Transfer pricing
LEXIA assists companies operating in international contexts in designing and implementing transfer pricing policies compliant with the arm’s length principle. Our services include functional analysis, selection of the most appropriate methodologies—such as cost-plus or uncontrolled comparables—and the use of benchmarking databases, in line with OECD guidelines and best international practices.
The team supports clients in preparing domestic and international transfer pricing documentation, including comparability analyses, country-by-country reporting, and the management of advance pricing agreements (APAs)—both unilateral and bilateral/multilateral—with tax authorities. We also handle international mutual agreement procedures (MAP) and audits, providing robust tools to prevent or resolve disputes.
LEXIA’s approach includes assistance in disputes initiated by tax authorities, offering rigorous support during audit and litigation phases. We rely on well-established national case law, including the Supreme Court ruling confirming criteria for substantive comparability and the need for comprehensive documentation.
The Transfer Pricing team works in synergy with Corporate, M&A, International Tax, and Wealth Planning practices to offer comprehensive assistance covering tax structuring of international transactions as well as managing reputational and tax risk. LEXIA provides structured support also for global manufacturing models and international value chains.
