Transfer pricing issues are increasingly relevant and complex

Transfer pricing issues are becoming increasingly relevant and, at the same time, imply technicalities and complexities deriving from the growing importance of tax matters for multinational groups, which are facing scrutiny from Tax Authorities, media and consumers.

TP assistance is key to multinational groups willing to manage the cross-border tax issues and aligning them with their business model and organizational structure.


Our solutions

At Bernoni Grant Thornton, a multidisciplinary team of qualified and experienced professionals can provide you with thorough tailor-made assistance with TP.

Step 1

  • check-up of the TP policies adopted and of the TP documentation available, if any
  • identification of the most suitable method for determining or verifying the arm’s length nature of intercompany transactions, relying on specialized databases (Bloomberg, Moody’s)
  • economic analyses to determine the arm’s length value of goods, services and royalties

Step 2

  • definition, planning and implementation of the best pricing policies to meet the group’s specific needs while complying with the applicable rules and domestic and international best practice
  • simulation of TP policies implementation
  • benefit tests in case of Cost Contribution Arrangements and on Management Fees
  • drafting of TP documentation in accordance with domestic and international documentary requirements
  • drafting of intercompany contracts and other TP-related documents in support of the group TP policy

Step 3

  • evaluation of the tax and customs implications of intercompany flow restructuring (PEs, “dummy companies”, CFCs, withholdings, black list costs, VAT, etc.)
  • assistance with restructuring intercompany flows, also in critical stages of a business life cycle (R&R, M&A)
  • assistance with TP-related pre-litigation and litigation procedures
  • assistance with APAs, MAPs and arbitration procedures