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: [email protected]
Phone: +39 0471 288 333
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Dott. Comm. Alessandro Zanellato
Email: [email protected]
Phone: +39 0471 288 333
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Dott. Comm. Stefan Lanznaster
Email: [email protected]
Phone: +39 0471 288 333
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Dott. Comm. Thomas Pichler
Email: [email protected]
Phone: +39 0471 288 333
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Our newsletters – Useful Updates on Tax and Legal Matters
Periodic reporting by delegated directors – reminder for the first half of 2026
Delegated directors must report to the board of directors and the statutory auditors at least every six months on business performance, outlook and major transactions. The documentation for the first half of 2026 should be completed within the third quarter.
Refund of foreign VAT – applications for 2025 to be filed by Wednesday, 30 September 2026
Companies and self-employed professionals may claim a refund of VAT paid in other EU Member States during 2025 up to 30 September 2026. We summarise the procedure, deadlines, minimum amounts and documentation requirements.