Transfer pricing

Implementation of transfer price management procedures for Italian and foreign multinational groups.


The Practice's services cover all phases typical of transfer pricing analysis.


  • Mapping of actions taken by describing the quality/quantity of operations between associate companies and establishing of transfer prices applied and/or to be applied, in order to identify the major risk areas on which the analysis must concentrate. In this context, it is extremely important to survey the Group's activities, a description of the reference markets, and to examine the Group's organisational chart as well as flows of goods and services.

  • Functional analysis carried out by acquiring an in-depth knowledge and understanding of the activities and transactions of the companies being analysed, to identify value creating factors (functions and risks). In this regard, the characteristics and breakdown of the company functions and risks between the various entities within the Group are analysed. This phase is normally carried out by interviewing company management and using specific checklists drawn up and developed over the years by professionals within the Practice.

  • Choice of the evaluation method from among those recommended by OCSE and accepted by the Italian tax authorities (essentially price comparison and profit based methods).

  • Economic analysis carried out using comparative methods, depending on the method chosen, in relation to the prices applied or the profit margins achieved in transactions between the companies being analysed, and those for independent companies with comparable functions and risks. This analysis is often carried out using specific databases to identify "comparable" transactions / entities.