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Transfer pricing

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Transfer Pricing

Our Transfer Pricing team will help you to design and implement transfer price policies in line with your business model, which minimize tax risks.

We have a team formed by economists and lawyers, all of them experts in fiscal matters and with long practical experience in transfer prices.

Scope of our Transfer Pricing service

Planning and design of Transfer Pricing policies:

  • Design and implementation of transfer pricing policies for multinational groups in line with their value chain, which fulfil the full competence principle.

Modification and adaptation of existing policies to reduce fiscal risks.


  • Preparation of documentation on related operations at the level of the group (master file) and of individual companies (local file) with the support of our PKF international network.
  • Assistance in the preparation and presentation of Form 231 - country by country documentation.
  • Assistance in the preparation and presentation of the informative declaration of related operations – Model 232.

Assistance in tax inspections:

  • Assistance in procedures to review related operations undertaken by the tax authority or the provincial tax authorities.
  • Defence of transfer price policies in the application of domestic and international regulations, in line with OECD guidelines and the new BEPS principles.

Due Diligence:

  • Analysis of risk in compliance with transfer pricing policies
  • Quantification of tax contingencies

Benchmarking studies:

  • Preparing benchmarking studies to determine the range of market values
  • Preparation of recommendations and improvements

Prior valuation agreements, amicable and arbitration procedures:

  • Negotiation of prior valuation agreements with the tax authorities to establish the market value of a specific related operation
  • Elimination of international double taxation, in coordination with our global PKF network, through amicable or arbitration procedures.