including assistance preparing global TP documentation with documentation required from 80 jurisdictions at varying levels of the value chain. KPMG also advised on a business restructuring model, allowing for the transfer of risks and functions between multiple companies within the same group, including the analysis and implementation of a transfer pricing policy in line with recent BEPS revisions.
Valente Associati GEB Partners/Crowe Valente is the Italian member firm of Crowe Global, the international accounting and advisory firm. It offers advice for firms conducting transfer pricing reviews in areas including value chain management and representation for MAPs/APAs negotiations and transfer pricing disputes.
The team is currently assisting a leading footwear manufacturer and distributor with a transfer pricing audit initiated by the IRS against its US subsidiary. The US subsidiary was under audit following the company's historic net operating loss, while the company was simultaneously conducting a business restructuring with the parent and US subsidiary company.