Tax

Corporate Tax

Transfer Pricing

Corporate Tax

Our “Corporate Tax” department provides consultancy services to multinational enterprises requiring professional assistance on tax issues involving ordinary business activities as well as extraordinary operations. Our tax team includes top-notch professionals, each of which has acquired long-standing and proven experience in assisting and representing taxpayers before Tax Authorities and Tax Courts.

The “Corporate Tax” team renders consultancy services and assistance on direct and indirect tax matters pertaining to multinational groups, enterprises and private clients.

Support to Tax Compliance

We provide a range of corporate tax compliance services to support the needs of our corporate tax clients, ranging from a fully outsourced tax compliance and advisory function, through the assistance on preparation of tax figures for inclusion in accounts.

Our Services:

Accounting
Bookkeeping
Tax Compliance Outsourcing
Registered Office Services
VAT compliance services
Monitoring overseas group companies’ tax compliance
Full international corporate tax compliance service through out other Crowe Member Firms

Transfer Pricing

In the current globalized economy, it is essential to establish transfer prices that are consistent with the overall policies implemented by corporations and compliant with relevant regulations. Our team assists large multinational corporations in examining and defending policies and procedures concerning transfer prices as well as in drafting the appropriate transfer pricing documentation. In particular, our "Transfer Pricing" team supports the client in the following activities:

Assistance in the development of transfer pricing policies

drafting of relevant documentation (Masterfile, country specific documentation and country by country reporting) according to relevant regulations;
examination and definition of corporate policies related to transfer pricing;
valuation of selected TP methods and verification of their application;
valuation and implementation of “alternative” TP methods;
assistance in the initiation of international ruling procedures;
development of models for measuring and monitoring intercompany transactions;
arrangement of procedures and authorization processes related to the regulation of intercompany relations.

Benchmarking

benchmarking studies at national and international level, carried out consistently with OECD provisions, through well-established methodologies and through the use of the best informative tools and of the most accurate analysis instruments available on the market;
preparation of specific economic and financial analyses in order to support intercompany transactions and business activities.

Assistance during the assessment procedures carried out by Tax Authorities and in the pre-litigation and litigation phases.

We are devoted to guaranteeing solid transfer pricing systems and policies, that are not only supported by economic substance but are entirely consistent with the legal and accounting framework, also in view of the latest BEPS developments.

Country-by-Country Reporting

CbCR regulation poses some challenges for multinational groups:

significant efforts, in terms of time and resources, required of such multinational groups that fall within the Decree’s application scope;
extent of disclosure under such regulation, where sensitive data about the group’s organization and strategy are involved;
Data consistency.

Companies which meet the CBCR requirements need to be ready to provide information on their global allocation of profit, taxes paid, and certain indicators of economic activity.

Financial Services TP

Our integrated team of professionals, including industry specialization, are particularly skilled in managing Financial Transfer Pricing projects, supporting our multinational clients in determining the correct and suitable arm’s length pricing for financial transactions within the group (design – implementation – defense/risk management).

Our team of experts provide assistance and support on the design or review of their TP policies in order to manage financial flows within the group, analyzing companies’ ratings, intra-group financing (loans, cash-pooling, etc.), and assessing potential risks.

Depending on your needs, we can help you on:

Determining the arm's length basis for transactions rewarding;
Providing economic advice on the overall cross border intra-group pricing system selected;
TP design/TP documentation;
Performing the necessary equity and asset related valuations and pricing in the case of organizational restructuring;
Delivering specialized advice in financial economics and transfer pricing to help defending a taxpayer's position in controversy/ negotiations with tax authorities.

Value Chain Analysis

In view of the BEPS changes/recommendations, we developed special inter-relational arm’s length transfer pricing analysis (in which transfer prices reflect the company’s business and tax purposes), which interacts, in turn, with the group value chain and with its value creation.

Mapping and understanding the value chain of a group has become a critical element for every corporate Group (identification of key value-drivers within its industry sector, as well as identification of the value drivers (in combination with a “quantitative analysis”) from which the company’s major risks within its industry might derive.

Our special focus is on:

Identification of key value drivers within a specific company and its industry, detailed analysis of the companies’ assets, functions and risks, assessment of the role of each group entity within the value creation process (definition of roles/responsibilities/risks).
In addition, we combine the latter analysis with an analysis of the so-called “significant people functions” involved in creating key value within a company for a correct allocation of profits. Our Firm is supporting several groups in this innovative and brand-new field.

An Alignment among corporate governance, operating model and tax/Transfer pricing structure is as crucial as an alignment/ syncing of the group economic, legal and financial realities.

Any discrepancies in such alignment might trigger additional tax liabilities.

Depending on your needs, our services might include:

Focus on quantitative aspects of Value Chain Analysis
Determine the need to change strategy and implementation
Specific guidance on how to properly share the profit between investment and profit center
Project management on value Chain Analysis
Assessment on the alignment among corporate governance, operating model and tax/Transfer pricing structure

End-to End TP

Our team assists large multinational corporations in examining and defending policies and procedures concerning transfer prices as well as in drafting the appropriate transfer pricing documentation. We support the top management of enterprises in the definition and in the management of transfer pricing policies also with reference to processes of corporate restructuring.

In particular, our "Transfer Pricing" team supports the client in the following activities:

Assistance in the development of transfer pricing policies:

determination of Group Transfer Pricing Policy (TPP);
definition of best possible Transfer Pricing Methods;
drawing up of comparability analyses;
drafting of relevant documentation (Masterfile, country specific documentation and country by country reporting) according to relevant regulations;
examination and definition of corporate policies related to transfer pricing;
valuation of selected TP methods and verification of their application;
valuation and implementation of “alternative” TP methods;
assistance in the initiation of international ruling procedures;
development of models for measuring and monitoring intercompany transactions;
arrangement of procedures and authorization processes related to the regulation of intercompany relations;
profit allocation to permanent establishments, etc.

Value Chain Transformation

Our TESCM unit, through its integrated and multidisciplinary team followed several projects for key players of the market in the areas of supply chain planning, corporate restructuring and relocation of functions aimed at revisiting and improving value chain efficiency mainly in connection with extraordinary operations (i.e., M&A, etc.).

Our Team is focused on advising and supporting you aligning tax strategies with business initiatives and companies operating models.

Depending on your needs, we can support you on the:

redesigning of business models in business restructuring projects (TESCM projects);
drafting of operating procedures in support of intercompany transactions;
centralization and optimization of intercompany services;
focus on some centralized functions and services (such as R&D and coordination services);
definition of inter-company flows dynamics;
other projects involving Transfer Pricing and business restructurings;
analysis and drawing up of inter-company agreements;
drawing up of CCAs (Cost Contribution Arrangements); etc.

TP Risk Management

Tax risk and transfer pricing: our framework for the valuation of tax risk is based on the strategies used by Tax Authorities for planning audit activities. Based on the risk profile of the subjects involved and on the score assigned, it is possible to calculate a tax risk indicator. With reference to transfer pricing, by predicting the approach of the Tax Authorities, we are able to identify both the price that minimizes the risk for the group and the level of risk to which the group is exposed.

Crowe Valente team helps you recognizing tax and transfer pricing risks and to identifying methods for quantifying/managing transfer pricing risks, through specific risk assessment tools.