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Tax Control Framework

In today’s complex regulatory environment, ensuring effective tax compliance and risk management is crucial for businesses aiming to maintain financial integrity and operational efficiency. We offer specialized expertise in developing and implementing robust Tax Control Frameworks that provide comprehensive oversight of tax processes, responsibilities, and risks. We suggest a modular approach over a multi-year horizon, ensuring flexibility, responsiveness to specific needs, and minimal impact on internal resources. Our services are designed to enhance your company’s readiness for Cooperative Compliance programs, fostering a more transparent and collaborative relationship with tax authorities.

We suggest a modular approach, declined over a multi-year horizon, to ensure flexibility, responsiveness to specific needs, and minimization of impacts on internal resources:

  • Management of Tax Crimes L. 231: Activation of the management and control system for tax-related “crime risks”;
  • Management of Tax Risk: Extending the management system to cover all tax-related risks;
  • Tax Control Framework: Adjusting the system to effectively control tax risks;
  • Cooperative Compliance: Managing procedures for admission to Cooperative Compliance, maintaining admission conditions, and leveraging opportunities.

We conduct thorough assessments of your current tax controls, identify gaps, and implement advanced control mechanisms to mitigate risks. By setting up clear reporting lines and accountability structures, we ensure ongoing compliance and efficiency. Whether you are beginning your compliance journey or looking to enhance existing frameworks, our expert team is dedicated to providing a resilient tax strategy that supports sustainable growth, improves transparency, and positions you favourably in the eyes of regulatory bodies, stakeholders, and the market at large.

Our professionals developed a well-established and recognized thought leadership in Tax Governance and Tax control, with publications and participation to influential institutions.

Environmental, Social and Governance (ESG) reporting

In today’s fast-evolving global landscape, businesses are facing mounting pressures to adopt sustainable practices that align with Environmental, Social, and Governance (ESG) principles. This transition not only reflects a commitment to corporate responsibility but also presents unique opportunities for growth and fulfillment of corporate objectives.

We leverage our expert ESG knowledge to seamlessly integrate ESG management into your operations, primarily aimed at optimized reporting at a cost that balances with potential benefits. Our approach spans over a three-year horizon or more, assuming the involvement of internal resources for the implementation of the intervention plan. We offer comprehensive analyses of how external ESG variables impact your business and vice versa, and assist in developing your ESG strategy including strengths, weaknesses, opportunities, and threats analysis, and setting achievable goals. Our services extend to designing ESG reporting models based on materiality and significance assessments of data, planning interventions for data production necessary for ESG reporting and improving ESG impact and performance indicators. Furthermore, we provide support in project management for monitoring progress and updating intervention plans, as well as assistance in preparing ESG Reporting for 2025 and subsequent years.

Depending on your ESG strategy, we can mobilize specialized competencies in the area of environment (emissions, pollutions, biodiversity, recycle), labour, community, governance and tax and legal framework and ESG data gathering and processing.

We also tailored specific ESG approaches for:

  • Entities below the threshold of application but highly exposed to final consumers’ expectations or subject to information requests from main clients;
  • Subsidiaries of non-EU parent companies, temporarily and directly subjected to the EU reporting;
  • Subsidiaries of EU parent companies, subject to ESG internal reporting to the parent company.

Strategic Transfer Pricing and Value Chain Optimization

In an era of increasing globalization and market complexity, businesses must optimize their performance through agile and systemic approaches. We offer a modular approach to Strategic Transfer Pricing and Value Chain Optimization, ensuring flexibility and responsiveness to specific needs while maintaining a comprehensive view of all relevant aspects. Our services include:

 

  1. Optimization of Marketing Strategies: We provide an external and informed evaluation of your market strategies, identifying options to enhance your topline;

  2. Adjustment of Control Models to Market Repositioning: We improve the control of key commercial variables, particularly the informational quality of costs for assessing margin by channel, market, product/service, and customer. This also creates a stable and defensible base for the Transfer Pricing system;

  3. Alignment of Corporate and Transfer Pricing Models: We strengthen the representativeness, objectivity, and defensibility of your group’s corporate and Transfer Pricing model, managing opportunities and gaps created by changes in marketing policies. This allows for a more reasoned allocation of margins among different operational units, enhancing MBO systems and facilitating the correct preparation of Transfer Pricing documentation for tax purposes.

The value of our integrated approach lies in the overall coherence of the results, as well as the optimization of project time and resources, achieved through the adoption of shared methodologies and the use of a common information base.

Whether you are beginning your transfer pricing strategy or looking to refine existing models, our expert team is dedicated to providing a resilient and optimized approach that supports sustainable growth, improves transparency, and positions you favourably in the competitive global market.

Our professionals developed a well-established and recognized thought leadership in Transfer Pricing, with publications and participation to influential institutions. Depending on your pricing and commercial strategy we collaborate with the global leading pricing and growth specialist consulting firm

Pillar II

In response to the OECD/G20 Inclusive Framework on BEPS, the implementation of Pillar II presents significant challenges and opportunities for multinational enterprises. We offer specialized expertise in navigating the complexities of the Global Anti-Base Erosion (GloBE) rules under Pillar II, which aim to ensure a minimum level of taxation on cross-border profits. Our systematic approach is designed to help your organization comply with these new international tax standards while optimizing your global tax strategy. Our services include the entire spectrum of tax risks to be managed in relation to Pillar II

 

  • Impact Assessment: Conducting comprehensive evaluations of your existing tax structures to determine the potential impact of Pillar II GloBE rules on your global operations;
  • Strategic Planning: Developing tailored strategies to optimize your tax position in light of the new minimum tax requirements, including the identification of potential tax liabilities and opportunities for restructuring;
  • Compliance Implementation / Tax control framework: Assisting with the implementation of robust compliance measures to meet Pillar II requirements, including the preparation of detailed documentation and reports in accordance with GloBE rules;
  • Ongoing Monitoring and Reporting: Providing continuous monitoring and reporting services to ensure ongoing compliance with Pillar II regulations, including the provision of real-time updates on regulatory changes and their implications.

Hybrid Mismatches

In the intricate landscape of international taxation, hybrid mismatches present considerable challenges for multinational enterprises, potentially leading to tax inefficiencies and substantial compliance risks. We provide specialized expertise in identifying and addressing hybrid mismatch arrangements, ensuring your cross-border transactions are structured to minimize tax liabilities and adhere to regulatory standards. Our methodical approach is tailored to meet the specific needs of your organization while maintaining a comprehensive view of all pertinent issues. Our services cover all the needs a multinational enterprise may express in the management of the tax risks originated by hybrid mismatches :

  • Strategic Planning: Developing strategies to neutralize the tax effects of hybrid mismatches in accordance with OECD BEPS Action 2 and EU Anti-Tax Avoidance Directives (ATAD 2), ensuring alignment with global anti-hybrid regulations;
  • Identification and Analysis: Conducting rigorous assessments to detect hybrid mismatch arrangements, including hybrid entities and hybrid instruments, within your corporate structure;
  • Documentation and Reporting: Providing detailed documentation and reporting solutions to enhance transparency and facilitate regulatory scrutiny, ensuring robust defense against tax authority challenges;
  • Regulatory Compliance / Tax control framework: Assisting in the implementation of compliance measures to meet the stringent requirements of anti-hybrid legislation, thereby mitigating the risk of tax base erosion and profit shifting.

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