LMS Tax Department, with the team led by the partner Felice D’Acquisto and composed of the associate Riccardo Lancia, has obtained the elimination of international double taxation from intra-group transfer pricing through MAP (international mutual agreement procedure under Convention 90/436/EEC and applicable Conventions against double taxation) with Belgium and Japan.


The procedure concerned a leading multinational Group in the automotive sector and the dispute of the Italian Tax Authority was about the transfer prices applied by the Group to the Italian subsidiary for the purchase of vehicles for distribution in Italy in its relations with the Belgian subsidiary and the Japanese parent company.


Previously, LMS had assisted another leading automotive Group in two MAP procedures, one multilateral with the US, Germany, UK and Spain and one bilateral with Germany following a tax audit by the Italian Tax Authority. In the first case, the Italian Tax Authority claim had been strongly reduced and, in both cases, the international double taxation eliminated.

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