Methodology, Functional Analysis and BEPS Compliance
Ciani Partners’ transfer pricing advisory is grounded in a rigorous functional analysis of intra-group transactions and in the application of methods recognised by the OECD Transfer Pricing Guidelines and by tax authorities’ practice. The firm carefully assesses functions performed, risks assumed and assets employed, ensuring that group entities’ remuneration reflects the genuine economic substance of their activities.
- Detailed functional analysis of trading transactions, intra-group services, licensing of intangibles and intra-group financing arrangements.
- Application of traditional methods (Comparable Uncontrolled Price, Resale Price, Cost Plus) and transactional profit methods (Transactional Net Margin Method, Profit Split Method), with a critical assessment of their suitability in each specific case.
- Alignment of transfer pricing policies with substance over form principles, transparency requirements and the BEPS project, with particular focus on Actions 8–10 and 13.
- Periodic review of existing policies to capture timely regulatory changes, business model evolutions and evolving expectations from tax authorities.
Documentation, Tax Audits and Preventive Tools
Ciani Partners assists companies in preparing transfer pricing documentation that complies with tax authorities’ requirements, with specific attention to master file and local file obligations under the BEPS framework and domestic documentation rules. The aim is to provide taxpayers with a comprehensive, consistent set of documents capable of reducing penalty risk and facilitating constructive dialogue with tax authorities.
- Drafting of master file and local file describing the group, value chains, transfer pricing policies and supporting economic analyses.
- Assistance in tax audits and investigations relating to transfer pricing, from initial access through to discussions with the authorities and potential litigation.
- Support in Mutual Agreement Procedures (MAP) and Arbitration Conventions designed to prevent or eliminate double taxation arising from transfer pricing adjustments.
- Evaluation and assistance in obtaining Advance Pricing Agreements (APA) to define, on a preventive basis, the criteria and methods applicable to intra-group transactions.
Companies and Multinational Groups
Companies and multinational groups operating across multiple jurisdictions face significant complexity in transfer pricing, with substantial implications for taxation, cash flows and reputational risk. Ciani Partners supports parent companies, sub‑holding entities and operating subsidiaries in defining an integrated transfer pricing strategy that reflects business needs, regulatory constraints and investors’ expectations.
- Design of profit allocation models among group entities, in line with the economic substance of functions performed and risks assumed.
- Advice on value chain restructurings, relocation of functions and transfers of intangible assets, assessing transfer pricing impacts and implications for direct and indirect taxation.
- Assistance in setting pricing policies for shared service centres, logistics hubs, digital platforms and intra‑group financing structures.
- Support in managing coordinated cross‑border audits and disputes across multiple jurisdictions, focusing on consistency of positions taken and mitigation of double taxation.