Transfer pricing – tax compliant and internationally aligned
Intra-group supply and service relationships are regularly a focus of tax audits. Transfer prices that are not properly documented and not structured at arm's length quickly become a weak point with significant tax consequences. We therefore support international groups in the design, adjustment and documentation of their transfer pricing systems in accordance with OECD principles and Italian tax law.
When international structures start to shift
In the case of new business models, relocations of functions and international value chains, transfer pricing systems must grow with the company. The aim is a consistent tax structure that avoids double taxation risks and meets the requirements of international groups.
The focus lies on the development and structuring of transfer pricing models as well as the attribution of profits between group companies and permanent establishments. In addition, we prepare the transfer pricing documentation required under Italian rules, including the Local File and Master File, and support companies in tax audits and mutual agreement procedures.
Your contacts
Dott. Comm. Josef Vieider
Email: vieider@pdc-alliance.com
Phone: +39 0471 288 333
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Dott. Comm. Alessandro Zanellato
Email: zanellato@pdc-alliance.com
Phone: +39 0471 288 333
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Dott. Comm. Stefan Lanznaster
Email: lanznaster@pdc-alliance.com
Phone: +39 0471 288 333
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Dott. Comm. Thomas Pichler
Email: pichler@pdc-alliance.com
Phone: +39 0471 288 333
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Our newsletters – Useful Updates on Tax and Legal Matters
Corrective decree to the tax reform of 7 August 2026 – other changes
Legislative Decree No. 148 of 7 August 2026 introduces numerous further corrections to the tax reform – from income from employment to business and financial income, from VAT to tax assessment and the two-year advance agreement.
Corrective decree of 7 August 2026 and its effects on the mixed use of company cars
The corrective decree of 7 August 2026 (Legislative Decree No. 148/2026) standardises the calculation of the benefit in kind for the mixed use of company cars with retroactive effect from 1 January 2026 and at the same time introduces two new surcharges on the benefit-in-kind value.