CUSTOMIZED LEGAL CONSULTANCY FOR YOUR BUSINESS OBJECTIVES

Transfer Pricing remains one of the hottest areas in terms of assessment is evident from the growing number of disputes and from the attention paid to it by the financial administration.

 The peculiarity of this matter depends on the fact that the determination of the correct transfer price passes through an evaluation process that must take into consideration the characteristics of the transactions carried out and the reference markets, the strategies of the company and the group, the assets involved , the functions performed and the risks assumed.

 It will be in the interest of the tax payer to detail these aspects as clearly as possible, in order to provide the administration with the information framework necessary to find the adequacy of the transfer prices adopted.

 Agreeing in advance with the Public Administration, through the use of the international ruling procedure, it is possible also on a bilateral basis, could offer the advantage of avoiding checks and penalties. Furthermore, as clarified by the tax office old communication date d 25 / E / 2014, towards those accessing the procedure, it will be possible to initiate checks only with reference to issues other than those covered by the ruling, in order to prevent the same business model being the subject of a different interpretation.

 Thus, a ruling concerning transfer prices should inhibit further controls, such as those relating to stable hidden organization or other aspects relating to the same business model.

LDP  Transfer Price services

• economic analyzes on databases (AMADEUS and AIDA)  used and recognized by Italian Tax Administrations and international best practice;
• preparation of the entire documentation on transfer price: Country file and master file;
• international tax planning and consultancy on value chain restructuring activities;
• assistance in tax litigation regarding Transfer Pricing and Permanent Establishment

LDP labour lawyers guaranty an efficient, effective and extensive assistance covering all the Human Resource area.

LDP Labour Lawyer Services

• Drafting of employment contracts, including restrictive covenance such as: non competition and non solicitation clauses, Stock Option and RSU plan;
• management of Trade Unions relation;
• employment dispute management;
• disciplinary proceedings;
• collective redundancies drawing up of company regulation;
• detachment agreement
• supporting Clients during the purchase or the sale of going concern business that will impact on the human resource;
• provide Due Diligence on the labor matters.

LDP Legal department during the 27 years of business activity has advised multinational companies from the drafting and the negotiating of the below listed  contracts.

LDP Commercial Law

• drafting and negotiation of commercial agreements governed by domestic or international laws, such as: agency agreement, distribution, stock assignment, logistic;
• Directors Powers drefting;
• Transfer Price Policy preparation;
• Corporate Finance.
• Cross Border Agreement such as:

– cash pooling;
– cost sharing agreement;
– management fees;
– consignment stock;
– distribution;
– royalty agreement.

LDP Legal and Tax Team work often together and this guaranty a unique and professional approach.

LDP corporate law services

– corporate reorganization;
– merger &  demerger;
– equity crowd funding;
– company transformation;
–  company dissolution.

General Data Privacy Regulation (GDPR) is applied in Italy since 25th of May 2018. The GDPR rules prescribe new regulations and replaced to the previous Italian Legislative Decree 196/03 about Pricivay. The new law imply the safeguard of the privacy data on day to day businesses; new measures on the collection of data, access and storage of third parties data, such as clients, suppliers, employees and others can be adopted. 

The Italian Data Protection Agency (DPA) provided since last year useful guidelines that can help local companies to transition to the new system. 

LDP GDPR Services

LDP offer legal assistance on the application of the new data protection regulations, training and set of the necessary documentation.