International Tax, Pillar Two and Transfer Pricing

We assist multinational groups, institutional investors and Italian businesses operating abroad in structuring cross-border flows, managing the complexity arising from global minimum taxation, and designing robust and defensible transfer pricing policies. The goal is to combine efficiency, legal certainty and reputational sustainability in a regulatory environment in constant transformation.

Our activity covers the full spectrum of international taxation: from the analysis of tax residence and permanent establishment to the qualification of cross-border flows, from the negotiation of APAs and MAPs to transfer pricing architectures for industrial and financial groups. On Pillar Two, we assist businesses in the calculation of ETR by jurisdiction, in transitional safe harbours, in GIR compliance and in the impact assessment on holding structures and incentive regimes.

The oversight of transfer pricing is inseparable from the economic valuation of intercompany transactions. For this reason, we integrate within our practice a valuation method tailored to the tax context: from the quantification of intangibles (trademarks, patents, know-how, software, customer base) to the valuation of business divisions and equity interests, from Exit Charge in business restructuring to the determination of fair value and impairment with tax relevance. We combine legal and tax expertise with economic and financial skills, drawing on the contribution of independent valuation specialists where required.

Areas of focus

  • Pillar Two: GloBE, Italian QDMTT, IIR/UTPR, safe harbours, GIR filing.
  • Double tax treaties: interpretation and application, beneficial ownership, anti-treaty shopping rules.
  • Tax residence of individuals, companies and entities; material, personnel and service permanent establishment.
  • Cross-border payments, withholding taxes, anti-hybrid rules, CFC, interest limitation.
  • Transfer pricing: policy design, Master File and Local File, valuation of intangibles and financial transactions.
  • Unilateral and bilateral APAs, MAPs, arbitration procedures under EU Directive 2017/1852.
  • DAC6, automatic exchange of information and management of relations with foreign Tax Authorities.
  • Valuation of intangibles and complex intercompany transactions: trademarks, patents, know-how, software, customer base, royalty rate benchmarking, valuation of intercompany guarantees and financing.
  • Business Restructuring and Exit Charge: design of function reallocations.

Valuations for tax, accounting and litigation purposes: fair value, impairment test, expert appraisals, expert opinion in arbitrations and MAP/APA proceedings.