International Tax Planning
The increasing internationalization and globalization of business has brought to the attention of companies the need to Consider taxation in a transnational dimension. Proper management of international taxation is crucial for both multinational companies operating in Italy and Italian groups with offices abroad or companies seeking to expand abroad.
Operate within the tax laws of the different countries in which you invest and have a tax strategy aligned with your company structure and business model.
Our highly qualified team of professionals experienced in international issues will assist you in analyzing the international business structure and assessing the relevant tax profiles.
The team provides consulting and advisory services to Italian and foreign multinational groups in international and domestic tax law, direct and indirect taxation, tax litigation, conciliation and adhesion procedures, advice in the application of bilateral treaties against double taxation, Transfer Pricing, Tax compliance for direct, VAT and indirect taxes and refunds to nonresidents.
Specifically, we deal with:
- International tax planning and assessment of related tax impacts
- Taxation of extraordinary corporate transactions
- Analysis and identification of the correct VAT treatment and consequent invoicing methods for transnational business transactions, both within and outside Europe
- VAT aspects related to e-commerce and digital services in general
- Interpretation and application of International Conventions against double taxation on income Taxation of expatriates and impatriates
- Conduct and conclusion of international ruling procedures
- Transfer pricing, intercompany contracting, and conducting benchmark analyses to support transfer pricing policies
Transfer Pricing
Transfer pricing represents one of the major instruments of international taxation. The framework refers to the management of intra-group trade relations and the prices that companies, permanent establishments or in general entities belonging to the same multinational group located in different jurisdictions charge each other for buying and selling goods and services.
Tax rules related to transfer pricing are complex, and governments are increasingly active in examining transfer pricing practices and triggering audit and control actions from which significant penalties can result for improper application and management of the discipline.
Our specialized transfer pricing professionals enjoy solid fiscal and business-economic expertise, support entrepreneurs and companies in resolving transfer pricing issues through analysis and review of procedures and adoption of tax-efficient intercompany transfer pricing policies that comply with Italian and foreign regulations.
Specifically, we deal with:
- Preliminary functional analysis of activities and risks at the group level
- Assistance in the analysis and determination of transfer pricing applied to financial transactions
- Benchmark analyses based on research of comparable companies through the use of domestic and international databases
- Assistance in preparing a set of documentation to support the transfer pricing policies of multinational groups (“Master file” and “Domestic documentation”)
- Support in assessing the impacts arising from the OECD recommendations and the future implementation of the BEPS project.
- Assistance in the conclusion of unilateral and multilateral agreements – Advance Pricing Agreement (International Ruling)
Tax Compliance
The considerable amount of tax compliance and constant changes in the regulatory environment can leave businesses in a position of uncertainty. Often, tax compliance, especially foreign tax compliance, can be a time-consuming and resource-intensive necessity.
The international environment in which companies operate increasingly leads to the need to activate forms of tax identifications such as VAT identifications, Fiscal Representations and Local Branches. These entail the need to handle a whole range of different fulfillments than those in the country of establishment.
Our goals in carrying out our own support activities are:
- The proper management with respect to local regulations of the transactions put in place by the client;
- maximum efficiency of processes intended for the preparation and submission of tax compliance required by local regulations.
The methodology adopted to achieve the set goals includes:
- The preliminary analysis of the customer’s scenario, in accordance with current regulations;
- the process of identifying the client in the country, based on the actual needs;
- the preliminary set-up of information to be shared for the correct compilation of tax compliance;
- the agile sharing of the data necessary to carry out the activity, through Ayming Sphere, a specially dedicated tool;
- total transparency and clarity in the periodic filing of the fulfillments sent on behalf of clients, accompanied by all sending receipts.