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Transfer Pricing

Our professionals, tax lawyers and economists, assist clients on transfer pricing issues from a network present in more than 45 countries.

Our professionals support clients in all aspects of transfer pricing, providing tailor-made solutions.

The right balance of technical-economic knowledge and practical experience enables our professionals to provide strategic yet highly practical support.

 The expertise of our professionals  ranges from the most advanced planning  of transfer pricing policy to the day-to-day management of tax audits, from the preparation of documentation (Master File, Local File, CbCR, defence file) to the integration of transfer pricing policies with other tax and legal issues (VAT, customs, IP, contracts, etc.), including in particular:

  • the implementation of  effective transfer pricing policies for supplies of goods and services, intangible assets and financial relationships
  • the preparation of documentation supporting the transfer pricing applied
  • the preparation of financial and economic studies using databases that are also used by tax authorities
  • assistance and representation in the signing of advanced pricing agreements (unilateral or bilateral) with the relevant tax authorities
  • assistance and representation in connection with tax audits, joint audits or simultaneous audits and in all pre-litigation stages and subsequent litigation proceedings, including legitimacy proceeding
  • assistance and representation in dispute resolution (Mutual Agreement Procedures, bilateral or multilateral) and under the OECD International Compliance Assurance Programme

Explore more

Intragroup services under the microscope: the Italian Supreme Court sets the bar on cost deduction and benefit testing (Judgment No. 5753/2026)

26 Mar 2026 7 min read

Cross‑Border Tax Forecast 2026

26 Feb 2026 2 min read

EU–India FTA – Entering India’s Automotive Market

03 Feb 2026 10 min read

CMS International Disputes Digest – 2025 Winter Edition

17 Dec 2025 3 min read

Pillar One – Amount B: What it is and why it matters

03 Dec 2025 6 min read

CMS Expert Guide to Transfer Pricing Documentation

12 Nov 2025 2 min read

Tax Dispute Resolution: Trends, Tips and Practical Guidance

22 Oct 2025 1 min read

CMS Expert Guide to Pensions

06 Oct 2025 2 min read

Events

  • Italy
    08 Apr 2026

    CMS at Fordham IP & Policy Conference

  • Italy
    16 Apr 2026

    Green claims in focus

  • Italy
    21 Apr 2026

    On the Pulse webinar series 2026 - Spring/Summer

  • Italy
    28 Apr 2026

    IP Insights webinar series 2026

  • Italy
    02 May 2026

    CMS at INTA 2026

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