Transfer Pricing
Transfer pricing is at the center of international tax enforcement, with both the U.S. and Italy imposing strict rules on cross-border transactions between related entities. Taxpayers must demonstrate that intercompany pricing is consistent with the “arm’s length” standard, and failure to do so can result in significant adjustments, penalties, and double taxation. We help clients plan, document, and defend their transfer pricing strategies, ensuring compliance while minimizing financial and operational risk.
Attorneys
Our attorneys advise multinational businesses with operations in the U.S. and Italy on the full spectrum of transfer pricing issues. We assist with setting defensible prices for goods, services, royalties, and financing arrangements; structuring cost-sharing agreements; and preparing documentation that meets regulatory requirements. When disputes arise, we represent clients before U.S. and Italian tax authorities and work through Competent Authority procedures to mitigate double taxation.
In partnership with Marco Q. Rossi & Associati (Of Counsel) we deliver coordinated strategies that align with international standards while reflecting the specific requirements of U.S. and Italian law.