The new tax regulations on Transfer Pricing, which apply to operations between related parties, have established obligations for the taxpayer. These regulations affect a wide range of taxpayers: groups of multinational companies, related companies resident in just one country, companies and their relationships with partners and directors, including small companies. These obligations refer to:

• Valuation at market price of transactions between Related Parties.
• The carrying out of balance sheet and off-balance sheet adjustments to reflect free market prices.
• Documentation that must be prepared and retained in relation to these operations.
• The submission, where appropriate, to specific auditing procedure by the Tax Authority.
• The imposition of penalties due to the failure to comply with the documentation requirement.

CIALT, being aware of the need to resolve the problems that our clients face in complying with this demanding legislation, has created a team of professionals specialising in Transfer Pricing. This team, which is well trained and has extensive experience, has been successfully providing consultancy and support services in this area, including the carrying out of all the steps involved in the compliance of the statutory obligations. Among these activities we can highlight the following:

• Design and implementation of transfer pricing policies.
• Carrying out of economic analyses to determine the valuation levels for related operations.
• Tax risk assessment concerning the valuations used in related operations.
• Advice on business restructuring and company acquisition operations.
• Drafting of cost shearing agreements.
• Drafting of management support service contracts.
• Production of documentation relating to the Group of companies.
• Production of the specific document related to taxpayer.
• Negotiation of advance valuation agreements with the Tax Authorities.
• Attendance to tax audits.