Transfer pricing – Worldwide distributor

The transaction The multinational group, headquartered in Italy, is engaged in the development and manufacture of machines and plants for production of goods belonging to a specific industry sector. In particular, the Italian company  is engaged in the production of machinery and equipments which are then sold to the Group’s foreign subsidiaries engaged in the distribution. Activities carried out An Economic Analysis on Transfer Pricing has been performed to support compliance to the arm’s length principle of the transfer prices applied to the transaction under analysis. Details of the project The work was meant at identifying the proper remuneration of the foreign group distributors. On the basis of the functional analysis performed the latter resulted, in fact, the most appropriate parties to be testified. Considering that the trading partners were located in Europe, USA and Canada with a level of functions and risks lower than those of the Italian company, the tested parties of the transaction were considered the foreign distribution companies on the basis of the OECD guidelines and the Italian transfer prices regulations. For this purpose  ​​two benchmark analyses were performed (one for the European market and the other for the North ...