Transfer pricing and Patent Box

Italian Version

Intragroup operations to determine the suitable price in transferring the ownership of goods, services and intangibles.

What is Transfer Pricing?

The body of rules and regulations for transfer pricing provided for in Article 10, paragraph 7 of the Italian Consolidated Tax Act is one of the main international taxation issues that every company with subsidiaries abroad or belonging to a multinational group is now called upon to manage and document appropriately.


The context

Carrying out in-depth analysis and studies on transfer pricing is not only an important opportunity for managerial reflections but also an increasingly real need to manage and solve any critical issues concerning correct compliance with tax regulations, in consideration of the high level of focus shown by the tax administration authorities during tax audits.

Transfer pricing is indeed one of the key issues in the life of multinational groups as it influences tax decisions and also has significant implications on administrative processes and the planning and control model.


The service

Servizi Confindustria Bergamo S.r.l. aims to offer companies a high-quality transfer pricing service.


Service objectives

To help companies ‘take a snapshot’ and then analyse their transfer pricing policy in order to understand its compliance with the principles established by tax regulations and the customary practice in order to identify any critical issues or areas for improvement.

Provide companies with analyses and/or studies to document both their transfer pricing policy and the intragroup transactions carried out. This documentation will be of support in the event of tax audits and also for the beneficial regime providing for the waiving of administrative sanctions under Article 1, paragraph 2-subsection 3 of Legislative Decree No. 471 of 18 December 1997.


The intervention areas

Given the complexity of the subject of Transfer Pricing, the service is set up in three modules:

  • Current situation: this activity consists of taking, through a number of meetings with the company’s management, an initial snapshot of the company and the group to which it belongs, focusing on the main intragroup relations and determining the transfer pricing methods adopted, aimed at illustrating strengths and weaknesses, any macro-criticalities and possible areas for improvement;
  • Preparing for a Transfer Pricing study: this activity, subsequent to the analysis referred to in point 1, consists of assisting the company in preparing a Transfer Pricing study, also valid for the beneficial regime providing for the waiving of administrative sanctions;
  • Assistance during eventual tax litigation related to Transfer Pricing: this activity includes assistance in the assessment phase regarding the possible decision to initiate tax litigation (or possible tax assessment settlement and/or court settlement procedures), as well as assistance in preparing appeals and in the subsequent phases and formalities for initiating and managing tax litigation.


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