Audits and litigations between taxpayers and tax authorities on TP issues have grown remarkably over the past 20 years.

Whether an audit focuses on TP of services, tangible or intangible goods, on the assessment of alleged Exit Charges as a consequence of a Business Restructurings, or on the existence of Permanent Establishments (PE) deriving from matrix-type organisational structures, the defensive strategy must be based on:

• A rigorous analysis of the facts, that allows understanding both taxpayer’s and tax authority’s strengths and weaknesses, assessing the actual risk and developing robust economic arguments accordingly; and
• the assistance during the whole process, promptly targeting tax authority’s specific requests through the development of ad-hoc analysis and the preparation of supporting evidences, in order to minimise, if not eliminate, the potential income adjustment and related penalties.

VVA EO gained substantial experience in several tax audits and litigations, assisting taxpayers under different conditions, from the very beginning of the procedure to stepping in during its course to solve complex situations.