Studio Commerciale GS gained significant experience in the set up, analysis and implementation of transfer pricing best practice for International Public companies.

Transfer pricing methodologies have changed rapidly and the impact of the new BEPS implementation must be carefully considered.


Specifically, our firm’s activity encompasses all the stages of a typical transfer pricing analysis:

  • Mapping of activities by means of a qualitative and quantitative description of related-company transactions and identification of the transfer prices adopted and/or to be adopted, in order to focus the analysis on the main risk areas. In this framework, special attention is given to the activities carried out by the Group, the description of the relevant markets, the examination of the Group’s organization chart and of the flow of goods and services.
  • Functional analysis performed after obtaining detailed information on and in-depth understanding of the business and transactions carried out by the companies under study with a view to identifying value-creating factors (functions and risks). In this respect, the analysis is based on the characteristics and the allocation of business functions and risks among Group operations. This stage of the process generally consists of interviews with the company’s management using specific checklists conceived and developed over the years by the firm.
  • Choice of the methodology among those recommended by the OECD and accepted by the Italian tax authorities (basically, price comparison and profit-based methods)
  • Economic analysis consisting in the comparative analysis, based on the methodology chosen, of the prices applied or profit margins obtained in transactions between the companies under study and those of transactions between independent enterprises with similar functions and risks. Specific databases for the identification of comparable transactions and entities are frequently used in carrying out the analysis.
  • conducting transfer pricing studies to determine a fiscally acceptable profit allocation within a group of companies;
  • the valuation of Intellectual Property, a company or specific assets/liabilities;
  • the preparation of transfer pricing (master or local) files and documentation files;
  • the preparation/ review of intercompany agreements;
  • the preparation of specific operational manuals to ensure compliance to the governing transfer pricing model/ strategy;
  • the monitoring and alignment of the transfer pricing policy to the actual transactions conducted within the group;
  • the negotiations of Advance Pricing Agreements with the tax office;
  • representation in transfer pricing audits or disputes with the tax office

At the end of the process, the firm issues documentation compliant with the applicable domestic regulations, which may be produced to validly defend the transfer prices adopted and support future planning.

As a rule, a final report is also issued, complete with the relevant enclosures and translated into all the languages of the Countries where the group operates, summarising the information gathered and the analyses performed in the previous stages as well as the conclusions reached.

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