Transfer pricing and Assets Appraisal
On the basis of our extensive track record acting for important Italian and foreign listed and non-listed corporate groups, we can offer our clients assistance in the valuing of companies and specific assets for various purposes.
We also assist multinational groups in reviewing, documenting, and defending their transfer pricing procedures, from preliminary and functional analysis to the selection of the transfer pricing method.
The team also works on international assignments, drawing on a network of specialised professionals, and provides support on complex deals.
We have extensive experience in valuing companies and intangibles in a variety of sectors. The department’s team of dedicated professionals provides wide-ranging advice in identifying value drivers and key parameters, applying valuation methodologies and advanced simulation techniques of scenario analysis applied - among others - to regulated markets and economic consulting.
Business valuation is an activity that requires not only accounting knowledge, but also industrial, financial, market, tax, and legal knowledge. Examples of the types of valuations we carry out are set out below:
- Valuations required by law (in the context of business transfers, company transformations, tax revaluation of company shareholdings, enforcement procedures, etc.);
- Valuation of intangible assets (including trademarks, licences, IP, software, and patents);
- Valuations of businesses (including groups, individual companies, and business units) for extraordinary transactions;
- Fairness opinions;
- Voluntary valuations as part of the preparation of financial statements, or of transactions involving the purchase or sale of shares or quotas in domestic and foreign companies;
- Valuations for reporting purposes, including Purchase Price Allocation and Impairment test (IAS 36).
- Civil and/or tax revaluations of intangible assets value.
- We also prepare risk assessments for the preparation of company financial statements
The increasing relevance of transfer pricing is a natural evolution of globalisation, of the presence of multinational groups in the most important markets, and of the consequent increase in transnational transactions. These factors in turn have led to international organisations, legislators and financial administrations turning a considerable amount of attention to this area.
We assist clients at all stages of the transfer pricing process and in the preparation of the relevant documentation, such as:
- Analysis of the adopted business model and review of existing transfer pricing policies;
- Assessment of group structure and reorganisation of business and supply chain models;
- Preparation and development of the transfer pricing policy and preparation of the related documentation (“master file” and “country file”) in line with the applicable regulations, recently updated by order 0360494 of 23 November 2020;
- Analysis and drafting of intra-group contracts;
- Management of international standard Ruling procedures;
- Assistance with permanent establishment issues;
- Assistance and support in the conclusion of unilateral and multilateral advance pricing agreements (APAs) with the tax authorities as well as in the course of mutual agreement procedures (MAPs) for the resolution of international transfer pricing disputes
- Assistance and defence during tax assessment and litigation.